IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE AT SIRCILLA

O.S. No. of 2023

Between:
Annarapu Srinivas
…Plaintiff
And
1. Konda Raju
2. Konda Venu

…Defendants

Sub:- Suit for perpetual injunction restraining the defendants, their family
members, agents and workmen etc. from entering into and interfering
with the peaceful possession and enjoyment of the Plaintiff over his
agricultural lands admeasuring 633 Sq Yards out of Sy. No. 72/C out of
total extent 3-00 Acres situated at Shanti Nagar locality of Siricilla Town &
Mandal of Rajanna Sircilla District, as boundaries mentioned in the
schedule annexed hereto.

PLAINT UNDER SECTION. 26, ORDER. 7, RULE. 1 R/W CPC

May it please your Honour,
The above named Plaintiff submits as under:-
1. Name and Address of the Plaintiff:
Annarapu Srinivas w/o. Late Annarapu Ballaya, aged 40 years, occ: Business, r/o.
H.No. 2-7-33, Sanjeevaya Nagar locality of Siricilla Town & Mandal of Rajanna
Sircilla District
The address of the Plaintiff for the purpose of service of all notices and process is as
stated above and also is c/o. RK LAW ASSOCIATES, AVUNOORI RAMAKANTH
RAO, ADVOCATE, SIRCILLA of Rajanna Sircilla District.
2. Names and Address of the Defendant:
1. Konda Raju s/o. Late Konda Venkatesham, aged 45 years, occ: Business
2. Konda Venu s/o. Late Konda Venkatesham, aged 43 years, occ: Business
Both are r/o. H.No 5-7-45, Siddulawada Locality of Siricilla Town & Mandal of
Rajanna Sircilla District
The address of the defendants for the purpose of service of summons and all
processes is as stated above.
…Contd. Page 2
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3. That the plaintiff is the absolute owner, possessor and occupant of the agricultural
lands bearing Sy. No. 72/C admeasuring 3-00 Acres situated at Shanthi Nagar locality of
Siricilla Town & Mandal of Rajanna Sircilla District, as boundaries mentioned in the
schedule annexed hereto, which is hereinafter called as suit schedule lands.

4. Previously, the father of the Plaintiff by name late Annarapu Balayya was the
absolute owner and possessor of the Agriculture land bearing SY. No 72/C measuring
3-00 Acres. He died in the year 2010 leaving behind the Plaintiff as his sole legal heir.
After his demise, the plaintiff succeeded the suit's scheduled property by way of
succession. Plaintiff's name also entered in revenue records & concerned revenue
authorities issued Pattadar passbook & titled deed in favor of the Plaintiff in respect of the
suit scheduled land & issued new digital Pattadar passbook & title deed vide booklet
number T19080050603 & Katha Number 2781 and continuing the same till today. From
the succession of suit scheduled land from his father the plaintiff is in peaceful possession
and enjoyment of suit scheduled land till this day by raising seasonal crops therein.
To prove his title and upto date possession over the suit schedule land, the plaintiff is
herewith filing his Original New Pattadar passbook cum Title deed, Original Old Pattadar
passbook & Title deed, CC of Pahani for the year 2016-17 attested by the Naib Tahsildar
original mutation proceeding copy issued by the Tahsildar, Siricilla, Mee Seva pahanis for
the year Fasli no. 1423, dated: 28/9/2013, Fasli no. 2017, dated 5/9/2018, Fasli no. 1425,
dated 25/2/2016, Fasli no. 2017, dated 14/3/2019 and Online pahanies, obtained from
Dharani website, Survey report conducted by the deputy inspector of Survey attested by
the Divisional Administrative Office of RDO office under a list, for kind perusal of this
Hon’ble court.
5. That the defendants are natural brothers and sons of Late Konda Venkatesham
(Who died in the month of February 2023) & they are strangers to the suit schedule lands
of the plaintiff, as they have no rights or interests whatsoever over the suit schedule lands
of this plaintiff. The defendants no. 1 & 2 are being adjacent land owners of plaintiff,
having their land towards the Southern side of suit schedule land, developed ill intention
and coveted eye against the plaintiff and his suit schedule land and with an intention to
occupy the same, started causing recurring interference with the peaceful possession and
enjoyment of the plaintiff over his suit schedule land with an intention to occupy the
same, but the plaintiff resisted the illegal acts of the defendants and remained in
possession thereof. The defendants kept silent for some period and finally on: 15/04/2023
at Shanti Nagar Locality of Sircilla Town & Mandal of Rajanna Sircilla District, came to
the suit schedule lands and tried to obstruct the plaintiff from doing his work in the suit
schedule land with an intention to occupy the same, but the plaintiff with the help of his
family members and well wishers, resisted the illegal acts of the defendants and remained
in possession thereof. The defendants left the suit schedule lands by threatening the
plaintiff that they would come and occupy the suit schedule land one or other day with
their brutal force, hence the cause of action to file this suit against the defendants for the
relief of injunction simpliciter and the defendants is liable to answer the same.

6.