IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE O.S.

NO: Plaintiff : Defendant /2012

Peravali Manohara : Kalisam Pullaiah

PLAINT FILED ON BEHALF OF THE PLAINTIFF UNDER ORDER VII, RULE 1 R/W. SECTION 26: C.P.C. 1. Plaintiff : Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residing at D.NO:9/204, Kammaveedhi, 2nd lane, Madanapalle. The address of the Plaintiff is as stated above and also care of Sri B. Bhujanga Rao, B.Sc,LLB,M. Venkatappa, BA,LLB, B. Chandra Sekhar Rao,BA,LLB,M.N.Nagalakshmi, BAL,BL,G.Manohara, BA,LLB, Advocates, Madanapalle. 2. Defendant : Kalisam Pullaiah, S/o. Thippaiah, aged about 60 years, Hindu, residing at Tekulapalem, H/o. Vempalle, Madanapalle Mandal The address of the Defendant is as stated above for all purposes of service

of process, summons, etc., issued from this Honble court. 3. The Plaintiff humbly submits that on 0111-2009, the Defendant borrowed a sum of Rs.10,000/- (Rs. Ten thousands only) from the Plaintiff for his legal necessities and justifiable causes, agreeing to repay the same with interest @24%p.a, on demand either to the Plaintiff or to his order and in evidence thereof, the Defendant executed the suit pronote in favour of the Plaintiff on the even date. 4. Inspite of repeated demands made by the Plaintiff, the Defendant has been postponing to discharge the said debt along-with interest on some pretext or the other and the entire debt is still due. The Plaintiff also caused a legal notice dt:2304-2012 to the Defendant calling him upon to discharge the suit debt and the Defendant, having received the said legal notice, neither sent any reply, nor paid the amount, and thereby, virtually admitted

the contents of the said legal notice. Since the Defendant has been intentionally evading to discharge the Plaintiffs debt, he is constrained to file this suit. 5. The cause of action for this suit arose on 01-11-2009, when the Defendant

borrowed Rs.10,000/- from the Plaintiff and executed the suit pronote, and when the Defendant failed to discharge the said debt inspite of repeated demands and inspite of issuance of legal notice dt:2304-2012 and at Madanapalle, where the

suit transaction took place within the jurisdiction of this Honble court. 6. Particulars of valuation: Principle amount under suit pronote dt:0111-2009: Rs.10,000/Interest on Rs.10,000/- @24%p.a.,

from 01-11-2009 to 10-06-2012 Rs. 6,260/Total Rs.16,260/:

The value of the suit for purpose of court fee and Jurisdiction is Rs16,260/- and a court fee of Rs. of A.P.C.F.Act. 7. PRAYER: It is therefore most humbly prayed that the Honble court may be pleased to Pass a Decree and Judgment in favour of the Plaintiff and against the Defendant: a) By directing the Defendant to pay the suit amount of Rs.16,260/- to the Plaintiff with interest @24%p.a, from the date of suit till realization; b) Award the costs of the suit; and /- is paid under S.20

c) Pass such other or further reliefs as this Honble court deems fit and proper under the Circumstances of the case, in the interest of justice.

Counsel for the Plaintiff Plaintiff Verification The facts stated above are all read over and explained to me in Telugu and admitted herein to be true and correct to the best of my knowledge, belief and information. Madanapalle, Plaintiff Dt:11-06-2012 List of Documents: 1. 01-11-2009 : Original suit pronote executed by the Defendant in favour of the Plaintiff; 2. : Xerox copy of Document no:1. 3. 23-04-2012 : Office copy of legal notice issued by the Plaintiff to the Defendant; 4. : Postal Acknowledgement card.

Counsel for the Plaintiff

IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE O.S.NO: /2012 Plaintiff : Peravali Manohara Defendant : Kalisam Pullaiah Affidavit of the Plaintiff Filed U/s. 26(2): C.P.C. I, Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residing at D.NO:9/204, Kammaveedhi, 2nd lane, Madanapalle, do hereby solemnly affirm and state as follows: 1. I am the Plaintiff in the above suit and Deponent herein. 2. I submit that I have filed the above suit for realization of the suit amount from the Defendant along-with interest and costs basing on the suit pronote dt: 01-112009 and the Plaint pleadings may kindly

be read as part and parcel of this Affidavit for all material purposes. 3. I submit that on 01-11-2009, the Defendant borrowed a sum of Rs.10,000/(Rs. Ten thousands only) from me for his legal necessities and justifiable causes, agreeing to repay the same with interest @24%p.a, on demand either to me or to my order and in evidence thereof, the Defendant executed the suit pronote in my favour on the even date. 4. Inspite of repeated demands made by me, the Defendant has been postponing to discharge the said debt along-with interest on some pretext or the other and the entire debt is still due. legal notice I also caused a to the dt;23-04-2012

Defendant calling upon him to discharge my debt, and the Defendant, for which, also the Defendant has not come forward to discharge my debt. Since the Defendant has been intentionally evading to discharge my debt, I am constrained to file this suit.

5. It is therefore most humbly prayed that the Honble court may be pleased to Pass a Decree and Judgment in my favour and against the Defendant by directing the Defendant to pay the suit amount of Rs.16,260/- to me with interest @24%p.a, from the date of suit till realization; Award the costs of the suit; and Pass such other or further reliefs as this Honble court deems fit and proper under the Circumstances of the case, in the interest of justice. Deponent Solemnly affirmed and signed before me on 11-06-2012 at Madanapalle. Advocate IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE O.S.NO: Plaintiff : Defendant /2012

Peravali Manohara : Kalisam Pullaiah

DUPLICATE PLAINT FILED ON BEHALF OF THE PLAINTIFF UNDER ORDER XVIII, RULE 4: C.P.C. 1. Plaintiff : Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residing at D.NO:9/204, Kammaveedhi, 2nd lane, Madanapalle.

The address of the Plaintiff is as stated above and also care of Sri B. Bhujanga Rao, B.Sc,LLB,M. Venkatappa, BA,LLB, B. Chandra Sekhar Rao,BA,LLB,M.N.Nagalakshmi, BAL,BL,G.Manohara, BA,LLB, Advocates, Madanapalle. 2. Defendant : Kalisam Pullaiah, S/o. Thippaiah, aged about 60 years, Hindu, residing at Tekulapalem, H/o. Vempalle, Madanapalle Mandal The address of the Defendant is as stated above for all purposes of service of process, summons, etc., issued from this Honble court. 3. The Plaintiff humbly submits that on 0111-2009, the Defendant borrowed a sum of Rs.10,000/- (Rs. Ten thousands only) from the Plaintiff for his legal necessities and justifiable causes, agreeing to repay the same with interest @24%p.a, on demand either to the Plaintiff or to his order and in evidence thereof, the Defendant executed the suit pronote in favour of the Plaintiff on the even date.

4. Inspite of repeated demands made by the Plaintiff, the Defendant has been postponing to discharge the said debt along-with interest on some pretext or the other and the entire debt is still due. The Plaintiff also caused a legal notice dt:2304-2012 to the Defendant calling him upon to discharge the suit debt and the Defendant, having received the said legal notice, neither sent any reply, nor paid the amount, and thereby, virtually admitted the contents of the said legal notice. Since the Defendant has been intentionally evading to discharge the Plaintiffs debt, he is constrained to file this suit. 5. The cause of action for this suit arose on 01-11-2009, when the Defendant

borrowed Rs.10,000/- from the Plaintiff and executed the suit pronote, and when the Defendant failed to discharge the said debt inspite of repeated demands and

inspite of issuance of legal notice dt:2304-2012 and at Madanapalle, where the

suit transaction took place within the jurisdiction of this Honble court. 6. Particulars of valuation: Principle amount under suit pronote dt:0111-2009: Rs.10,000/Interest on Rs.10,000/- @24%p.a., from 01-11-2009 to 10-06-2012 Rs. 6,260/Total Rs.16,260/The value of the suit for purpose of court fee and Jurisdiction is Rs16,260/- and a court fee of Rs. of A.P.C.F.Act. 7. PRAYER: It is therefore most humbly prayed that the Honble court may be /- is paid under S.20 : :

pleased to Pass a Decree and Judgment in favour of the Plaintiff and against the Defendant: a) By directing the Defendant to pay the suit amount of Rs.16,260/- to the Plaintiff with interest @24%p.a, from the date of suit till realization; b) Award the costs of the suit; and c) Pass such other or further reliefs as this Honble court deems fit and proper under the Circumstances of the case, in the interest of justice.

Counsel for the Plaintiff Plaintiff Verification The facts stated above are all read over and explained to me in Telugu and admitted herein to be true and correct to

the best of my knowledge, belief and information. Madanapalle, Plaintiff Dt:11-06-2012 List of Documents: 1. 01-11-2009 : Original suit pronote executed by the Defendant in favour of the Plaintiff; 2. : Xerox copy of Document no:1. 3. 23-04-2012 : Office copy of legal notice issued by the Plaintiff to the Defendant; 4. : Postal Acknowledgement card. Counsel for the Plaintiff

IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE O.S.NO: /2012

Plaintiff : Peravali Manohara Defendant : Kalisam Pullaiah Affidavit of the Plaintiff I, Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residing at D.NO:9/204, Kammaveedhi, 2nd lane, Madanapalle. , do hereby solemnly affirm and state as follows: 1. I am the Plaintiff in the above suit and Deponent herein. 2. I submit that I have filed the above suit for realization of the suit amount from the Defendant along-with interest and costs basing on the suit pronote dt: 01-112009 and the Plaint pleadings may kindly be read as part and parcel of this Affidavit for all material purposes. 3. I further submit that the Defendant,

having borrowed the amount from me long back in the year, 2009, has been intentionally evading to discharge my debt and so far, he has not paid even a copper coin to me. The Defendant is also indebted to several other creditors like me and he is the rightful owner of the petition schedule Property. In order to disable his creditors like me, the Defendant has been making hectic efforts to alienate the

petition Schedule Property and serious negotiations have been going on in this regard. Except the Schedule Property, the Defendant has no other Property and if the Defendant succeeds in his unlawful attempts, I will not be in a position to enjoy the fruits of the decree that may be passed in my favour. Thus, to protect my interest to realize the amount from the Defendant, it is just and essential to attach the Schedule Property. Hence, this petition. 4. It is therefore most humbly prayed that the Hon'ble court may be pleased to ATTACH the Schedule Property BEFORE JUDGMENT, for the above submitted reasons, in the interest of justice. Or else, I will be put to serious loss and great hardship. Deponent Solemnly affirmed and signed before me on 11-06-2012 at Madanapalle Advocate IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE I.A.NO: /2012

O.S.NO:

/2012

Petitioner/ Plaintiff : Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residing at D.NO:9/204, Kammaveedhi, 2nd lane, Madanapalle. Respondent/ Defendant : Kalisam Pullaiah, Thippaiah, aged about 60 years, Hindu, residing at Tekulapalem, Vempalle, Madanapalle Mandal

S/o. H/o.

PETITION FILED ON BEHALF OF THE PETITIONER/ PLAINTIFF UNDER ORDER 38, RULE 5 R/W. S.151, 94(e): C.P.C. That for the reasons stated in the enclosed affidavit, it is therefore most humbly prayed that the Hon'ble court may be pleased to ATTACH the Schedule Property BEFORE JUDGMENT, in the interest of justice. Or else, the Petitioner will be put to serious loss and great hardship. Madanapalle, the Petitioner/ Plaintiff Dt:11-06-2012 counsel for

SCHEDULE Chittoor DistrictMadanapalle subdistrictVempalle Revenue village Landed

Property bearing 1. Sircar Dry S.NO:1308 40 cents 2. Sircar Dry S.NO:1490 50 cents 3. Sircar Dry S.NO:1333 73 cents

Ext.Ac.3Ext.Ac.5Ext.Ac.-3-

With all fruit bearing trees, water sources, etc.,. Counsel for the Petitioner/ Plaintiff

IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE Plaintiff : O.S.NO: 230/2012 Peravali Manohara

Defendant : Kalisam Pullaiah CHIEF-EXAMINATION AFFIDAVIT OF P.W.-1 FILED UNDER ORDER 18, RULE 1 : C.P.C. I, Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residing at D.NO:9/204, Kammaveedhi, 2nd lane, Madanapalle, do hereby solemnly affirm and state as follows: 1. I am the Plaintiff in the above suit and Deponent herein. 2. I submit that on 01-11-2009, the Defendant borrowed a sum of Rs.10,000/(Rs. Ten thousands only) from me for his legal necessities and justifiable causes, agreeing to repay the same with interest @24%p.a, on demand either to me or to my order and in evidence thereof, the Defendant executed the suit pronote in my favour on the even date. 3. Inspite of repeated demands made by me, the Defendant has been postponing to discharge the said debt along-with interest on some pretext or the other and the entire debt is still due. I also caused a legal notice dt;23-04-2012 to the Defendant calling upon him to discharge my debt, and the Defendant, for which, also the Defendant has not come forward to discharge my debt. Since the Defendant has been intentionally evading to discharge my debt, I am constrained to file this suit.

4.

It is therefore most humbly prayed that the Honble court may be pleased to Pass a Decree and Judgment in my favour and against the Defendant by directing the Defendant to pay the suit amount of Rs.16,260/- to me with interest @24%p.a, from the date of suit till realization; Award the costs of the suit; and Pass such other or further reliefs as this Honble court deems fit and proper under the Circumstances of the case, in the interest of justice. Deponent

Solemnly affirmed and signed before me on 09-04-2013 at Madanapalle. Advocate List of Documents sought to be marked as Exhibits: Ex.A-1:01-11-2009 : Ex.A-2:23-04-2012 : Ex.A-3: : Original suit pronote executed by the Defendant in favour of the Plaintiff; Office copy of legal notice issued by the Plaintiff to the Defendant; Postal Acknowledgement card. Counsel for the Plaintiff IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE Plaintiff : O.S.NO: 230/2012 Peravali Manohara

Defendant : Kalisam Pullaiah CHIEF-EXAMINATION AFFIDAVIT OF P.W.-2 FILED UNDER ORDER 18, RULE 1 : C.P.C. I, Valligatla Ramakrishna, S/o. Venkatramana, aged about 32 years, Hindu, Mason, residing at Malepadu village an post, do hereby solemnly affirm and state as follows: 1. I am the Plaintiff in the above suit and Deponent herein. 2. I submit that on 01-11-2009, the Defendant borrowed a sum of Rs.10,000/(Rs. Ten thousands only) from the Plaintiff for his legal necessities and justifiable causes, agreeing to repay the same with interest @24%p.a, on demand either to the Plaintiff or to his order and in evidence thereof, the Defendant executed the suit pronote in favour of the Plaintiff on the even date. 3. On the date of execution, i.e., on 01-11-2009, I accompanied the Defendant at his request to the Plaintiffs house and at the time of execution, myself, the Plaintiff, the Defendant were present. In my presence, the Plaintiff lent the sum of Rs.10,000/- to the Defendant and the Defendant after counting the amount, himself scribed the suit pronote under Ex.A-1 and subscribed his signatures across the two Revenue stamps and beneathe the same in telugu. He also subscribed his signature as scribe in the scribe column. Thereafter, I signed as attestor in Ex.A-1. Thus, the suit transaction took place in my

presence and the Defendant became indebted to the Plaintiff to the tune of Rs.10,000/-. Deponent Solemnly affirmed and signed before me on 09-07-2013 at Madanapalle Advocate