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By Regd Post with Ack-due

Kadapa,
08-12-2018.
From:-
Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District.
To:-
Smt. Tanneru Sharon
W/o. Shouri Rajan
Door No.4/334, Vivekananda Nagar colony,
Kadapa city.
Madam,
Sub:- Legal notice for cancellation of decree dated 22-08-2008
passed in O.S No.426/2007 on the file of Principal Junior Civil Judge court
at Kadapa – Rg.
Under the instructions and on behalf of my clients
1. Tammisetty Pedda Nagaiah S/o late Chinna Nagaiah
and husband of late Naga Lakshumma, 2. Nagamani
W/o Venkata Subbaiah and daughter of late Naga
Lakshumma, 3.Tammisetty Naga Rajendra Prasad S/o
Pedda Nagaiah and Naga Lakshumma residing in
Kadapa city, 4.Venkata Lakshumma W/o Raju and
daughter of Naga Lakshumma residing at Vempalle
and 5. Tammisetty Venkatrama Kumar S/o Pedda
Nagaiah and Naga Laksumma residing at Kadapa city,
and that my clients 1,3 and 5 are residing at door :
39/455-3 house, Om Santi Nagar Kadapa city, I hereby
issue this legal notice to you with the following facts:-
1. My client came to know during May 2018 that you got ex-
parte decree on 22-08-2008 in O.S No.426/2007 on the file of Principal
Junior civil Judge court at Kadapa against Tammisetty Naga Lakshumma
who is the wife of my first client and mother of my clients 2 to 5 for the
schedule property secretly without serving court summons, notices etc
on Tammisetty Naga Lakshumma by playing fraudulent game against
Tammisetty Naga Lakshumma and my clients for making wrongful gain
of schedule property.

2. Late Tammisetty Naga Lakshumma W/o Pedda Nagaiah being


the wife of my first client and mother of my clients 2 to 5 were living at

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door No.42/290-22 in Bhagya Nagar colony Kadapa city from 2006 for
six years upto 2012 years and voters identity cards, Fair price shop
family member card were issued by showing the residence of
Tammisetty Naga Lakshumma and my clients 1, 3 and 5 at door
No.42/290-22 Bhagya Nagar colony Kadapa city issued in the name of
Tammisetty Naga Lakshumma. Later Tammisetty Naga Lakshumma with
her family members shifted their residence to Chinna Chouk in Kadapa
city during 2013 year and lived there for four year and later shifted to
Om Santi Nagar to door No.39/455-3 house in Kadapa city. Tammisetty
Naga Laksumma purchased the schedule property on 16-06-1997 from
Karnati Krishna Reddy and his wife Karnati Bramaramba for Rs.7500/-
under registered sale deed No.2874/1997 and that women did not sell
that property to anybody. The said Tammisetty Naga Lakshumma died
on 13-11-2017 by leaving the schedule property to my client with all
rights and without selling or making any testament in favour anybody.

3. You took summons to Naga Lakshumma to door No.4/343-1A


Vivekananda Nagar colony in Kadapa city instead of door No.42/290-22
Bhagya Nagar colony Kadapa city wherein Naga Lakshumma was
residing with fraudulent intention for the purpose of taking exparte
decree in O.S No. 426/2007 for the schedule with the motive to knock
away the schedule property of Tammisetty Naga Lakshumma. You did
not take notice in E.P No.198/2009 to Tammisetty Naga Lakshumma to
door No.42/290-22 Bhagya Nagar colony Kadapa city in 2009 year with
the sale motive of playing fraud on Tammisetty Naga Laksumma. My
clients submit that the wife of my first client and mother of my clients 2
to 5 did not execute any agreement of sale 10-09-1999 in favour of you
for the schedule mentioned property. My clients submit that you forged
the L.T.I of Tammisetty Naga Lakshumma on the alleged agreement of
sale dated 10-09-1999 for knocking away the schedule property of
Tammisetty Naga Lakshumma. My clients raised the foundation in the
schedule property about one year ago by spending Rs.10,000/- in your
presence. You did not oppose my clients from laying foundation in the
schedule property.

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4. My clients come to know about the decree in O.S No.426/2007
during May 2018 through some persons and applied for certified copy of
decree in O.S No.426/2007 during august 2018 and got that decree on 14-
09-2018 and taking steps for filing the suit for cancellation of that decree.
You have no right or title or authority over the schedule property since you
took the decree in O.S No.426/2007 on 22-08-2008 by playing fraud on the
court as well as on Tammisetty Naga Lakshumma. Hence my clients are
forced to file the suit against you for cancellation of the decree in O.S
No.426/2007 dated 22-8-2008.

5. Therefore please take this legal notice that the ex-parte decree
in O.S No.426/2007 dated 22-08-2008 is not valid in law since you played
fraud on the court as well on T.Naga Lakshumma in getting the ex-parte
decree in O.S No.426/2007 on 22-08-2008 and that you should not claim
title and right over the schedule property. Otherwise my clients are forced
to file civil suit against you in the court of law for the schedule property by
holding you liable for costs and consequences.

Schedule
Immovable house site property situated in Chinna Chouk village
fields within the limits of Kadapa Municipal Corporation Kadapa urban
Sub-district and Kadapa district.
1. S.No.843/2 extent 0.88 cents.
2. S.No.842/1 Extent 0.86 cents.
Boundaries:
East - Vanka Poramboke
West - Site of Veera Reddy.
North - Road
South - property of others.
East to West – 25 links or 5.08 meters.
North to South – 60 links or 12.18 meters
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