By Regd Post with Ack-due

Kadapa,
23-05-2018.
From:-
1. Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District
2. Sri.M.Ramanjaneya Reddy M.A., B.L
Advocate
Door No:-2/468-1 Up stares,
Nagarajupet,
Kadapa city post and District
To:-
Sri.S.Ravi Kumar B.A., B.L
Advocate
Door No: 1/1821-1,
Near Apparao Buildings,
Yerramukka Palli,
Kadapa city post and District.
Sir,
Sub: Reply notice for your legal notice dated 16-05-2018 – Rg.
Under the instruction and on behalf of our client Sri.V.S. Prabhakar
Reddy S/o Reddenna Door No: 40/582-1-A-2 Challa compound, Dhrama
pet, Kurnool city, we herely issue this reply notice to you for your legal
notice dated 16-05-2018 issued on behalf of your clients 1.V.Priyanka
aged about 16 years and 2. Reddappa Reddy aged about 14 years minors
represented by their mother Smt.V.Sylaja Residing at 44/167-1
Chemmumiya pet, Kadapa City with the following facts.
1. Our client does not know whether your clients are the issues
of V.Ramanjula Reddy and that Sylaja is the wife of V.Ramanjula Reddy.
Your legal notice falsely alleges that Ramanjula Reddy addicted to bad
habits and creating nuisances to your clients since 20 days is totally false
and created for issuing your false legal notice on their behalf. The said
Ramanjula Reddy is not at all addicted to bad habits. Our client has every
right to demand your clients to vacate your notice schedule property
since Ramanjula Reddy is not paying rents to our client from January
2018 upto now. The said V.Ramanjula Reddy has no right or authority to
live in the house of our client without paying rents to our client.
2. Our client deny the allegation that the schedule property is
mortgaged property for Rs. 7,34,000/-. One Vadlatala Ramanjula Reddy
son of Reddenna sold you notice schedule property to our client on 01-
01-2015 under a registered sale deed No: 2/2015 and got the delivery of
that property on 01-01-2015 from that vendor named Vadlatala
Ramanjula Reddy. The said Vadlatala Ramanjula Reddy completely
vacated your notice schedule property on 31-12-2014 and delivered the
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possession of that house to our client on 01-01-2015 by virtue of that
registered sale deed No. 2/2015 executed by that Vadlatala Ramanjula
Reddy in favour of our client. Our client got the possession of your notice
schedule property on 01-01-2015 and carried out repairs to bath room
lavatory, painting to the building electrical repairs etc and leased out that
house to Vadlatala Ramanjula Reddy for the rent of Rs. 3,000/- per
month under oral lease on 10-02-2015. That Vadlatala Ramanjula Reddy
was paying rent regularly to our client upto the end of December 2017
but not paying the rents from January 2018 upto now.
3. The sad Vadlatala Ramanjula Reddy defaulted to pay the
arrears of rent of Rs. 12,000/- to our client from January 2018 to April
2018. So our client legally demanded Vadlatala Ramanjula Reddy to
vacate your notice schedule house requiring that house for laying R.C.C
roofing by removing cements sheets on the up stair for his self-
occupation. The sale deed deed 01-01-2015 was identified and attested
by Vadlatala Sakuntalamma being the wife of Vadlatala Ramanjula Reddy.
4. Your notice is falsely alleging that your notice schedule
property is ancestral of Vadlatala Ramanjula Reddy. The said Vadlatala
Ramanjula Reddy purchased your notice schedule property under
registered sale deed No. 539/1968 dated 12-02-1968 for Rs. 100 from
Ponnolu Pali Reddy. Hence your notice schedule property is not at all the
ancestral property of Vadlatala Ramanjula Reddy. Your notice schedule
property is self-acquired property of Vadlatala Ramanjula Reddy and that
Vadlatala Ramanjula Reddy made valid sale deed on 01-01-2015 in favour
of our client by taking valid sale consideration of Rs. 7,34,000/- from our
client. Your clients have no authority to deny the title and right of our
client for demanding your clients for vacating the premises. Our client
strongly believes that your clients with active collusion of Vadlatala
Ramanjula Reddy issued your false notice with malafide intention for
wrongful gain.
5. Therefore please take this legal notice and advise your clients
to vacate the premises by the end of June 2018 and deliver vacant
possession of that house to our client. Otherwise our client is forced to
file R.C.C in the Rent Control Tribunal at Kadapa for evicting them from
your notice schedule property by holding Vadlatala Ramanjula Reddy and
his issues liable for costs and consequences and costs of this reply notice
Rs. 2,000/-.

Advocates