By Regd Post with Ack-due

Kadapa,
09-06-2018.
From:-
Sri.K.Venkata Reddy B.com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District.

To:-
Sri.C. Sankar Reddy,
S/o.C. Ponna Reddy
Cool Drinks Shop,
Obulavaripalle Town, Post & Mandal,
Pin Code No: 516108,
Rly. Koduru erstwhile Taluk,
Kadapa District.
Sir,
Sub:- Second legal notice issued to you U/s 10 of A.P Building
control Act 1960 R/w section 106 of T.P Act for evicting you from the
schedule property of my client – Rg.
***
Under the instructions and on behalf of my client Sri. Kommuru
Somi Reddy, S/o Sidda Reddy and his father Sidda Reddy, Residing in
Obulvaripalle Town, Post & Mandal, Kadapa District, I hereby issue this
second legal notice to you with the following facts.

1. The schedule property originally belonged to paternal

ancestors of my client named Kommuru Chinna Narasa Reddy and
Yasodamma. Kommuru Chinna Narasa Reddy died long ago by leaving his
estate to his wife named Kommuru Yasodamma. The paternal
grandmother of my client named Yasodamma surrendered the schedule
property to the Mandal Revenue Officer of Obulvaripalle for granting
D.K.T. patta to my client. Thereafter the Mandal Revenue Officer of
Obulvaripalle Mandal granted D.K.T Patta No: 506/1409 dated 08-04-
1999 to my client for the schedule property. My client constructed Zink
Sheet house in the schedule property during 1999 and enjoying the
schedule property. My client about 2 years ago orally leased out the Zink
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sheets house as mentioned in schedule to you for the monthly rent Rs.
1,000/- under oral lease. You have been running Cool Drink Shop in that
Zink sheet house property. You agreed to pay the rent of Rs: 1,000/- to
my client as per oral lease agreement, but you are not paying the rent to
my client with fraudulent motive since 8 months. My client is devotee of
GODS and visiting the temples and Ashrams very often. My client is
residing in Obulvaripalle as well as in other places in obedience to the
devotion to the GODS for sub-missing of his puja as per his Bhakti yoga.
So it is not correct to say that my client is not residing in Obulvaripalle for
the last 20 years. The parents of my client about 3 months back took my
client to Tirupati S.V.I.M.S and other hospitals at Tirupati for treatment
for the diseases of my client. My client is in the good habit of visiting
temples and Ashram and staying there for some period for realization of
GOD.
2. You issued totally false reply notice dated 12-04-2018 to my
client through your advocate Sri.S.Ravindra and Smt.S.Rama Devi in
response to the legal notice of my client dated 22-03-2018. You are not
the tenant of Kommuru Yasodamma since she surrendered the schedule
property and other properties to M.R.O of Obulvaripalle for granting
D.K.T patta to my client and her other legal heirs. You agreed to pay rent
Rs.1,000/- to my client as agreed upon by you under oral lease
agreement about 2 year ago. You falsely stated the rent as Rs.500/-
instead of Rs.1,000/-. That Akepati Venkata Subba Reddy has no right or
authority to take the rent from you for the schedule property of my
client.
3. My client, his brothers and father are the legal heir for the
property of Kommuru Yosodamma wife of China Narasa Reddy since my
client is the grandson of the elder brother of China Narasa Reddy. Akepati
Venkata Subba Reddy is not the son-in-law of Kommuru Yasodamma
since Kommuru Yasodamma had no daughter and that Yasodamma died
issueless. That Akepati Venkata Subba Reddy is not the family member of
Kommuru Yasodamma since that Akepati Venkata Subba Reddy is a farm
servant of Yosodamma looking after the fields, buffaloes etc of
Yasodamma. My client and his brothers and his parents are the family
members of Yasodamma factually and also as per the deposition of
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Yasodamma in OS No: 4/2006 as they were kept by Yasodamma in her
house since 20 years. So my client, his brother and his parents are the
family member of Yasodamma. The SENIOR CIVIL JUDGE COURT at
Rajampeta did not accept the family member certificate issued by
Tahsilder of Obulvaripalle Mandal to Akepati Venkata Subba Reddy in OS
No: 4/2006 as the legal heir of Kommuru Yasodamma.
4. The alleged false will dated 19-04-2014 speaks that
Kommuru Yasodamma maintained Akepati Venkata Subba Reddy as farm
servant and that 67 years aged farm servant was not taken as either
adopted son as per Hindu Adoption act or treated as family member of
Yasodamma. So Akepati Venkata Subba Reddy or Kommuru Tandava
Krishna Reddy or Kommuru Ramachandra Reddy are not at all the legal
heirs for the property of Yasodamma. The family certificate given by
Tahsilder of Obulvaripalle is totally false and that certificate is not
applicable for land disputes or court case. How does that certificate of
Tahsilder of Obulvaripalle by stating that Akepati Venkata Subba Reddy
as the son-in-law of Yasodamma when Yasodamma had no daughter at
all and she died issueless?
5. My client submits that Kommuru Yasodamma did not execute
the alleged will dated 19-04-2014 in favour of Akepati Venkata Subba
Reddy and further submits that Akepati Venkata Subba Reddy and his
supporters manufactured the alleged will dated 19-04-2014 by forging
the signature of Kommuru Yasodamma for the purposes of knocking
away of the property of Kommuru Yasodamma.
6. You are trying to construct a house in the schedule property
unlaw fully in order to grab the notice schedule property of my client
without any right or authority over the notice schedule property. You
should not make any construction in the schedule property.
7. Therefore please take this legal notice under Section 10 of
A.P Buildings Control Act of 1960 R/w Section 106 of T.P Act and that my
client hereby terminated the oral lease of you over the schedule property
by virtue of this second legal notice and that my client is demanding you
to vacate the schedule property by end of this June month 2018 and
deliver vacant possession of the schedule property to my client.
Otherwise my client is forced to take appropriate Civil and Criminal action
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against you in the court of law for the Said reliefs by holding you liable for
casts and consequences.
Schedule:
The property situated in Obulvaripalle village fields,
Obulvaripalle Mandal, Pullampeta Sub-District, Kadapa District.
S.No: 2623, plot No: 4, Extent Ac.0.03 cents.

Boundaries:-
East : Land of Kommuru Narasa Reddy
West : Rastha
North : Vacant site
South : Bandla Bata

Advocate
(K. Venkata Reddy)