N THE COURT OF THE PRINCIPAL JUNIOR CIVIL JUDGE AT

WARNAGAL

O.S. No. 11 of 2018

Between:

Thatikayala Nagendra

..Plaintiff

And

1. Emmadi Chukkaiah

2. Emmadi Sampath

..Defendants

WRITTEN STATEMENT FILED OF

DEFENDANTS U/O VIII RULE-1 OF C.P.C.

1. It is submitted that, this suit is not maintainable either in law or on

facts, the same is liable to be dismissed with costs. All the material

allegations made in the plaint are false, fictitious and self serving,

besides being untenable and impermissible as per law. This

defendant deny the pleadings and the plaintiff is hereby called upon

strict and legal proof thereof with authenticated documentary

evidence if any.

2. This suit is not bonafide suit at all, there is no cause of action to file

this suit by the plaintiff, but suppressed all material facts, the

plaintiff after thought filed this suit having ulterior motive to get the

wrongful gain by wrongful means.

3. It is submitted that this defendant does not admit any of the

allegations made in the plaint, except save those that are

specifically and expressly admitted herein and put the plaintiff to

strict proof of the same.

4. The para no. I & II are the descriptive part of the plaintiff and

defendant, which needs no reply from this defendants.

5. In reply to the Para no. 1 this defendants submits that it if false in

incorrect to say that the Plaintiff most humbly submits as here

under.

6. In reply to the para No. 2 of the plaint, these defendants denies that

the Plaintiff is the absolute owner and possessor of the unfinished

house with open place bearing H.No. 11-1-315, to an extent of 120

Sq.Yds of Plinth area of 288 Sq. Fts the plaintiff has got the siad

property through the registered gift settlement deed bearing

Doc.No. 7247/2018 Dt. 26-11-2018 executed by his mother Takikayala Mani.

Originally the house property bearing No. 11-1-315 belongs to Tatikayala Dasu who is
the father of donor of plaintiff. i.e. Grand father of plaintiff and the said Tatikayala Dasu
has got only one daughter i.e. the mother of the plaintiff. The said Tatikayala dasu who
is having the open land applied for construction of house and under Indiramma Urban
Scheme the Telangana Housing State Corporation has sanctioned the amounts for
construction of house property vide Beneficiary I.D.no. 21269810610035 are nothing but
tissues of lies and falsehood, hence denied in toto.

7. In reply to the para No. 3 of the plaint, it is false and incorrect to say that the said
Tatikayala Dasu has constructed two rooms under Indiramma Urban Housing Scheme.
The wife of Tatikayala Dasu by name Mariya is submitting herewith. The mother of the
plaintiff has also obtained family member certificate from Tahsildar, Warangal Dt. 03-
11-2018 that the mother of the plaintiff is the only legal heir of Tatikayala Dasu. It is
submitted that still the municipal records the name of Tatikayala Dasu is entered. The
Plaintiff humbly submits that due to his employment the plaintiff and his mother is living
at Hyderabad in rented house. The plaintiff along his mother used to visit the property
regularaly are denied by these defendants, the plaintiff suppressed all the facts to create
sympathy before the Hon’ble court and get favorable orders, as the pleadings does not
have any genuine facts.
8. In reply to the para No. 4 of the plaint. It is false and incorrect to say that the house
with open place bearing H.no. 11-1-315 to an extent of 120 Sq.Yds situated at
Chennareddy colony, Labour Colony, Warangal is nothing but utterly false and concocted
for the purpose of filing of the suit.

9. In reply to the para No.5 of the plaint, it is false and incorrect to say that the plaintiff
along with his grand parents and mother used to reside at Hyderabad and the plaintiff
always used to visit the suit schedule property regularly and due to lack of funds, the
plaintiff could not complete tehhh plastering of the suit schedule property, is
absurdities, which resembles to fictitious and fabricated, hence denied in toto.

10. In reply to the para No. 6 of the plaint, it is false and incorrect to say that submitting
the relevant documents showing the prima facie title and possession over the suit
schedule property. As the matter of fact the said documents are created and fabricated
and self styled in order to grab the suit schedule property.