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MEMORANDUM OF CONTEMPT APPLICATION

(UmER SECTION 151 OF CIVIL PROCEDURE CODE)

IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH

AT: AMARAVATHI

LA. NO : OF 2023
IN
CCNO. 5og^ OF 2022
Between:

P. Madhusudhan Rao,
S/o Satyanarayana, Age: 50 yrs,
Occ: President Water Users Association,
R/o Thirumalampalem Village,
Dwaraka Tirumala Mandal,
West Godavari District. ...Petitioner

AND

1. M.Seshi Bhushan Rao,

The State of Andhra Pradesh,
Rep. by its PrI. Secretary,
Water Resources Department,
Secretariat, Velagapudi,
Guntur District.
2. Mr. Prasanna Venkatesh,
The District Collector,
Eluru District at Eluru.
3. Mr.Naresh,
The Divisional Accounts Officer (W),
Irrigation Division at Eluru,
Eluru District.
4. Mr. Ravi
The Chief Engineer, Minor Irrigation,
Water Resources Department,
D.NO: 14-7-29, 2nd Floor,
Namboori Gopalarao Street,
Hanumanpet, Vijayawada,
NTR District. ...Respondents

A
 It is therefore prayed that this Honourable Court may be pleased to direct the

_responclent authorities to appear before this Honorable Court personally by issuing

Form-I notice in the interest of Justice and pass such other order or orders as this

Honourable Court deems fit and proper in the circumstances of the case.

Amaravathi

-03-2023 COUNSEL FOR THE PETITIONER

 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI

I.A. NO : OF 2023
IN
CCNO. 50?-^ OF 2022

BETWEEN:

P. Madhusudhan Rao,
S/o Satyanarayana, Age: 50 yrs,
Occ: President Water Users Association,
R/o Thirumalampalem Viiiage,
Dwaraka Tirumala Mandai,
West Godavari District. ...Petitioner

AND

1. M.Seshi Bhushan Rao,

The State of Andhra Pradesh,
Rep. by its PrI. Secretary,
Water Resources Department,
Secretariat, Veiagapudi,
Guntur District.

2. Mr. Prasanna Venkatesh,

The District Coiiector,
Eiuru District at Eiuru.

3. Mr.Naresh,
The Divisionai Accounts Officer (W),
Irrigation Division at Eiuru, Eiuru District.

4. Mr. Ravi
The Chief Engineer, Minor Irrigation,
Water Resources Department,
D.NO: 14-7-29, 2nd Fioor,
Nambobri Gopalarao Street,
Hanumanpet, Vijayawada/ NTR District. ...Respondents
 &

AFFIDAVIT

I, P. Madhusudhan Rao, S/o Satyanarayana, Age: 50 yrs, Occ: President Water

Users Association, R/o Thirumaiampalem Viilage, Dwaraka Tirumaia Mandal, West

Godavari District, do hereby solemnly and sincerely affirm and state as follows:

1. I am the Petitioner herein and as such I am well acquainted with the facts of the

case.

2. I submit that I filed the above contempt case when the contemnors failed to

comply the orders of the Honourable Court in payment of bills amounts under 'Neeru .

Chettu' scheme. I submit that inspite of service of notice the contemnors did not

comply the orders of this Honourable Court and seeking adjournments projecting that

they will comply the orders of this Honourable Court. I submit that the contemnors are

trying to drag the matter. I submit that unless and until the Honourable Court direct the

contemnors to present before this Honourable Court personally by issuing Form-I notice

the contemnors shall not comply the orders of this Honourable Court.

It is therefore prayed that this Honourable Court may be pleased to direct the

respondent authorities to appear before this Honorable Court personally by issuing

Form-I notice in the interest of Justice and pass such other order or orders as this

Honourable Court deems fit and proper in the circumstances of the case.

SS o <&o$oo
Sworn and singed before me on this

day of March 2023 at Amaravathi Advocate/Amaravathi

 VERIFICA- STATEMENT

I, P. Madhusudhan Rao, S/o Satyanarayana, Age:50 yrs, Occ: President

Water Users Association, R/o Thirumalampalem Viilage, Dwaraka Tirumala

Mandal, West Godavari District, being the petitioner/ person acquainted with

the facts do hereby verify and state that the contents of the above paras of

the Affidavit are true and correct to the best of my knowiedge. Hence

verified at Amaravati on this the day of 07.11.2022.

Advocate Deponent
 i
(SHOW CAUSE NOTICE BEFORE ADWII^IQN)
IN THE HIGH COURT OF ANDHRA PRADESH At/
, (Original Jurisdiction)
FRIDAY. THE THIRD DAY OF MARCH.
TWO THOUSAND AND TWENTY THREE r I W”"
:PRESENT:
THE HONOURABLE SRI JUSTICE.R RAGHUNANDAN RAO
CONTEMPT CASE NO: 5084 OF 2022

P Madhusudhan Rao, S/o Satyanarayana, Age 50 yrs. Occ President Water Users
Association, Rio' Thirumalampalem Village, Dwaraka Tirumala Mandal, West
Godavari District
AND
1 M Seshi Bhushan Rao.I.A.S, The State of Andhra Pradesh, Rep. by its PrI.
Secretary, Water Resources Department, Secretariat, Velagapudi. Guntur
2 M?Praaan'na Venkatesh, The District Collector, Eluru District at Eluru.
3. Mr.Naresh; The.Divisidnai Accounts Officer (W), Irrigation Division at Eluru.
Eluru District. ■ ' \ .
4. Mr. Ravi, The Chief Engirieer, Minor Irrigation, Water Resources Department,
D N014-7-29', 2nd Floor, Naniboori Gopalarao Street, Hanumanpet,
Vijayawada, NTR District Respondents

WHEREAS the Petitioner has presented under Sections 10 to 12 of the

Contempt of courts Act 1971, above case through his counsel Sri M P V N V
SASTRl, praying that this Hon’ble High Court may be pleased to punish the
respondents herein for will fully deliberately violating the final orders in
W.P.No.18056 of 2022, dated 19.07.2022; —
WHEREAS the said case coming on for orders as to admission on this day
and whereas the High Court, upon perusing the affidavit filed therein and upon
hearing the arguments of Sri M P V N V SASTRl. Advocate for th^-P^trtioner;
directed issuance of Notice Before Admission to the respondent Nos. 1, 3 & 4. to
show cause as to why in the circumstances stated in the affidavit filed in support
thereof, the said case should not be admitted.^..-'-

M.Seshi Bhushan Kumar,I.A.S, The State of Andhra Pradesh. Rep. by its PrI..
Secretary, Water Resources Department, Secretariat, Velagapudi, Guntur
i 2. M^N^esh, The Divisional Accounts Officer (W), Irrigation Division at Eluru,

Eluru District. „
; 3. Mr. Ravi, The Chief Engineer, Minor Irrigation, Water Resources Department,
D.N014'-7*29,2nd Floor, Namboori Gopalarao Street, Hanumanpet.
Vijayawada, NTR District
be and hereby are directed to show cause, as to why this contempt case should
not be admitted, either appearing in person or through Advocate duly instructed on

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I
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12.04.2023, to which date the case stands postedjpr- hearing, failing wherein the
said case will be heard and determined ex-parte. ‘
Sd/- V.DIWAKAR
DEPUTY REGISTRAR
//TRUE COPY//
V—■
SECTION OFFICER
To.
1. The District Judge, Guntur District, at Guntur. (By RPAD in duplicate along
with a copy qf petition and affidavit to serve on Respondent No. 1 .and to
return to this Court before 12.04.2023)'^ r
2, The District Judge, West Godavari District, at Eluru7(By RPAD in duplicate
along with a copy of petition and affidavit to serve on Respondent No. 3 and ■
to return to this Court before 12.04.2023)
3. The Metropolitan Sessions Judge, Vijayawa'Ja, Krishna District (By RPAD in
duplicate along with a copy of petition and affidavit to serve on Respondent
No.4-and to return to this Court before 12.04.2023)
4. M.Seshi Bhushan Kumar,I.A.S, The State of Andhra Pradesh, Rep. by its PrI.
Secretary, Water Resources Department, Secretariat, Velagapudi, Guntur
District. .
5. Mr.Naresh. The Divisional Accounts Officer (W), Irrigation Division at Eiuru
Eluru District. . ’
6. Mr. Ravi, The Chief Engineer. Minor Irrigation, Water Resources Department,
D.N014-7-29, 2nd Floor, Namboori Gopalarao Street, Hanumanpet,
Vijayawada, NTR District (Addressee nos. 4 to 6 by RPAD- along with a copy
of petition and affidavit)
7. One spare copy
CVSS
 HIGH COURT

RRRJ

DATED:03/03/2023

POST ON 12.04.2023.

NOTICE BEFORE ADMISSION

CC.No.5084 of 2022

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 (^p
WEST GODAVARI DISTRICT

IN THE HIGH COURT OF ANDHRA PRADESH

AT; AMARAVATHI

I.A. NO : OF 2023
IN
CCNO. OF 2022

DIRECTION PETITION

1II0 APR 2023 ♦

of A.P.jWS^^
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Filed by:
So s
Q.
M.P.V.N .V. SASTRY(10207)
ADVOCATE
COUNSEL FOR THE PETITIONER
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