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IN THE COURT OF HON’BLE XII TH ADDITIONAL

DISTRICT JUDGE, PITHAPURAM

CMA 5/2021.

Between :
Bandaru Satyavathi .... Appellant/Plaintiff
and

1. Nalam Narayana Rao


2. Oruganti Veerababu
3. Adabala Gopala Krishna .... Respondents/Defendants

CROSS OBJECTIONS FILED BY THE RESPONDENTS /


DEFENDANTS

1. Appellant :
Bandaru Satyavathi, W/o Late Sri Ramulu, Hindu, Age. 75 years, House-

wife. Presently residing at Block No. 9 GF 7, Rajeev Gruhakalpa, Jaggayya

Cheruvu, Pithapuram, East Godavari District, PTP JCJC Limits.

2. Respondents :

a) Nalam Narayana Rao, S/o Venkata Ramana, Hindu, Age 60 yearrs, Land

lord and Advocate, D.No.1-211, Near Nookalamma Temple, Kumarapuram Vil-

lage, Pithapuram E.G.Dist.,Pithapuram JCJC Limits.

b) Orugnati Veerababu, S/o Naga Suryudu, Hindu Age. 48 years, Beside

Statue of Sai Temple, Jaggayya Cheruvu, Pithapuram E.G.Dt. Pithapuram JCJC

Limits.

c) Adabala Gopala Krishna S/o Not known, Hindu, Age. 54 years, Rice

Business, Near Sai Temple, Jaggayya Cheruvu, Pithapuram, E.G.Dist., Pithapuram

JCJC Limits.

3. Order and decree dt.23.3.2021 in I.A.330 of 2020 in O.S. 196 of 2020 on

the file of Principle Junior Civil Judge Court, Pithapuram and made between

Bandaru Satyavathi .............. Petitioner

and

1. Nalam Narayana Rao

2. Oruganti Veerababu

3. Adabala Gopala Krishna ............ Respondents


4. The following grounds of objections preferred.

a) The learned Lower Court erred in over looking the basic tenant of Law that

the Order of statusco pre suposes a finding as to the right full possession of the

plaint schedule property which lacking in the order of the lower Court.

b) As in found that the Respondents/defendants have filed a sketch along

with their counter and written statement which is not at all traversed or con-

tested by the petitioner/plaintiff as false, The learned Lower court should have

dismissed the petition inlimini on the ground of non traversal itself.

c) The learned Lower court having observed that “To a sertain whether the Ex

P1 issued by Thasildar infavour of the Petitioner in respect of the petition sched-

ule property or some other property not to be decided in interiocutory application,

which requiresful length of trial orders” The learned Lower Court should have

dismissed the petition in the length of the fact that the petitioner failed to plead

and prove a primafacy case in is favour.

d) Having found that the dispute with regard to issurance of patta and the

dispute with request to whether Ex 1 Patta issued in respect of the petition sched-

ule property or some other property or tribul issue which could be decided after

full length trial only the learned Lower Court should have dismiss the petition in

TOTO on the ground of non Existing balance of conveanence infavour of Peti-

tioner/Plaintiff.

For these and for such other grounds as may be urged at the time of the

hearing of this appeal. The Respondents/ defendants do pray the Hon’ble Court

to allow the cross objections and to dismiss the petition with costs throughtout.

Be pleased to Consider

Advocate for Respondents/Defendants

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