1

Memorandum of Grounds of Civil Revision Petition

(Under Art. 227 of the Constitution of India)

On the file of Hon’ble XII Additional District Judge, Vijayawada at Nuzvid

I.A.No. 109 OF 2022

IN
A.O.P.No.02 OF 2022

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI

C.R.P.No. OF 2022

BETWEEN:

Dr. Raghavarao Polavarapu

Address: 32-4-10a, Uma Maheswara Street,
Prajasakthi Nagar, Venkateswarapuram,
Vijayawada, Andhra Pradesh-520010
...PETITIONER/ RESPONDENT No.29
AND

1. Dr. Jitendra Prasad Katneni S/o. Jaganmohana Rao,

Aged 65 Years, Medical Profession,
R/o 12216,Wind Chillway Fenton, Michigan 48430, USA,
Rep by his GPA holder Gutta Siva Leela Durga Vara Prasad,
S/o Venkatramaiah, aged 50 years, employment,
R/o LIC Colony, Vijayawada - 520008, Krishna District
…RESPONDENT/ PETITIONER
2. Dr.Krishna Prasad Surapaneni, Aged about 65 years,
S/o.Rama Rao,
Occ: Medical Profession,
R/o.Surapaneni- Genomic Solutions, Pl.No.91,
Road No.71, Film Nagar, Hyderabad.

3. Dr.Krishna Kumar Gannamaneni, Aged about 65 years,

S/o.Nageswara Rao, Occ: Medical Profession,
R/o.5205, West Shoreline Terrace, Muncie, IN 47304.

4. Dr. Ravindra Alapati, 1771 Wromneya Dr

Ste C Anaheim, California 92801,
C/o Sri Alapati Rajendra Prasad MLA, Vidya Nagar,
Guntur, AP.

5. Dr. V. V. Subbarao, 5806, Newfield Lane,

Dublin, California 94568
C/o.Padmavathy Superspeciality Hospital,
Kothapeta, Opp.BSNL Guntur, Andhra Pradesh

6. Dr.Sai Ramesh Bikkina, 4359, Longview Drive

Lapeer, Michigan-48446, U.S.A.

7. Dr. Mahesh Bikkina, 703,

Ginger Lane, Franklin Lakes,
Newjersey-07417, USA
 2

8. Dr. Appa Rao Mukkamala

Address: 4545 Warwick Circle
Grand Blanc, Michigan 48439 USA
 3

9. Dr. Raju N Mantena

Address: Burr Oak, Palatain,
Illinois, USA

10. Dr. Kothapalli Srinivasa Rao

Address: 1840, 27th Street, PO Box 1666,
Nederland, Texas 77627, USA

11. Dr. Pratap Aravapalli

Address: 1143 Kings Carriage
Grand Blanc, Michigan 48439 USA

12. Dr. Vani Manyam

Address: 6197 Pine Croft Court
Flint, Michigan 48532

13. Dr.Sumathi Mukkamala

Address: 4545 Warwick Circle
Grand Blanc, Michigan 48439 USA

14. Dr.Hanumaiah Bandla

Address: 6765 Burtonwood Drive
West Bloomfield, Michigan 48322

15. Dr.Ramakrishna Pinnamaneni

Address: 9042 University Drive
Munster, Indiana 46321

16. Dr.Suresh Anne

Address: 5155 Norko Drive
Flint, MI 48507

17. Dr.Prasad BR Neerukonda

Address: 220 Indian Trail Road
Oak Brook IL 60523

18. Dr.Sujatha Neerukonda

Address: 221 Indian Trail Road
Oak Brook IL 60523

19. Mr.C. T. Chowdhary

Address: 36-11-7, Santhi Nagar,
Ist Lane, Mogalrahpuram,
Vijayawada - 520010.

20. Dr.Pallavi Atluri

Address: Vishwaroopa Residency
Acharya Ranga Street
Gayatri Nagar, Vijayawada 520008

21. Dr.Pardhasaradhy Mukkamala

Address: Sri Ramachandra Rao Street,
Sankara Matham Road
Eluru, West Godavari Dist, AP
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22. Dr.Sreedhar Koneru

Address: Vishwaroopa Residency
Acharya Ranga Street
Gayatri Nagar, Vijayawada 520008

23. Sri.Somu Krishna Murthy

Address: Advocate
29-37-64, Eluru Road
Suryaraopet, Vijayawada 520002

24. Sri Murali Krishna Kudharavalli

Address: 59-11-7A Ghantasalavari St
2nd Lane Gayatri Nagar
Vijayawada 520008, AP

25. Sri Arjuna Lemke

Address: 2423 N Kenzie Boulaward,
Chicago, IL, USA

26. Sri Srinivasa Rao Uppalapu

Address: 54-16-1/17A, Loyola College Road,
Central Excise Colony
Near Central Excise Office
Vijayawada-520008, Andhra Pradesh.

27. Dr. Nimmagadda Upendranath, Aged

about 79 Years,
S/O: N.Sambasiva Rao,
Occ: Medical Practitioner,
R/o: Quarters no-3-1-11, NRI Academy
campus,
Gowtham Budha road, Chinakakani,
Guntur, Andhra Pradesh – 522503,

28. Dr. Mani Akkineni, Aged about 74

Years, W/o Sudarsana Rao Akkineni,
Occ: Doctor,
R/o H.No 59-8-2/1, Flat No-105,
Trendset Harmony Apartments,
Gayatri Nagar, Vijayawada.

29. Dr. Surendra Avula

Address: Oak Lawn, 152 Siloridge Road,
 5

North Orland Park IL 60467, USA

30. Dr.Subramanyam Naidu

Address: 2862 Emerald Drive
Johansborough
GA 30236, USA

31. Smt. Syamala Naidu

Address: 2863 Emerald Drive
Johansborough, GA 30236, USA

32. Dr. Y. Basaveswara Rao Yalamanchili

Address: 9171 Falling Waters Dr
E Burr Ridge IL 60527-0716
33. Smt. Roopa Akkineni
Address: 506 Midwest Club Pk Way Oak Brook, IL 60523

34. Ms. Madhavi Nimmagadda

R/o 2423 N Kenzie Avenue,
Chicago, Illinois 60614, USA

35. Dr. Manjula Tella

Address: 15717 Burdette Street
Omaha, NE 68116.
…RESPONDENTS/ RESPONDENTS

A. The address for service of all notices, process and summons of

the above said Petitioner is that of his counsel Mr.N.Ashwani Kumar

(11879) Advocate, Mr.K.Ajay Kumar, Mr.U.Raghava Krishna,

Ms.P.Vandana, Advocates, 4th Floor, Sumana Towers, Door.No.48-17-

9/2 (3F-401), Road No.2, Nagarjuna Nagar Colony, NTR Road,

Vijayawada- 520008. Phone: +91-90522-19194.

B. The above named Petitioner begs to present this Memorandum

of Grounds of Revision against the Order passed in I.A No.109 of 2022

in A.O.P No.02 of 2022 dated 23.05.2022, on the file of the Hon’ble XII

Additional District Judge, Vijayawada at Nuzvid on the following among

the other;

GROUNDS
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1. The order under Revision is bad in law, contrary to the facts on

record and is liable to be set-aside.

2. The impugned order is in teeth of the order passed by the Delhi

High Court in Arb A (Comm) no. 24/2022 and 25/2022 dated 19.05.2022

and this Hon’ble Court dated 21.05.2022 in WP(SR) no 20530/2022.

3. The Hon’ble Court below ought not to have been entertained during

the pendency of the aforesaid appeals before the Delhi High Court.

4. The Learned Court below vide impugned order dated 24.05.2022

has exceeded its jurisdiction and thus the order is liable to be set aside.

5. The order has been obtained by misleading and misrepresentation. It

is a classic case of judicial overreach and opposed to the principles of

natural justice.

6. The Petition before the Learned Court below was totally

misconceived and ought not to have been entertained. The order has

been passed just a day before the hearing of appeals before the Hon’ble

Delhi High Court.

7. That in view of order passed by the Delhi High Court and this

Hon’ble Court, the arbitration proceedings could not have been

interfered with.
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8. That the impugned order is without jurisdiction and a complete

abuse of process of law. The order being patently illegal ought to be set

aside.

9. The Hon’ble Court below ought to have seen that this is a classic

case of forum shopping where some of the respondents have filed an

appeal before the Hon’ble Delhi High Court and some have filed before

the Ld. Court below that too challenging the same order.

10. That the impugned order has the effect of perpetuating the fraud

committed by the contesting respondents by granting them opportunity

to siphon off money and destroy evidence pertaining to the same.

11. That the impugned order is without any reason and does not refer

to any facts and cryptic. The order is ex facie bad in law.

12. The Petitioner craves leave to urge other grounds at the time of

hearing of the Revision.

C. VALUATION: The value of the Revision is more than Rs.1000/-

and hence, fixed Court fee of Rs.100/- is paid herewith.

D. For the reasons stated, it is therefore prayed that this Hon’ble

Court may be pleased to allow the revision while setting aside the Order

passed in I.A No.109 of 2022 in A.O.P No.02 of 2022 dated 23.05.2022,

on the file of the Hon’ble XII Additional District Judge, Vijayawada at

Nuzvid and pass such other order or orders as this Hon’ble Court may

deem fit and proper in the circumstances of the case.

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DATE: 24.05.2022 COUNSEL FOR THE PETITIONER

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KRISHNA:: DISTRICT

IN THE HIGH
COURT OF ANDHRA
PRADESH
AT AMARAVATI

CRP NO. OF 2022

AGAINST

I.A.No. 110 OF 2022

IN
A.O.P.No. 2 OF 2022

(On the file of XII

Additional District Juge,
Vijayawada at Nuzvid)

MEMORANDUM OF GROUNDS

FILED ON:- 24.05.2022

FILED BY:

N.ASHWANI KUMAR (11879)

ADVOCATE
COUNSEL FOR THE PETITIONER
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IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI

I.A. NO. OF 2022

IN
C.R.P.No. OF 2022

BETWEEN:

Dr. Raghavarao Polavarapu

Address: 32-4-10a, Uma Maheswara Street,
Prajasakthi Nagar, Venkateswarapuram,
Vijayawada, Andhra Pradesh-520010
... PETITIONER/
PETITIONER/RESPONDENT No.29
AND

1. Dr. Jitendra Prasad Katneni S/o. Jaganmohana Rao,

Aged 65 Years, Medical Profession,
R/o 12216,Wind Chillway Fenton, Michigan 48430, USA,
Rep by his GPA holder Gutta Siva Leela Durga Vara Prasad,
S/o Venkatramaiah, aged 50 years, employment,
R/o LIC Colony, Vijayawada - 520008, Krishna District
…RESPONDENT/
RESPONDENT/ PETITIONER
2. Dr.Krishna Prasad Surapaneni, Aged about 65 years,
S/o.Rama Rao,
Occ: Medical Profession,
R/o.Surapaneni- Genomic Solutions, Pl.No.91,
Road No.71, Film Nagar, Hyderabad.

3. Dr.Krishna Kumar Gannamaneni, Aged about 65 years,

S/o.Nageswara Rao, Occ: Medical Profession,
R/o.5205, West Shoreline Terrace, Muncie, IN 47304.

4. Dr. Ravindra Alapati, 1771 Wromneya Dr

Ste C Anaheim, California 92801,
C/o Sri Alapati Rajendra Prasad MLA, Vidya Nagar,
Guntur, AP.

5. Dr. V. V. Subbarao, 5806, Newfield Lane,

Dublin, California 94568
C/o.Padmavathy Superspeciality Hospital,
Kothapeta, Opp.BSNL Guntur, Andhra Pradesh

6. Dr.Sai Ramesh Bikkina, 4359, Longview Drive

Lapeer, Michigan-48446, U.S.A.

7. Dr. Mahesh Bikkina, 703,

Ginger Lane, Franklin Lakes,
Newjersey-07417, USA

8. Dr. Appa Rao Mukkamala

Address: 4545 Warwick Circle
Grand Blanc, Michigan 48439 USA
 11

9. Dr. Raju N Mantena

Address: Burr Oak, Palatain,
Illinois, USA

10. Dr. Kothapalli Srinivasa Rao

Address: 1840, 27th Street, PO Box 1666,
Nederland, Texas 77627, USA

11. Dr. Pratap Aravapalli

Address: 1143 Kings Carriage
Grand Blanc, Michigan 48439 USA

12. Dr. Vani Manyam

Address: 6197 Pine Croft Court
Flint, Michigan 48532

13. Dr.Sumathi Mukkamala

Address: 4545 Warwick Circle
Grand Blanc, Michigan 48439 USA

14. Dr.Hanumaiah Bandla

Address: 6765 Burtonwood Drive
West Bloomfield, Michigan 48322

15. Dr.Ramakrishna Pinnamaneni

Address: 9042 University Drive
Munster, Indiana 46321

16. Dr.Suresh Anne

Address: 5155 Norko Drive
Flint, MI 48507

17. Dr.Prasad BR Neerukonda

Address: 220 Indian Trail Road
Oak Brook IL 60523

18. Dr.Sujatha Neerukonda

Address: 221 Indian Trail Road
Oak Brook IL 60523

19. Mr.C. T. Chowdhary

Address: 36-11-7, Santhi Nagar,
Ist Lane, Mogalrahpuram,
Vijayawada - 520010.

20. Dr.Pallavi Atluri

Address: Vishwaroopa Residency
Acharya Ranga Street
Gayatri Nagar, Vijayawada 520008

21. Dr.Pardhasaradhy Mukkamala

Address: Sri Ramachandra Rao Street,
Sankara Matham Road
Eluru, West Godavari Dist, AP
 12

22. Dr.Sreedhar Koneru

Address: Vishwaroopa Residency
Acharya Ranga Street
Gayatri Nagar, Vijayawada 520008

23. Sri.Somu Krishna Murthy

Address: Advocate
29-37-64, Eluru Road
Suryaraopet, Vijayawada 520002

24. Sri Murali Krishna Kudharavalli

Address: 59-11-7A Ghantasalavari St
2nd Lane Gayatri Nagar
Vijayawada 520008, AP

25. Sri Arjuna Lemke

Address: 2423 N Kenzie Boulaward,
Chicago, IL, USA

26. Sri Srinivasa Rao Uppalapu

Address: 54-16-1/17A, Loyola College Road,
Central Excise Colony
Near Central Excise Office
Vijayawada-520008, Andhra Pradesh.

27. Dr. Nimmagadda Upendranath, Aged

about 79 Years,
S/O: N.Sambasiva Rao,
Occ: Medical Practitioner,
R/o: Quarters no-3-1-11, NRI Academy
campus,
Gowtham Budha road, Chinakakani,
Guntur, Andhra Pradesh – 522503,

28. Dr. Mani Akkineni, Aged about 74

Years, W/o Sudarsana Rao Akkineni,
Occ: Doctor,
R/o H.No 59-8-2/1, Flat No-105,
Trendset Harmony Apartments,
Gayatri Nagar, Vijayawada.

29. Dr. Surendra Avula

Address: Oak Lawn, 152 Siloridge Road,
 13

North Orland Park IL 60467, USA

30. Dr.Subramanyam Naidu

Address: 2862 Emerald Drive
Johansborough
GA 30236, USA

31. Smt. Syamala Naidu

Address: 2863 Emerald Drive
Johansborough, GA 30236, USA

32. Dr. Y. Basaveswara Rao Yalamanchili

Address: 9171 Falling Waters Dr
E Burr Ridge IL 60527-0716
33. Smt. Roopa Akkineni
Address: 506 Midwest Club Pk Way Oak Brook, IL 60523

34. Ms. Madhavi Nimmagadda

R/o 2423 N Kenzie Avenue,
Chicago, Illinois 60614, USA

35. Dr. Manjula Tella

Address: 15717 Burdette Street
Omaha, NE 68116.
…RESPONDENTS/ RESPONDENTS/ RESPONDENTS

AFFIDAVIT

I, Dr. Raghavarao Polavarapu R/o 32-4-10a, Uma Maheswara

Street, Prajasakthi Nagar, Venkateswarapuram, Vijayawada, Andhra

Pradesh-520010, do hereby affirm and solemnly affirm and sincerely

state as under:

1. I am the Petitioner herein and Respondent No.2 in the

A.O.P.No.2 of 2022, as such I am fully conversant with the facts of the

case.

2. The instant Revision is preferred aggrieved by the order passed

in I.A No.109 of 2022 in A.O.P No.02 of 2022 dated 23.05.2022, on the

file of the Hon’ble XII Additional District Judge, Vijayawada at Nuzvid.

 14

3. The Hon’ble Court below grossly erred in granting interim

direction in the aforementioned I.A. On legal advice, I submit that there

is fair chance of the above revision being allowed. I submit that the

Memorandum of Grounds of Revision may be read as part of this

affidavit.

Facts of the Case are as following.

4. The NRI Academy of Sciences is a society registered under the AP

Societies Registration Act, 2001 and is represented through its

administrator. The society is running a medical college as well as a 1000

bedded hospital.

5. I submit that the Hon’ble High Court of Andhra Pradesh vide order

dated 22.02.2022 passed in W.A. No. 234/22 and other connected

matters constituted an Arbitral Tribunal comprising of Ld. Sole Arbitrator

– Hon’ble Justice Devinder Gupta (Retd) in view of Section 23 of the

Andhra Pradesh Societies Registration Act, 2001 to adjudicate upon the

rival claims of the parties as regards the management, membership of

the 1st petitioner Society- NRI Academy of Sciences.

6. I submit that pursuant to the aforesaid order dated 22.02.2022

passed by Division Bench of this Hon’ble Court, the arbitration

proceedings were commenced between the parties and the same was

presided over by the Sole Arbitrator – Hon’ble Justice Devinder Gupta

(Retd.).

7. I submit that the Ld. Arbitrator vide order dated 14.05.2022

appointed ‘Sri.MV Rao’ as administrator to look after and manage all the
 15

affairs of NRIAS including financial matters. The contesting

Respondents were restrained from meddling with the affairs of the

society in any manner including its management or operation of bank

accounts of the society. The relevant portion of the order dated

14.05.2022 passed by the Ld. Arbitrator is extracted herein below:-

“Having duly considered the submissions made before

me and having gone through the record, I am of the considered
view that till the matter is heard it will be necessary to issue
some interim measures of protection in respect of the affairs of
the Society in as much as there are serious allegations that the
affairs of the Society are not being run properly by the
Respondents, who presently are in control of the affairs of the
Society. There is no denial of fact that the parties to the
arbitration proceedings are members of the Society and there is
a dispute amongst the members of the Society in respect of the
matters relating to the affairs of the Society. The Respondents
are not agreeable to maintain status quo till matter is heard.
Accordingly, there is no other option left except to appoint a
person to look after and manage all the affairs of the NRI
Academy of Sciences, Chinakakani, Guntur District including
management and financial matters.
Accordingly, Mr. MandavaVishnuvardhana Rao, IPS
(Retd.) is appointed with immediate effect to take over the
charge as an Administrator of NRI Academy of Sciences,
Chinakakani, Guntur District and look after and manage all the
affairs including financial matters till further orders, whose
particulars, as obtained by me from the High Court are as
under:
Mr. M. V. Rao, IPS (Retd),
House No.1-65/288, Kakatiya Hills,
Road No.6, Guttala Begumpet,
Hyderabad-500003 (Telengana).
Email vishnuips@gmail.com;
Mobile +918333878687
His remunerations will be fixed after consultation with the
parties during the next sitting. In the meanwhile, Mr. M. V. Rao,
IPS (Retd) will be paid an amount of Rs. 5 Lac by the Claimant
to meet all necessary expenses required to be incurred by him.
The Claimants will ensure that Mr. M. V. Rao, IPS (Retd) is duly
delivered all necessary and relevant documents within a period
of two days. Resultantly with passing of this order, the
Respondents are restrained from medalling, in any manner, with
the affairs of the Society including its management or operating
the bank accounts of the Society, which will now be managed,
looked after and operated by Mr. M. V. Rao IPS (Retd), the
Administrator.”

8. I submit that on 16.05.2022, forenoon at 9.45am, the Administrator

took charge over the affairs of NRIAS.

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9. That some of the contesting respondents who were parties to the

dispute in arbitration proceedings had challenged the order dated

14.05.2022 passed by the Ld. Sole Arbitrator in Arb. A. (Comm) No.

24/2022 and 25/2022 before the Hon’ble Delhi High Court. The Hon’ble

Delhi High Court vide order dated 19.05.2022 directed the parties to

maintain status quo and listed the matter for further hearing on

25.05.2022.

10. It is relevant to note that the Administrator filed a Writ Petition

seeking to issue Writ particularly in the nature of the Writ of Mandamus

directing the state police as well as CISF to provide him with the security

in order to ensure smooth functioning of the Society. The aforesaid Writ

Petition bearing No. (W.P. (S.R.) No. 20530/2022) was listed before the

Andhra Pradesh High Court on 21st May, 2022 was pleased to pass the

following order.

“7. According by virtue of the appointment as administrator, the

2nd petitioner has assumed charge on 16.05.2022 of the 1 st
petitioner and the same was informed through e-mail to the
learned sole Arbitrator. Thereafter, he sent authorization letters
dated 16.05.2022 to the bankers with regard to the clearances
for the financial issues of the society and the same are also
filed. Thereafter, the 1st Petitioner conducted a meeting of
Administrator with Hospital/College Administration and non-
teaching Sectional Heads of NRI Academy of Sciences on
16.05.2022. Thereafter, on 19.05.2022 the members
(respondents in arbitration proceedings) have challenged the
order of the learned Sole Arbitrator before the High Court of
Delhi and the Delhi High Court vide order dated 19.05.2022
directed the parties to maintain status quo and listed the matter
for further hearing on 25.05.2022. It shows that pursuant to the
order of status Quo issued by the Hon’ble High Court of Delhi,
the members (respondents in arbitration proceedings) are
obstructing the 2nd Petitioner from discharging his duties as an
Administrator and the status quo order dated 19.05.2022
passed by the Hon’ble High Court of Delhi would mean that the
2nd Petitioner who assumed charge on 16.05.2022 of NRIAS
would continue to discharge functions as an administrator of
the society till further orders.
 17

8. having regard to the facts and circumstances of the case

and upon perusing the entire material available on record, as
the 2nd and 3rd respondents are different agencies, as per their
rules, policy and regulations, they will act on the issues.
Accordingly, liberty is given to the 2 nd Petitioner to submit a
complaint before the 2nd respondent and thereupon the 2nd
respondent is directed to receive and consider the same and
given interim protection to the 2nd petitioner from individuals
obstructing the 2nd Petitioner from discharging functions, so as
to ensure smooth administration of the 1st Petitioner society.
9. further, it is open to the 2nd Petitioner to submit his complaint
to the 3rd respondent’s higher authority i.e., Director General of
Police, CISF, Ministry of Home Affairs. On such submission of
complaint by the 2nd petitioner, the DGP, CISF is directed to
give protection in accordance with law.

11. Despite the challenge to the order dated 14.05.2022 passed by

the Ld. Arbitrator pending before the Delhi High Court, the Ld. Court

below, vide order dated 23.05.2022 entertained the challenge to the

order dated 14.05.2022 and granted stay of order dated 14.05.2022.

Hence the present CRP.

12. Upon legal advise, it is submitted that in view of the Impugned

Order dated 23.05.2022, the Administrator is restrained from

undertaking the enquiries in respect of the financial irregularities and

embezzlement of funds which were undertaken on large scale by the

contesting Respondents, and thus, the need of the hour, is an

immediate investigation and enquiry to be caused by the Police,

otherwise, there exists every threat wherein the contesting Respondents

are likely to destroy and damage the entire evidence (documentary and

digital) in order to escape and evade the prosecuting agencies. Hence,

the above CRP is being presented before the Designated Vacation

Court as this Hon’ble Court is currently under the Summer Vacation and

thus, only urgent and matters of grave concern are taken up for

admission and hearing. There is no other efficacious and alternate

remedy available to the Petitioner herein, who is the founding member

 18

of the NRIAS. Unless or until, this Hon’ble Court suspends the order

passed by the Hon’ble District Judge in I.A.No.110 of 2022 in

Arb.O.P.No.2 of 2022, the Petitioner will be put to irreparable loss, injury

and grave injustice. The NRIAS is running public functions including

medical college and a hospital and the Impugned Order is obstructing

the functioning of the society. Thus, the matter is of urgent nature. If the

matter is not heard immediately, it will affect the functioning of the

medical college and more importantly the hospital, which requires

constant monitoring.

In the Interim, it is therefore prayed that this Hon’ble Court may

be pleased to suspend the order passed in I.A No.109 of 2022 in A.O.P

No.02 of 2022 dated 23.05.2022, on the file of the Hon’ble XII Additional

District Judge, Vijayawada at Nuzvid, pending the disposal of the above

C.R.P and pass such other or further order or orders as the Hon'ble

Court may deem fit and proper in the circumstances of the case.

In the Interim, it is further prayed that this Hon’ble Court may be

pleased to stay all further proceedings in Arb.O.P.No.2/2022 on the file

of the 12th Additional District Judge, Machilipatnam at Nuzvid, pending

disposal of the above CRP and pass such other order or orders as this

Hon’ble Court may deem fit and proper in the circumstances of the case.

Solemnly affirmed and signed in my DEPONENT

presence at Amaravati on this the
24th Day of May, 2022
Before Me : :
Advocate, Amaravati

VERIFICATION
 19

I, Dr. Raghavarao Polavarapu R/o 32-4-10a, Uma Maheswara

Street, Prajasakthi Nagar, Venkateswarapuram, Vijayawada, Andhra
Pradesh-520010, duly attested in the presence of an Advocate state that
the contents of the affidavit filed in support of the above CRP are true
and correct to the best of my knowledge and belief and paragraphs and
are based on legal advice. Hence, verified on this 24 th Day of May, 2022
at Amaravati.

COUNSEL FOR THE PETITIONER DEPONENT