IN THE COURT OF THE HON’BLE CHIEF JUDGE

AT: HYDERABAD

O.S.NO. 2023

BETWEEN:
1. Turlapati Venkateshwar Rao
S/o. Late T.Hanumantha Rao,
Aged about 49 years, Occ: Business.

2. Turlapati Rajya Lakshmi

W/o. Late T.Hanumantha Rao,
Aged about 76 years, Occ: House Wife,

3. Chundi Neeraja
W/o. Chundi Chandra Sekhar
Aged about 52 years, Occ: Private Employee.

Plaintiff 1,2 and 3 are R/o Plot No 50 H.NO 42-300/1 Maruthi Nagar,
Malkajgiri, Hyderabad-500062.
….PLAINTIFFS
AND
1. The Tahsildar

2. ALL CONCERNED ... DEFENDANTS

SUIT FILED FOR DECLARATION TO DECLARE PLAINTFFS AS LEGAL HEIR

OF LATE T.HANUMANTHU RAO S/O T.VENKATESHWARA RAO

PLAINT UNDER ORDER VII RULE 1 R/W SEC 26 OF CPC

I. DESCRIPTION OF THE PLAINTIFFS:

The description of the plaintiffs is the same as stated in the above cause title.
The address for service of all summons, notices and process on the above
named plaintiffs is that of their M/s. MURALI MARABOINA Advocate,
off: H.NO. 37-72/42B, J.J Nagar Colony, Sainikpuri, Secunderabad-500094.
II. DESCRIPTION OF THE DEFENDANTS:

The description of the defendants is the same as stated in the above cause title
above. The address for service of all notices, summons and process on the
above named defendants is the same as stated in the above cause title.

THE BRIEF FACTS OF THE CASE AS FOLLOWS:-

The plaintiffs humbly submit as under:-

1. It is submitted that the plaintiff No.1 is Son, Plaintiffs No.2 is wife &
Plaintiff is the daughters of Late T.Hanumantha Rao S/o T.Venkatehwara
Rao.

2. The Plaintiffs submits that the said Late T.Hanumantha Rao died on 24-
08-2005 leaving behind the plaintiffs as his legal heirs. The plaintiffs further
submit that they are the only surviving legal heirs of late T.Hanumantha Rao,
who died intestate.

3. The Plaintiff submits that the Late T.Hanumantha Rao during his life time
purchased immovable properties Plot No 534 in Sy.No.120, 102/1(403/1),
Admeasuring 706 Sq.Yds or …… Sq.Mts Situated at ………………..,
purchased from ……………….., through registered Sale Deed No. ………..
Dated ………..

4. That the plaintiffs submits that after death of late Late T.Hanumantha Rao,
they approached the Concerned Revenue Authorities in first week of June 2023
for legal heir certificate, but the 1 st respondent refused to give the same on the
ground that he has no power or authority under law to issue such certificate and
advised the plaintiffs to approach competent civil court to obtain a decree and
judgment for declaration of their legal status as legal heirs of late Late
T.Hanumantha Rao. The plaintiffs therefore prefer the present suit for grant of a
decree declaring the plaintiffs as the legal heirs of late Late T.Hanumantha Rao.

5. It is further submitted that, the plaintiffs are advised to get a legal heir
declaration in the name of plaintiffs so as to enable them self to get the flow of
title in the schedule property for the purpose of equitable mortgage to Banks
and financial institutions in case of dire necessities and further transactions.

6. The Plaintiffs have no other option except to approach this Honorable Court
for the reliefs prayed in the present suit. The Plaintiff has not filed any other
suit or proceedings before any other court or tribunal seeking relief as prayed
in the present suit.

CAUSE OF ACTION:-The cause of action arose On 17-08-2005 when Late

T.Hanumantha Rao died intestate and the same was recorded by municipal
authorities and issued a death certificate dated 24-08-2005 and subsequently
when plaintiff approached the Revenue authority in first week on June 2023
who refused to issue legal heir certificate in the names of the plaintiffs
Therefore the suit is within time and not barred by limitation.

JURISDICTION: This Honble court has territorial as well as pecuniary

jurisdiction to try the suit, as the cause of action accrued within the
jurisdiction and suit schedule property is within the jurisdiction.

COURT FEE:- The suit is filed for declaration of legal heirs/status of

plaintiffs and properties valued total at Rs /- and the 1/2 comes to
Rs. On which a court fee of Rs. /-is paid under section 24(d)
of A.P.C.F.and S.V.ACT. Which is proper and sufficient.
DECLARATION AND LIMITATION:- The plaintiffs declares that they
have not filed any other suit before any other court seeking the same relief
as prayed for in the present suit. The Suit is filed well within the period of
Limitation.

PRAYER:-The plaintiffs therefore prayed that this Hon’ble court may

pleased to pass a judgment and decree in favor of the plaintiffs declaring the
legal/heirs status of plaintiffs as the legal representatives of late
T.Hanumantha Rao and pass such other order or orders as this Hon’ble may
deems fit and proper in the interest of justice.

Date: - -2023
PLACE AT: Hyderabad PLAINTIFFS

COUNSEL FOR PLAINTIFFS

VERIFICATION

We the above named plaintiffs hereby declare that what is stated in the

above plaint is true and correct to the best of our knowledge, belief and

information, available on record and hence verified at Hyderabad, on this

the day of 2023.

PLAINTIFFS
 SCHEDULE “A” PROPERTY

Plot No 534 in Sy.No.120,102/1(403/1) , Admeasuring 706 Sq.Yds or ……..

Sq.Mts Situated at And bounded as follows

NORTH : Plot No 535

SOUTH : Plot No 533

EAST : Open Space

WEST : 2.15 Mts Wide Road

VERIFICATION

We the above named plaintiffs hereby declare that what is stated in the

above plaint is true and correct to the best of our knowledge, belief and

information, available on record and hence verified at Kukatpally, on this

the day of 2023.

PLAINTIFFS
 LIST OF DOCUMENTS

1. Original death certificate of Sri Late T. Hanumantha Rao dated 17-08-

2005.
2. Certified Copy of Sale Deed No. .
3. Certified Encumbrance Certificates of Suit Schedule Properties
4. Market Value of the properties.
5. Copy of Aadhar Cards of Plaintiff 1 to 3.

Dated; - -2023
Place at: Hyderabad PLAINTIFFS

COUNSEL FOR PLAINTIFFS

 IN THE COURT OF THE HON’BLE
CHIEF JUDGE
AT: HYDERABAD

O.S.NO. 2023

BETWEEN:
Turlapati Venkateshwar Rao&2 others

….Plaintiffs
AND
Tahilsdar and All concerned
... Defendents

SUIT FILED FOR DECLARATION OF

PLAINTIFFS AS THE LEGAL HEIR OF
LATE T.HANUMANTHU RAO
PLAINT PRESENTED UNDER ORDER
VII RULE 1 READ WITH SECTION 26
OF CPC

Filed on:

Filed by: Counsel for Plaintiff

M/s. MURALI MARABOINA

K.RAVINDER NAIK, Advocate
H.No 38-6/1, J.J Nagar, Sainikpuri,
Sec-Bad -094.

IN THE COURT OF THE HON’BLE CHIEF JUDGE

 AT: HYDERABAD

O.S.NO. OF 2023
BETWEEN; -

Turlapati Venkateshwar Rao & 2 others Plaintiffs

AND

1. The Tahsildar

2. All concerned Defendants

VERIFIED AFFIDAVIT FILED BY THE PLAINTIFFS

I, Turlapati Venkateshwar Rao W/o late T. Hanumantha Rao, Aged about 49

years, Occ: Business, R/o Plot No 50 H.NO 42-300/1 Maruthi Nagar,
Malkajgiri, Hyderabad-500062do hereby solemnly affirm and sincerely state
on oath as follows:

1. I am the deponent herein and plaintiff No.1 in the above suit, as such I am
well acquainted with the facts of the case and I am also authorized to depose
this affidavit on behalf of plaintiff No.2 to 6.
2. I submit that I along with my Mother and Sister have filed the above suit
for declaration to declare us as legal heirs of deceased Late T. Hanumantha Rao.
3. I submit that the contents of the above plaint are true and correct to the
best of our knowledge, information and legal advice and the documents filed by
us are genuine documents. As such I have verified the same on this day.

Hence this verification affidavit.

Sworn and signed before me,

On this day of 2023 DEPONENT
At Kukatpally
Identified by SRI MURALI MARABONA, Advocate

Advocate/Hyderabad
 IN THE COURT OF THE HON’BLE
CHIEF JUDGE
AT: HYDERABAD

O.S.NO. 2023

BETWEEN:
Turlapati Venkateshwar Rao&2 others

….Plaintiffs
AND
Tahilsdar and All concerned
... Defendents

AFFADAVIT

Filed on:

Filed by: Counsel for Plaintiff

M/s. MURALI MARABOINA

K.RAVINDER NAIK, Advocate
H.No 38-6/1, J.J Nagar, Sainikpuri,
Sec-Bad -094.