By Regd Post with Ack-due
Kadapa
01-11-2017
From
Sri.K.Venkata Redddy B.com.B.L
Advocate
2/476 Nagarajupet, Kadapa city
To
Sri.P.Rajesh Kumar Reddy
Advocate
Door No:-1/380-1 Maruti Nagar
Kadapa city
Sir,
Sub:-Reply noties bor the legal noties dated 30-10-2017 - Rg.
Under the insthructions and on behalf of my client Sri.Kuppireddy Nagi
Redddy S/o late pedda subba Reddy, Prinscipal of Global college of Engineering
and Technology, Sheshaiah gari palle village, Chinna masupalli post, chennuru
mandal, Kadapa District, I here by issue this reply notice to you for the legal noties
dated 30-10-2017 issued by you on behalf of your client Gaddam Jataraju son of
Ramudu residing at Harijanawada, Bayanapalli alias Kondapeta Village and post
Chennuru mandal, Kadapa District with the following facts.
1.My client and his brothers partitioned their joint family properties during
1994 year. My client got the properties mentioned in 1-B Namuna in Bayanapalli
village fields, in Chennuru Mandal Kadapa District. Kuppireddy Subba Reddy is the
eldest brother of my client and that person did not get the property shown in 1-B
Namuna of my client on partition in 1994 year. The copy of 1-B Namuna of my
client is enclosed to this reply notice for your perusal to understand the truth.
2.The schedule property mentioned in the schedule of your legal notice is
part and parcel of the property my client which is clearly shown in the revenue
record 1-B Namuna of my client as item No:8 Khata No:357 survey No:220-1
Extent 0.13 cents. That Kuppireddy subba reddy has no right or authority over
your notice schedule property. My client is the absolute owner of your notice
schidule property. So the said Kuppireddy Subba Reddy had no right, titler or
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authority to sell your notice schedule property to your client on 27-03-1996 and
to make registered sale deed in favour of your client. That Kuppireddy subba
Reddy is nothing to do with your notice schedule property of my client. So your
client cannot get your notice schedule property by virtue of the sale deed dated
27-03-1996 since his vendor has no title or inerest over your notice schebule
propety. My client is in possession and enjoyment of your notice schedule
property as per the revenue records like No:3 Adangal and 1-B Namuna dated
31-10-2017 issued by the revenue department to my client.
3. Your client is not in possession and enjoyment of your notice schedule
property at any point of time. My client with bonafide intention did not use either
political power or rowdy clements or criminal force against your client since my
client is in possession and enjoyment of your notice schedule property. Your
client has no title or possession over your notice schedule property since the
alleged sale deed made by Subba Reddy is not valid and not binding on my licent
as per the principles of law owing to the reason that the vendor of your client is
not having any valid and legal right over your notice schedule property for selling
to your client. Nothing comes out of nothing. The vendor of your client did not
posses your notice schedule property as such your client did not get your notice
schedule property and can’t claim tittle or possession over the shedule property
of my client. Your client is trying to knock awy property of my client by showing
the false and nominal sale deed dated 27-03-1996 for making wrong full gain of
the property my client by causing unlawfull loss and injustice to my client .
4. Therefore please take this reply notice and advise your cllient not to
venture and claim title and possession over your notice schedule property of my
client. Otherwise my client will file civil suit and take criminal steps against your
client in the court of law by holding your client liable for costs and consequeneces
if your client tries to interfere with the right, title and possossion of my client with
your notice schedule property inspite of this reply notice.
Advocate
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Enclosures:-
1.Copy of 1-B Namuna issed in the name of client for your notice schudule
property and other properties on 31-10-2017.
2. Copy of No:-3 Adangal issed in the name of my client on 1-11-2017
showing that my client is in possossion and enjoyment of your notice schedule
property.
Advocate
Capy to your client for information:-
1.Gaddam jayaraju S/o Ramudu
Harijana wada, Bayanapalli Village and post
Chennuru mandal Kadapa city.
