1

IN THE HIGH COURT OF KARNATAKA, AT BENGALURU

CRIMINAL PETITION NO:_______________/2019(482)

BETWEEN:

Sri. Mirle Varadaraju and others …PETITIONERS

AND:

State of Karnataka and another …RESPONDENTS

SYNOPSIS

DATE EVENT

12/12/2018 The respondent no. 2 given a written information dated

12/12/2018, and on the information received by the respondent
no. 1 registered a FIR in Crime No.365/2018 against the
petitioner who are accused no.1 and 2 and other two accused for
the offences punishable under section 465, 468, 471,420, 506 r/w
Section 34 of IPC., pending on the file of the learned IX
Additional Chief Metropolitan Magistrate At Bengaluru.

15/12/2018 The respondent No.1, subsequent to registration of the First

Information Report, has requested the learned IX Additional
Chief metropolitan Magistrate, to transfer the above case to the
learned LXX Additional City Civil & Sessions Judge and Special
Judge, Bengaluru, as the Respondent No.1 has invoked Section
3(1)(f)(g) of the Schedule Caste & Schedule Tribe (Prevention of
Atrocities) Act, thereby the matter is now stands transferred to
the said court.

BRIEF FACTS OF THE CASE

On the basis of the written information dated 12/12/2018, lodged by the second
respondent herein, a case in Crime No.365/2018 is registered by the first
respondent police against the petitioners and others purportedly for the offences
punishable U/Ss 465, 468, 471,420, 506 r/w Section 34 of IPC.

That one Sri G Munivenkatappa, the father of the second respondent, was
landlord of the agricultural property bearing Sy.Nos 40/2, and 40/3 of
Nagadevanahalli Village, Bangalore South Taluk and the said property as
 2

acquired for the purpose of formation of road and that on 04/04/2000, the first
petitioner has written a letter to the Secretary, BDA Bangalore stating in it that
the father of the second respondent was residing at No.544, 5th Main Road,
Kengeri Satellite Town, Bangalore- 560 060. However, the father of the second
respondent was residing at Voddarapalya, Kengeri Satellite town, Bangalore
South Taluk, Bangalore.

The said site was thereafter sold to certain K.R. Nanda. Another site bearing
No.220 allotted by BDA in the name of Sri G. Munivenkatappa represented by
Mirale varadaraju as his power of attorney has also been sold in favour of his
brother in law one N. R. Nagaraju. It is further alleged another site bearing
No.197/c situated at 4th Sector, HSR Layout, which is also property allotted by
BDA in favour of father of second respondent, has been sold on the basis of
power of attorney by the petitioner in favour of certain Aparna Vedantham. Like
wise the two other properties, which are residential, sites allotted in favour of
father of the second respondent have been sold in favour of third parties.

On 22/08/2002, the second respondent has lodged information with Kengeri

Police station regarding loss of possession certificate in respect of Site No.38 and
further that the petitioner belongs to Vokkaliga community and second
respondent belongs to scheduled castes. It is further alleged that site No.38 was
sold to one Sridhar V, which the petitioner through G. Munivenkatappa claimed
to be the property of G. Munivenkatappa, and sought for cancellation of the
khatha registered in the name of Sri V. Sridhar and B.V. Vijaya Kumar. On
10.10.2003, after a detailed enquiry, the Court turned down the said request. It is
further alleged that based on the representation of one Venkatesh S/o Siddappa
and Puttamma C/o late Guruappa, the BDA has allotted five sites in first block of
Sir M. Viveswaraiah Layout. However, both of them belong to different families
but in the notification, they are referred to as brother and sister.

On 21/12/2003, the second respondent has given a complaint to the Chairman,

and Commissioner of BDA comprising of 18 ages. Thereafter, on the basis of the
said order, the Inspector, Spl. Squad, BDA Bangalore has given a report about
the acquisition in respect of Sy.Nos 40/2 and 40/3. It is also further alleged that
there was an enquiry and the legal advisor, BDA, gave the report. However,
even after three years, nothing has transpired. Of course, on enquiry with Mirale
Varadaraju, the first petitioner herein, it as said that both Munivenkatappa and
 3

his wife Narayanamma had given a GPA, agreement to sell and a letter stating
that full and final settlement in respect of the properties have been made.

It is claimed by the second respondent in the above said information that the first
petitioner herein has cheated the children of said Munivenkatappa and
Narayanamma and the petitioners are also prevented from taking recourse under
law. As such on 06/02/2018, the Commissioner of Police, Bangalore City and
Addl. Commissioner of Police (Crime) in their TV interview wherein the general
public were called upon to lodge information if any with the city crime branch.
Accordingly, on 10/12/2018, the second respondent has approached CCB,
Bangalore with written information. On the basis of the advise of one
Shanmugappa, the present written information is lodged with jurisdictional
police i.e., the first respondent – police.

The first respondent police, upon registering the FIR has proceeded to take up the
matter for investigation. However, the respondent No.1, subsequent to
registration of the First Information Report, has requested the learned IX
Additional Chief metropolitan Magistrate, to transfer the above case to the
learned LXX Additional City Civil & Sessions Judge and Special Judge,
Bengaluru, as the Respondent No.1 has invoked Section 3(1)(f)(g) of the
Schedule Caste & Schedule Tribe (Prevention of Atrocities) Act, thereby the
matter is now stands transferred to the said court.

Being aggrieved by the registration of the above crime, the petitioners herein
have preferred the above criminal petition.

PLAC: BENGALURU ADVOCATE FOR PETITIONERS

DATE: 30/01/2019
 4

IN THE HIGH COURT OF KARNATAKA, AT BENGALURU

(MEMORANDUM OF CRIMINAL PETITION UNDER SECTION 482 OF
THE CODE OF CRIMINAL PROCEDURE)

CRIMINAL PETITION NO:_______________/2019(482)

IN THE COURT OF IX ADDITIONAL CHIEF METROPOLITAN

MAGISTRATE AT BENGALURU

CRIME NO: 365/2018

IN THE COURT OF THE LXX ADDITIONAL CITY CIVIL AND

SESSIONS JUDGE AND SPECIAL JUDGE, AT BENGALURU (CCH-71)

CRIME NO: 365/2018

CIS CR NO: 6/2019

IN THE HIGH COURT OF KARNATAKA, AT BENGALURU

CRIMINAL PETITION NO:_______________/2019(482)

BETWEEN: RANK OF PARTIES

TRAIL COURT/HIGH COURT

1. Sri. Mirle Varadaraju

S/o. late Bore Gowda
Aged about 57 years,
R/at: No.544, 5th Main Road,
Kengeri Satellite Town,
Bengaluru 560 060. …ACCUSED NO.1/PETITIONER NO.1

2. Smt. Girija Varadaraju

W/o. of Mirle Varadaraju
Aged about 52 years,
R/at: No.544, 5th Main Road,
Kengeri Satellite Town,
Bengaluru 560 060. …ACCUSED NO.2/PETITIONER NO.2

AND:

1. State of Karnataka
Through Station House Officer,
Janabharathi Police Station,
Bengaluru-560 056.
Rep by its: State Public Prosecutor
High Court of Karnataka
Bengaluru-560 001. …PROSECUTION/RESPONDENT NO.1

2. Sri M. Satyanarayana
S/o. Late G Munivenkatappa,
Aged about 42 years,
R/at: No. 6, Vaddarapalya,
Kengeri Hobli, Bengaluru-560 060. …INFORMANT/RESPONDENT No.2
 5

MEMORANDUM OF CRIMINAL PETITION UNDER SECTION 482 OF

THE CODE OF CRIMINAL PROCEDURE

The petitioners herein humbly submit as under:

1. The address of the petitioners for the purpose of the service of this
court notices, summons etc, is as stated in the cause title and aslo that
of is counsel M/s. Haranahalli Law Partners LLP, Sri. S. S. Srinivasa
Rao, Sri. Yeshu Mishra, Sri. Anantha and Sri. Anoop Haranahalli
advocates office at: No. 160, Level 2 and 3, R. T. Nagar Main Road,
MLA Layout, Bengaluru-560 032.

2. The address of the respondents for similar propose is as mentioned in

the cause title and in addition an advance copy of the petition is being
served on the respondent no.1 herein through the Learned State Public
Prosecutor, Hon’ble High Court of Karnataka.

3. That, the petitioners herein are seeking indulgence of this Hon’ble

Court in quashing the FIR in Crime No.365/2018 dated 12/12/2018
registered by the Janabharathi police and the written information dated
12/12/2018, lodged by the respondent no. 2 herein against the petitioners
who are accused no. 1 and 2 for the offences punishable under
section 465, 468, 471, 420 and 506 read with section 34 of
Indian Penal Code, pending on the file of the learned IX
Additional Chief Metropolitan Magistrate at Bengaluru transfer to the
learned LXX Additional City Civil & Sessions Judge and Special Judge,
Bengaluru. The petitioners herein are further seeking kind indulgence
of this Hon’ble Court in quashing the entire proceedings in Crime
No.365/2018(CIS CR NO.6/2019) against the petitioners who are
accused no. 1 and 2 for the offences punishable under section 465,
467, 468, 471, 420 and 506 read with section 34 of Indian Penal
Code and section 3(1)(f)(g) of the Schedule Caste & Schedule Tribe
(Prevention of Atrocities) Act, pending on the file of the learned
LXX Additional City Civil & Sessions Judge and Special Judge,
Bengaluru City . The certified copies of the FIR in Crime
No.365/2018 dated 12/12/2018 and the written information dated
12/12/2018 and entire proceedings in Crime No.365/2018(CIS CR
 6

NO.6/2019) is enclosed and marked as ANNEXURE-“A” and “B”

and “C”.
FACTS OF THE CASE

4. On the basis of the written information dated 12/12/2018, lodged by the

second respondent herein, a case in Crime No.365/2018 is registered by the
first respondent police against the petitioners and others purportedly for the
offences punishable U/Ss 465, 468, 471,420, 506 r/w Section 34 of IPC.
The first petitioner is arrayed as first accused in the above crime and second
petitioner is arrayed as Accused No.2.

5. It is alleged in the written information dated 12/12/2018 that one Sri G

Munivenkatappa, the father of the second respondent, was landlord of the
agricultural property bearing Sy.Nos 40/2, and 40/3 of Nagadevanahalli
Village, Bangalore South Taluk and the said property as acquired for the
purpose of formation of road and that on 04/04/2000, the first petitioner has
written a letter to the Secretary, BDA Bangalore stating in it that the father
of the second respondent was residing at No.544, 5th Main Road, Kengeri
Satellite Town, Bangalore- 560 060. However, the father of the second
respondent was residing at Voddarapalya, Kengeri Satellite town,
Bangalore South Taluk, Bangalore. In the mean time, the BDA decided to
allot a alternative site upon acquisition of the land in Sy.Nos.40/2 and 40/3
and accordingly, a notification was issued allotting a site No.213, situated at
3rd stage, IInd Block, Banashankari measuring 50’ x 80’ in the name of G.
Munivenkatappa, father of the second respondent represented by his power
of attorney – Mirale Varadaraju, the first petitioner herein. The copies of the
sale agreement, concern letter and GPA are enclosed and marked as
ANNEXURE-“E” to “E2”.

6. It is further alleged that the said site was thereafter sold to certain K.R.
Nanda. Another site bearing No.220 allotted by BDA in the name of Sri G.
Munivenkatappa represented by Mirale varadaraju as his power of attorney
has also been sold in favour of his brother in law one N. R. Nagaraju. It is
further alleged another site bearing No.197/c situated at 4th Sector, HSR
Layout, which is also property allotted by BDA in favour of father of
second respondent, has been sold on the basis of power of attorney by the
petitioner in favour of certain Aparna Vedantham. Like wise the two other
 7

properties, which are residential, sites allotted in favour of father of the

second respondent have been sold in favour of third parties. It is further
alleged that on 22/08/2002, the second respondent has lodged information
with Kengeri Police station regarding loss of possession certificate in
respect of Site No.38 and further that the petitioner belongs to Vokkaliga
community and second respondent belongs to scheduled castes. It is further
alleged that site No.38 was sold to one Sridhar V, which the petitioner
through G. Munivenkatappa claimed to be the property of G.
Munivenkatappa, and sought for cancellation of the khatha registered in the
name of Sri V. Sridhar and B.V. Vijaya Kumar. On 10.10.2003, after a
detailed enquiry, the Court turned down the said request. It is further
alleged that based on the representation of one Venkatesh S/o Siddappa and
Puttamma C/o late Guruappa, the BDA has allotted five sites in first block
of Sir M. Viveswaraiah Layout. However, both of them belong to different
families but in the notification, they are referred to as brother and sister.

7. It is further alleged on 21/12/2003, the second respondent has given a

complaint to the Chairman, and Commissioner of BDA comprising of 18
ages. Thereafter, on the basis of the said order, the Inspector, Spl. Squad,
BDA Bangalore has given a report about the acquisition in respect of
Sy.Nos 40/2 and 40/3. It is also further alleged that there was an enquiry
and the legal advisor, BDA, gave the report. However, even after three
years, nothing has transpired. Of course, on enquiry with Mirale
Varadaraju, the first petitioner herein, it as said that both Munivenkatappa
and his wife Narayanamma had given a GPA, agreement to sell and a letter
stating that full and final settlement in respect of the properties have been
made. The copies of the full and final settlement, letter dated 27.07.2001
and sale deeds are enclosed and marked as ANNEXURE-“F” to “F7”.
Thus, it is claimed by the second respondent in the above said information
that the first petitioner herein has cheated the children of said
Munivenkatappa and Narayanamma and the petitioners are also prevented
from taking recourse under law. As such on 06/02/2018, the Commissioner
of Police, Bangalore City and Addl. Commissioner of Police (Crime) in
their TV interview wherein the general public were called upon to lodge
information if any with the city crime branch. Accordingly, on 10/12/2018,
the second respondent has approached CCB, Bangalore with written
information. On the basis of the advise of one Shanmugappa, the present
 8

written information is lodged with jurisdictional police i.e., the first

respondent – police.

8. It is respectfully submitted that the first respondent police, upon registering

the FIR has proceeded to take up the matter for investigation. However, the
respondent No.1, subsequent to registration of the First Information Report,
has requested the learned IX Additional Chief metropolitan Magistrate, to
transfer the above case to the learned LXX Additional City Civil &
Sessions Judge and Special Judge, Bengaluru, as the Respondent No.1 has
invoked Section 3(1)(f)(g) of the Schedule Caste & Schedule Tribe
(Prevention of Atrocities) Act, thereby the matter is now stands transferred
to the said court. The request letter dated 15.12.2018 is enclosed and
marked as ANNEXURE-“D”.

9. Being aggrieved by the registration of the above crime, the petitioners

herein have preferred the above criminal petition invoking jurisdiction of
this Hon’ble Court under sections 482 of Criminal Procedure Code, the
petitioner submits that he has not filed any other criminal petition for the
similar relief or any other legal proceedings either before this Hon'ble Court
or any other court are pending on the following among other grounds:-

GROUNDS

10. It is respectfully submitted that the above First Information Report does not
even prima face make out a cognizable offence even if the entire contents of
First Information Report are taken as gospel truth.

11. It is respectfully submitted that the very fact that the entire transaction
alleged in the said written information dates back to years 1998-2003,
neither G Munivenkatappa, during his lifetime, nor anyone under him,
including the second respondent herein have ever initiated any proceedings
calling in question any of the said transactions taken place in the name of
their father on the basis of power of attorney executed in favour of the
petitioner before any forum. The very fact that the second respondent has
chosen to lodge written information after lapse of nearly 20 years from the
date of transactions, would indicate that the said contents of the written
information are fictitious and frivolous and with malafide intention, the
same is initiated.
 9

12. It is respectfully submitted that the second respondent has not even offered
any explanation whatsoever in the First Information Report as to the
inordinate delay of almost 20 years in lodging the said FIR. Even if the
allegations in the First Information Report were to be accepted as the
uncontroverted evidence in the matter, the same do not bring home any
offences punishable under Sections 420, 471, 468, 465, 467,506 and 34 of
Indian Penal Code & Section 3(1)(f)(g) of the Schedule Caste & Schedule
Tribe (Prevention of Atrocities) Act, as the said documents executed in
relation to the transactions which have been taken place 20 years, have
never been challenged even though all the documents were available to the
second respondent for his reference and necessary action as all the
documents were registered documents.

13. It is respectfully submitted that to constitute the offence of 420 IPC, it

should be the case of the second respondent that upon inducement or false
or misrepresentation of the petitioner, the second respondent or anyone in
whom the second respondent interested in would have parted with any
valuable property or valuable security thereby suffered any loss. In the
instant case, there is no such allegation of any inducement or
misrepresentation to anyone whomsoever by the petitioners, thus, there is
no offence U/s 420 can be made out from the contents of the First
Information Report.

14. It is further submitted that the second respondent has also not specifically
alleged or pointed out forgery of a particular document. In the absence of a
specific allegation of forgery in respect of a document, the registration of
First Information Report on vague and gross allegation is unjustified.

15. It is respectfully submitted that there was no occasion or reason for the
second respondent or any one not to seek recourse under law to call in
question any of the transactions before any of the Courts for 20 years
despite of having knowledge of all transactions which is evident from the
contents of the first information report above.

16. It is unambiguously clear from the first information report that itself is
being guided by alleged media, interview of the Commissioner of Police
and Addl. Commissioner of Police on 06/12/2018 and the second
 10

respondent has chosen to lodge this false information and make wrongful
gain for himself using the opportunity.

17. It is respectfully submitted that even after second respondent were to claim
any right or interest in the properties which are transacted allegedly by the
first petitioner, the same is civil dispute between the petitioners and the
second respondent and that cannot be given colour of criminal case as is
done in the instant case.

18. It is further submitted that the allegations in First Information Report are
very vague and not specific even Section 3(1)(f)(g) of the Schedule Caste &
Schedule Tribe (Prevention of Atrocities) Act, does not get attracted.

19. It is respectfully submitted that the registration of the First Information

Report and the investigation based on the said first information report, is
nothing short of sheer abuse of process of law and in fact the same has
allowed the police to usurp the jurisdiction of the Civil Court in deciding
the rights of the parties in respect of the properties in the guise of their
investigation into civil dispute.

20. It is respectfully submitted that in further continuation of the investigation

of the above matter, would case serious miscarriage of justice and allow the
police to abuse their power to exert pressure upon the petitioners whereby
the petitioners would even lose fair opportunity or protect their interest in
respect of their property. The interference by this Hon’ble Court is very
much warranted to prevent any further process of law by the respondents.
Thus this petition.

21. The petitioners seek kind leave of this Hon’ble Court to raise additional
grounds, if any, in the course of hearing of the above matter.

PRAYER

Wherefore, in view of the aforementioned facts Circumstances and

grounds cited, the petitioner in the present criminal petition prays that, this
Hon’ble Court be pleased to:

a) Quash the FIR in Crime No.365/2018 dated

12/12/2018 registered by the Janabharathi police and
 11

the written information dated 12/12/2018, lodged by the

respondent no. 2 herein against the petitioners who are
accused no. 1 and 2 for the offences punishable under
section 465, 468, 471, 420 and 506 read with
section 34 of Indian Penal Code, pending on the
file of the learned LXX Additional City Civil &
Sessions Judge and Special Judge, Bengaluru
City., vide ANNEXURE-“A” and “B”.

b) Quash the entire proceedings in Crime

No.365/2018(CIS CR NO.6/2019) against the
petitioners who are accused no. 1 and 2 for the offences
punishable under Sections 465, 467, 468, 471, 420
and 506 read with Section 34 of Indian Penal Code
of Indian Penal Code and Section 3(1)(f)(g) of the
Schedule Caste & Schedule Tribe (Prevention of Atrocities)
Act, pending on the file of the learned LXX
Additional City Civil & Sessions Judge and
Special Judge, Bengaluru City., vide ANNEXURE-
“C”.

c) Grant such other order/s as this Hon’ble Court

deems fit to grant in the facts and circumstances
of the case to meet the ends of justice

PLAC: BENGALURU ADVOCATE FOR P ETITIONERS

DATE: 30/01/2019
 12

IN THE HIGH COURT OF KARNATAKA, AT BENGALURU

I.A. NO:_______/2019
IN
CRIMINAL PETITION NO:_______________/2019(482)

BETWEEN: RANK OF PARTIES

TRAIL COURT/HIGH COURT

1. Sri. Mirle Varadaraju

S/o. late Bore Gowda
Aged about 57 years,
R/at: No.544, 5th Main Road,
Kengeri Satellite Town,
Bengaluru 560 060. …ACCUSED NO.1/PETITIONER NO.1

2. Smt. Girija Varadaraju

W/o. of Mirle Varadaraju
Aged about 52 years,
R/at: No.544, 5th Main Road,
Kengeri Satellite Town,
Bengaluru 560 060. …ACCUSED NO.2/PETITIONER NO.2

AND:

1. State of Karnataka
Through Station House Officer,
Janabharathi Police Station,
Bengaluru-560 056.
Rep by its: State Public Prosecutor
High Court of Karnataka
Bengaluru-560 001. …PROSECUTION/RESPONDENT NO.1

2. Sri M. Satyanarayana
S/o. Late G Munivenkatappa,
Aged about 42 years,
R/at: No. 6, Vaddarapalya,
Kengeri Hobli, Bengaluru-560 060. …INFORMANT/RESPONDENT No.2

INTERLOCUTORY APPLICATION UNDER SECTION 482 OF CODE

OF CRIMINAL PROCEDURE

The petitioners above named respectfully submit as follows:

1. The petitioners have preferred the above petition seeking quashing of First
Information Report registered in Crime No.365/2018 by the first respondent
on the basis of the written information lodged by the second respondent, for
the offences punishable under sections 465, 467, 468, 471, 420 and
506 read with Section 34 of Indian Penal Code of IPC and
Section 3(1)(f)(g) of the Schedule Caste & Schedule Tribe (Prevention of
 13

Atrocities) Act, pending on the file of the learned LXX Additional

City Civil & Sessions Judge and Special Judge, Bengaluru City.

2. The contents of the memorandum of Criminal petition may kindly be read

as part and parcel of this application in order to avoid repetition of facts.

3. It is respectfully submitted that the petitioners have a good case on merits. It

is most likely that this Hon’ble Court would accept the above petition and
grant the reliefs sought for in this petition and thus continuation of the
investigation or any proceedings arising out of the above crime would not
only affect the interest of the petitioners but also render the petition
infructuous. Thus this interlocutory application.

4. It is submitted that the petitioners are innocent of the offences. He has not
committed any offence much less as alleged in the FIR. Besides the
petitioner is put to great hardship. Hence, it is just and necessary to stay the
further proceedings.

Wherefore, the petitioners most respectfully pray that this Hon’ble Court
may be pleased to grant ad-interim order of stay of all further investigation/
proceedings in Crime No.365/2018(CIS CR NO.6/2019) against the
petitioners who are accused no. 1 and 2 for the offences punishable under
Sections 465, 467, 468, 471, 420 and 506 read with Section 34 of
Indian Penal Code of Indian Penal Code and Section 3(1)(f)(g) of the
Schedule Caste & Schedule Tribe (Prevention of Atrocities) Act, pending on
the file of the learned LXX Additional City Civil & Sessions Judge
and Special Judge, Bengaluru City., vide ANNEXURE-“C”., as against
the petitioners who are accused no 1 and 2 till disposal of the above
petition, in the interest of justice and equity.

PLAC: BENGALURU ADVOCATE FOR P ETITIONERS

DATE: 30/01/2019
 14

IN THE HIGH COURT OF KARNATAKA, AT BENGALURU

CRIMINAL PETITION NO:_______________/2019(482)

BETWEEN:

Sri. Mirle Varadaraju and others …PETITIONERS

AND:

State of Karnataka and another …RESPONDENTS

INDEX

Sl.No. PARTICULARS Page Nos.

1. Synopsis.

2. Memorandum of Criminal Petition.

3. ANNEXURE-“A”:- Certified copy of the FIR in Crime

no.365/2018 dated 12.12.2018, along with typed copy.

4. ANNEXURE-“B”:- Certified copy of the written

Information dated 12.12.2018, along with typed copy.

5. ANNEXURE-“C”:- Certified copy of the entire

proceedings in Crime No.365/2018(CIS CR
NO.6/2019), along with typed copy.

6. ANNEXURE-“D”:- Certified copy of the request letter

dated 15.12.2018.

7. ANNEXURE-“E”:- Copy of the sale agreement dated

15.12.1999.

8. ANNEXURE-“E1”:- Copy of the concern letter.

9. ANNEXURE-“E2”:- Copy of the GPA.

10. ANNEXURE-“F”:- Copy of the full and final

settlement.

11. ANNEXURE-“F1”:- Copy of the letter dated

27.07.2001.

12. ANNEXURE-“F2”:- Copy of the letter dated

27.07.2001.

13. ANNEXURE-“F3”:- Copy of the sale deed dated

 15

06.08.2001, along with typed copy.

14. ANNEXURE-“F4”:- Copy of the sale deed dated

06.08.2001, along with typed copy.

15. ANNEXURE-“F5”:- Copy of the sale deed dated

17.05.2002, along with typed copy.

16. ANNEXURE-“F6”:- Copy of the sale deed dated

08.05.2002, along with typed copy.

17. ANNEXURE-“F7”:- Copy of the sale deed dated

08.05.2002, along with typed copy.

18. Vakalath.

19. I.A. for stay.

20. Affidavit.

PLAC: BENGALURU ADVOCATE FOR PETITIONERS

DATE: 30/01/2019