Narra Sri Lakshmi CRP

MEMORANDUM OF CIVIL REVISION PETITION
(UNDER SECTION 227 OF CONSTITUTION OF INDIA)
IN THE COURT OF SENIOR CIVIL JUDGE: AT ADDANKI
Docket Order Dt. 25-03-2019 IN O.S. NO. 76 OF 2012
IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH:

AT : AMARAVATHI
C. R. P. NO. OF 2019
Between:-
Narra Sri Lakshmi

W/o Gopichand, Hindu, Aged about 45 years, Housewife,
R/o Andhra Sai Nilayam, Associate Builders,
Ashok Nagar, Dhanekulavari street, Vijayawada -7 ,
Present R/o D.No. 15-101-1, Times Hospital road, Srinivsa Residency,
Tulasi nagar, Vijayawada, Krishna District, A.P.
..Petitioner/Petitioner
And
1. Katragadda Venkata Anil Kumar

S/o late Krishna Murthy, Hindu, Aged about 32 years,
Panchayati Secretary, R/o Jammulapalem Village,
Tangutur mandal, Prakasam District.
2. Katragadda Venkata Sunil Kumar

R/o. C/o Katragadda Venkata Anil Kumar,
R/o Jammulapalem Village,
3. Bodepudi Maruthi Prasad, S/o Venkateswarlu

Hindu, Aged about 50 years,
R/o Bodempudiaripalem Village,
Addanki mandal, Prakasam District. ( R3 formal party)
.. Respondents/ Respondents
Address for service of all notices, summons etc., on the above named
Petitioner is that of his Counsel Sri PEDDI VIJAY BHASKAR, Advocate,
D.No. 9-28/1, Near Bus stand, Sivalayam backside, Tadikonda Village and
Mandal, Guntur District, A.P., Pin 522 236, Cell: 8008592163
Aggrieved by the Docket Order Dated 25-03-2019 made in O.S No.76

of 2012 pending on the file of Senior Civil Judge, Addanki, Prakasam
District. The revision petitioner begs to present this Memorandum of Civil
Revision Petition, on the following among other
GROUNDS.
1. The order of the lower court is contrary to law, weight of evidence
and probabilities of the case;
2. The Hon'ble Lower Court has failed to appreciate the statutory
provision available to the petitioners during the course of marking of
the document;
3. Refusing to mark the unregistered partitioned list dated 20-05-2003 is
against all canons of justice equity and fair play;
4. In any view of the matter refusing to marking the unregistered
partitioned list dated 20-05-2003 is arbitrary, illegal and against
settled principles of law;
5. The trial court ought to have marked the document.
6. The other grounds would be urged at the time of hearing of this
revision petition.
VALUE OF C.R.P.
The value of this CRP is more than Rs.1000/- and hence a fixed court fee
of Rs.100/- is paid.
Amaravathi, Counsel for the Petitioner.
Date: 28-06-2019
PRAKASAM : DISTRICT
IN THE HIGH COURT OF

JUDICATURE OF ANDHRA
PRADESH AT : AMARAVATHI
C.R.P.NO. OF 2019
MEMORANDUM OF GROUNDS
Filed On: 28-06-2019
filed By:
MR.VIJAY BHASKAR PEDDI (21032)
COUNSEL FOR THE PETITIONER

IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH:
AT : AMARAVATHI
C.R. M.P.No. of 2019

in
C. R. P. NO. OF 2019
Between:-
Smt. Narra Sri Lakshmi

Present R/o D.No. 15-101-1, Times Hospital road, Srinivasa Residency,
Tulasi nagar, Vijayawada, Krishna District, A.P.
..Petitioner/Petitioner
And



AFFIDAVIT FILED BY THE PETITIONER
I, Narra Sri Lakshmi, W/o Gopichand, Hindu, Aged about 45 years,

Housewife, R/o Andhra Sai Nilayam, Associate Builders, Ashok Nagar,
Dhanekulavari street, Vijayawada -7 , Present R/o D.No. 15-101-1, Times
Hospital road, Srinivsa Residency, Tulasi nagar, Vijayawada Krishna
District, A.P. do hereby sincerely and solemnly affirm and state on oath as
follows.
1. I am the Defendant No.1 in the court below and Petitioner herein. I

know the facts of the case.
2. I submit that in the lower court i.e Senior Civil Judge court Addanki ,
Prakasam District in OS No. 76 of 2012 the suit for partition among
the schedule properties filed by the respondents/plaintiffs. In that suit
originally the schedule property was purchased by me and my sister-
in- law i.e plaintiffs’ mother jointly with by way of Registered Sale
Deed no. 54 5/1998 on 9-04-1998 , in 2003 I and my sister sister-in- law
wrote an unregistered partition list; based up on that list I am in possession
of my share land since then; my sister sister-in- law died in 2007, after that I
offered to sale my share property to the defendant No.2 in the suit, then the
plaintiffs due to some family rivalries with an ill intention file that above
false suit for partition.
3. I further submit that then as the 1st defendant for supporting my case I
filed my chief evidence affidavit along with list of documents, in that
the unregistered partition list was objected for marking, at that time I
pray the lower court for sending it to District Registrar, Markapur for
impounding, after completing all due process the said partition list
was certified by District Registrar, Markapur; then also the lower
court is not marked that document and returned it with its Docket
Order Dated on 25-03-2019.
4. I further submit that if the trial of the case goes on without marking
the document, the very purpose of filing this CRP would be defeated
rendering irreparable loss to me.
Under the above stated circumstances, I pray the Hon’ble court to stay
all further proceedings in O.S.No.76/2012 on the file of the Senior Civil
Judge, Addanki, during the pendency of this revision petition in the interest
of justice and to pass such other and further order or orders as deemed fit
and proper.
Deponent
Sworn and signed before me

this the 28th day of June, 2019.
Advocate/AMARAVATHI.
MEMORANDUM OF CRP.MISC.PETITION
UNDER SECTION 151 OF C.P.C
IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH
AT : AMARAVATHI
C.R.P.MP.NO. OF 2019
IN
CRP.NO. OF 2019
Between:
Narra Sri Lakshmi

Present R/o D.No. 15-101-1, Times Hospital road, Srinivsa Residency,
Tulasi nagar, Vijayawada, Krishna District, A.P. ..Petitioner/Petitioner
And



For the reasons stated in the accompanying affidavit the petitioner

pray this Hon’ble Court may be pleased to stay all further proceedings in
O.S.No.76/2012 on the file of the Senior Civil Judge, Addanki, during the
pendency of this revision petition in the interest of justice and to pass such
other and further order or orders as deemed fit and proper.
AMARAVATHI Counsel for the petitioner

Dt. 28-06-2019
DISTRICT : PRAKASAM
IN THE HIGH COURT OF

JUDICATURE OF ANDHRA
PRADESH: AT :
AMARAVATHI
C.R.P.M.P.NO. OF 2019
IN
C.R.P. NO. OF 2019
STAY PETITION
Filed On: 28-06-2019
Filed By:
MR.VIJAY BHASKAR PEDDI

(21032)
COUNSEL FOR THE PETITIONER

HIGH COURT
CRP. MISC.PETITION
CRPMP.NO. OF 2019
IN
CRP.NO. OF 2019
PRAKASAM : DISTRICT
Narra Sir Lakshmi

…. PETITIONER
BY: MR.VIJAY BHASKAR PEDDI

ADVOCATE (21032)
NATURE OF APPLICATION
UNDER SECTION 151 OF CPC
That this Hon’ble Court may be pleased
to to stay all further proceedings in
O.S.No.76/2012 on the file of the
Senior Civil Judge, Addanki, during the
pendency of this revision petition in the
interest of justice and to pass such other
and further order or orders as deemed fit
and proper
PRESENTED ON: 28-06-2019
REPRESENTED ON:
HIGH COURT
CIVIL REVISION PETITION
(Under Art 227 of the Constitution of

India.)
C.R.P.NO. OF 2019
PRAKASAM : DISTRICT
IN THE COURT OF THE

SENIOR CIVIL JUDGE AT
ADDANKI:: PRAKASAM
Docket Order Dt. 25-03-2019

IN
O.S. NO. 76 OF 2012
Narra Sri Lakshmi

…. PETITIONER
BY:P. VIJAY BHASKAR

ADVOCATE(21032)
VS.
Katragadda Venkata Anil Kumar

and others
…Respondents
Date of Order :
Presented On:
Re-presented on:
Filed on:
CRP.MP.No. of 2019
IN THE HIGH COURT OF JUDICATURE ANDHRA PRADESH
AT AMARAVATHI
C.R.P. No. OF 2019
RUNNING INDEX
Sl. Description of Date of Date of filing of Page

No. Document Document Document No.
Court Fee 28-06-2019 28-06-2019
Memorandum of 28-06-2019 28-06-2019

Grounds
Certified copy of 25-03-2019 - do - -Filed-
Docket Order in
O.S. No. 76 of 2019
Xerox Copy of
Docket Order in
25-03-2019
O.S. No. 76 of 2019 - do -
Copy of Plaint - do -
Copy of Written - do -
statement
Un registered 20-05-2003 - do -
Partition list
Letters of 28-06-2019
Impounding process
and Certificate - do -
issued by District
Registrar, Markapur
Vakalath 28-06-2019
AMARAVATHI,
DATE: 28 -06-2019 Counsel for the Petitioner
BATTA FORM

S/o late Krishna Murthy, Hindu,
Aged about 32 years,
Panchayati Secretary,

Jammulapalem Village,
Amaravathi,
DT.28-06-2019 COUNSEL FOR THE PETITIONER
BATTA FORM

Panchayati Secretary,

Jammulapalem Village,
Amaravathi,
DT.28-06-2019 COUNSEL FOR THE PETITIONER

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MEMORANDUM OF CIVIL REVISION PETITION

(UNDER SECTION 227 OF CONSTITUTION OF INDIA)

IN THE COURT OF SENIOR CIVIL JUDGE: AT ADDANKI

Docket Order Dt. 25-03-2019 IN O.S. NO. 76 OF 2012

IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH:

Narra Sri Lakshmi

1. Katragadda Venkata Anil Kumar

2. Katragadda Venkata Sunil Kumar

3. Bodepudi Maruthi Prasad, S/o Venkateswarlu

Aggrieved by the Docket Order Dated 25-03-2019 made in O.S No.76

1. The order of the lower court is contrary to law, weight of evidence

and probabilities of the case;

2. The Hon'ble Lower Court has failed to appreciate the statutory

provision available to the petitioners during the course of marking of

3. Refusing to mark the unregistered partitioned list dated 20-05-2003 is

against all canons of justice equity and fair play;

4. In any view of the matter refusing to marking the unregistered

partitioned list dated 20-05-2003 is arbitrary, illegal and against

settled principles of law;

5. The trial court ought to have marked the document.

6. The other grounds would be urged at the time of hearing of this

Amaravathi, Counsel for the Petitioner.

IN THE HIGH COURT OF

Filed On: 28-06-2019

MR.VIJAY BHASKAR PEDDI (21032)

COUNSEL FOR THE PETITIONER

C.R. M.P.No. of 2019

Smt. Narra Sri Lakshmi

1. Katragadda Venkata Anil Kumar

2. Katragadda Venkata Sunil Kumar

3. Bodepudi Maruthi Prasad, S/o Venkateswarlu

AFFIDAVIT FILED BY THE PETITIONER

I, Narra Sri Lakshmi, W/o Gopichand, Hindu, Aged about 45 years,

1. I am the Defendant No.1 in the court below and Petitioner herein. I

rendering irreparable loss to me.

all further proceedings in O.S.No.76/2012 on the file of the Senior Civil

Sworn and signed before me

Narra Sri Lakshmi

1. Katragadda Venkata Anil Kumar

2. Katragadda Venkata Sunil Kumar

3. Bodepudi Maruthi Prasad, S/o Venkateswarlu

For the reasons stated in the accompanying affidavit the petitioner

AMARAVATHI Counsel for the petitioner

IN THE HIGH COURT OF

C.R.P. NO. OF 2019

Filed On: 28-06-2019

MR.VIJAY BHASKAR PEDDI

COUNSEL FOR THE PETITIONER

Narra Sir Lakshmi

BY: MR.VIJAY BHASKAR PEDDI

That this Hon’ble Court may be pleased

to to stay all further proceedings in

O.S.No.76/2012 on the file of the

Senior Civil Judge, Addanki, during the

pendency of this revision petition in the

interest of justice and to pass such other

and further order or orders as deemed fit

PRESENTED ON: 28-06-2019

CIVIL REVISION PETITION

(Under Art 227 of the Constitution of

IN THE COURT OF THE

Docket Order Dt. 25-03-2019

Narra Sri Lakshmi