In the court of the honorable 1st additional chief judge, CCC

At Secunderabad IA No. 279 Of 2019

IN

OS No. 3 of 1990 and OS No. 167 of 1986

Between
Srirangam Srimath Andavan Ashramam
Rep. by its GPA holder Sri R. Vasudevan
… Decree Holder
And
Smt. Geeta Rama Swamy
… Judgment Debtor
ADDITIONAL AFFIDAVIT FILED BY THE DECREE HOLDER
I, R.Vasudevan s/o. Raghava chary, aged about 60 years
Occ: Financial Consultant, R/O. Flat No. 20,Lakshmi Towers,
plot no.175 road no.6,West Marredpally, secunderabad-500026
do hereby solemnly affirm and state on Oath as follows:-
1. That I am the petitioner in the IA and I am the general
power of attorney holder of the petitioner and as such I am well
aquainted with the facts of the case.
2. I submit that Late MSS Raghavan and his wife Smt.
Sugandham Raghavan were the owners and possessors of H.No.10- 20-
39/1 situated in Road no 4 west Marredpally Secunderabad. That
Late MSS Raghavan and his wife executed two different settlement
deeds in our favour vide regd Doc No. 1942 of 2008 and 1943 of
2008 dated 15- 07- 2008.
3. That the previous owner filed OS No 3 of 1990 and OS No
167 of 1986 on the file of honorable 1st Additional Chief Judge,
City Civil Court at Secunderabad, the same was decreed on 19- 04-
1994. Aggrieved by the said judgment and decree the respondent
filed CCCA No 20 of 1997 before the honorable high court at
Hyderabad and the same was dismissed on 29- 06- 2014.
4. As per the judgment and decree in OS No 3 of 1990
confirmed by the honorable high court of the suit scheduled
property. That the respondent JDR in one of its petition states
that the settlement deeds executed by Late MSS Raghavan and his
wife Smt. Sugandham Raghavan were brought into existence by
forgery, and it also expresses that they expired long time back
and the settlement deed was executed only during 2008.
5. In this regard the attention is drawn into CCCA MP 305 of
2012 in CCCA No 20 of 1997 of the Honorable High Court of AP. It
it mentioned in the orders dated 20- 06- 2014 by the Honorable
High Court CCCA No 20 of 1997 that our Ashram was impleaded and
as per the court order dated 04- 11- 2013 CCCA MP 305 of 2012.
6. In this regard I submit that the affidavit filed by Sri
Chitra Rajagopalan S/o. Late Sri S. Ramaswamy in CCCA MP 305 of
2012 it was alleged that in page 2, as follows " the respondents
2 and 3 are residing at Madras at that time as their son Sri MS
Ramaswamy was temporarily residing at Hyderabad in the suit
scheduled property. The respondents 2 and 3 executed the
settlement deed vide Regd Document No. 942 of 2008 in favor of
the Ashram and the said gift settlement deed was executed on 15-
07- 1998 and the same was kept pending and it was released on
5- 9- 2008 and the same was executed after the disposal of the
suit No OS 167 of 1986 and 3 of 1990 by a common judgment of
1994. The respondents due to their spiritual interest executed
2/3 rd share in favor of the Ashram. The JDR did not file any
counter CCMP 2305 of 2012 and the ultimate the said MP was
ordered on 4- 11- 2013 and it has become final and conclusive.
Subsequently the respondent filed the SLP in Supreme Court and
the same was dismissed.
7. The documents in the form of certified copy of
settlement deed shows the date of presentation as 20- 07- 1998.
as per the endorsement and the registration charges were paid on
the same date. Though the document was pending and registered in
2008. At the time of presentation a sum of Rs. 6,426/- was
received by the Sub Registrar towards stamp duty and the stamp
duty was enhanced to Rs. 31,930/- as per the endorsement dated
20- 06- 1998. In the second document also the gift settlement
deed was presented on 20- 07- 1998 and a sum of Rs. 6,426/- was
received towards registration charges on the date and Rs.
31,930/- was received towards stamp duty. The gift settlement
deed was presented on 20- 06- 1998 itself when the donor was very
much alive and it was also attested by the witness on the same
day. In view of the discrepancy with regard to market value stamp
duty the documents were kept pending and finally released on
2008. In this regard I submit that the JDR is highly influential
and managed the registration officials to disappear the
documents. After persisting and continuous efforts we got the
documents from the registrar. The crucial point that is to be
noted by the Honorable court is the date of presenting the
document is a conclusive proof. Though the registration number
at a later date. In this regard all the non testimonials
presented for registration entered in book no 1 and the documents
kept pending in book no. 2. The documents refused in Book No.3.
The testimonials and GPA are entered in Book No. 4 as per
registration rules.
7. I submit that the respondent JDR is ignoring the basic
fundamentals of the acts and rules followed by the registering
public authority and irresponsible statements across the bar .
the documents were manipulated and forgery and there it is in
order to place the facts and it has become necessary for us to
file this additional affidavit. In order to falsify the
contention of the JDR.
8. it is also brought to the notice of the honorable court
that the JDR was represented by a senior advocate who also filed
his counter for commissioner and final decree. Both the petitions
were filed simultaneously on 22- 10- 2018. The petition for
appointment of commissioner was filed on 7- 8- 2018. However
after going through the file we have come to know that the
passing of the final decree is missing from the court file. I
therefore pray this honorable court to permit us to file the
extra copy. We are filing the copy of the affidavit of CCAMP 2012
along with the additional affidavit.

Sworn and Signed Deponent

before Me on 18-07-2019 Before Me

Advocate
 In the court of the honorable 1st additional chief
judge, CCC

At Secunderabad IA No. 279 Of 2019

IN

OS No. 3 of 1990 and OS No. 167 of 1986

Between

Srirangam Srimath Andavan Ashramam

Rep. by its GPA holder Sri R. Vasudevan
… Decree Holder

And

Smt. Geeta Rama Swamy

… Judgment Debtor

PETITION FILED UNDER SECTION 151 CPC

For the reasons stated in the accompanying affidavit it

is prayed that this honorable court may please allow
additional affidavit and pass such other orders as the
honorable ourt deem fit and proper under the
circumstances of the case.

Counsel for the petitioner

Secunderabad
Date: