By Regd Post with Ack-due

Kadapa,
25-07-2018.

From:-
Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District.
To:-
Kommuru Tandava Krishana Reddy
S/o. Chinna Venkata Reddy,
Obulavaripalle Town Post & Mandal,
Kadapa District.
PIN 516108

Sir
Sub:- Second legal notice clarifying that you have no right or
authority over the property of murdered Kommuru Yasodamma and
her husband Chinna Narasa Reddy alias Narasa Reddy and that my
client, his sons and daughters are legal representative of Yasodamma
and her husband Chinna Narasa Reddy alias Narasa Reddy – Rg.
Under the instructions and on behalf of my client Sri. Kommuru
Sidda Reddy son of late Pedda Venkata Reddy aged about 76 years senior
citizen residing at Obulvaripalle Town Post & Mandal, Kadapa District, I
herely issue this second legal notice to you with the following facts.
***
1. My client submits that you and Ramachandra Reddy said to
have manufactured a will dated 05-08-1981 by forging the signature of
Narasa Reddy for 15 items of property of Kommuru Narasa Reddy for
knocking away that property of 15 items. Later Kommuru Yasodamma
filed O.S No. 18/1989 IN SENIOR CIVIL JUDGE COURT OF RAJAMPETA
against you and Ramachandra Reddy. You both filed your written
statement by filing your forged will dated 05-08-1981 by engaging your
advocate Sri.S.Ravindra. The HONOURABLE SENIOR CIVIL JUDGE OF
RAJAMPETA pronnounced Judgment in O.S No. 18/1989 on 23-08-2000
by declaring the right and title of Yasodamma over that 27 items of
property to the extent of half share in those items. So you and
Ramachandra Reddy have no right or authority over the property of
Yasodamma and her husband since you did not file any suit against
 :: 2 ::
Kommuru Yasodamma or my client for declaration or partition of your 15
items property covered under your will dated 05/08/1981. The will dated
05/08/1981 has A-Schedule of you covers only 13 items and B-Schedule
of late Ramachandra Reddy covers only 2 items out of 27 items in O.S
No.18/1989. You did not file any partition suit against Kommuru
Yasodamma for partition of your 13+2=15 items of property out of 27
items of Kommuru Yasodamma. Your based your claim in O.S No.18/1989
basing on will dated 05/08/1981 for only 15 items of property our of 27
items. The Honourable court declared the right and title of Kommuru
Yasodamma over 27 items of property to the extent of half share in 27
items.
2. My client filed O.S No.4/2006 against Kommuru Yasodamma
basing on his agreement of sale dated 10/02/1999 executed by Kommuru
Yasodamma in favour of my client. My client submits that the said
defendant Kommuru Yasodamma was murdered on 07/05/2014 night.
The legal heirs of late Kommuru Yasodamma were not brought on the
record of O.S No. 4/2016 as her legal heirs to contest that O.S No.
42/2006 suit since my client and his sons and daughters are legal
representations of late Yasodamma and that my client and his sons and
daughters inherited all the properties of late Kommuru Yasodamma.
Hence the Honourable SENIOR CIVIL JUDGE OF RAJAMPETA was pleased
to dispose of O.S No.4/2006 on 27/06/2016 on the ground that there is
no actionable claim pending in this suit since opponent of my client i.e
Kommuru Yasodamma was murdered on 07/05/2014 and that there is no
opponent or claimant claiming in O.S No. 4/2006 suit schedule property
of my client and that the agreement of sale dated 10/02/1999 executed
by Kommuru Yasodamma was unopposed and absolute rights of my
client over that property was fructified. That Honourable court did not
pass any judgment on merits and that the order of the court in O.S No.
4/2006 is that there is no actionable claim pending against the plaintiff
and that suit O.S No. 4/2006 was disposed of as uncontested on 27th day
of September 2016.
3. Further you both filed E.P No. 40/2008 in O.S No.18/1989 for
alleged partition of those 27 items of property claiming half share right in
that property by allotting half share property in that property to you. The
Honourable Senior Civil Judge Court Rajampeta dismissed your E.P No.
40/2008 on 21-10-2009 by holding that you have no right or authority to
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pray for division and allotment half share to you both in 27 items of
property since that O.S No.18/1989 was not a partition suit and it was a
suit for declaration. This is second order of the court by holding that you
have no right or authority over 27 items of property of Kommuru
Yasodamma and her husband.
4. Yasodamma filed O.P No. 1/1989 in DISTRICT MUNSIFF
COURT AT RAJAMPETA for getting succession certificate which was
dismissed on 14/07/1992. Later A.S No.47/1998 was filed by Kommuru
Yasodamma for getting succession certificate and that was also dismissed
on 26-10-1998. Later Kommuru Yasodamma filed C.R.P No. 5274/1998
and C.R.P No. 3905/1999 against you and got favorable orders after
disposal on 17-03-1999 and on 01-02-2000. My client has been residing in
the house bearing door No. 10-14-A in Obulavaripalle town since 19998
up to now for more than 20 years as per the aspirations of Kommuru
Yasodamma since Yasodamma treated my client and brought up him as
her sakudu Koduku. The DISTRICT MUNSIFF COURT in O.S No.1/1989 and
FIRST ADDL DISTRICT JUDGE COURT IN KADAPA in A.S No. 47/1993 did
not declare your rights over the O.S No. 18/1989 property or O.S No.
4/2006 property. The FIRST ADDL DISTRICT JUDGE COURT IN KADAPA in
A.S No. 47/1993 held that the parties in that case are at liberty to agitate
about their rights covered under Ex: A-4 in a separate suit and it is wide
open to be decided in another suit.
5. You issued a reply notice through your advocate on 06-07-
2018 by falsely stating that you are residing in the said building with
absolute rights even though you are not at all residing in that building.
The decree in O.S No. 18/1989 speaks about the property in item No.21
as S.No.470/4 and S.No. 469/1 as well as in other items property that the
right and title of Kommuru Yasodamma was declared for half extent of
property. The will dated 05-08-1981 says that you and Ramachandra
Reddy have no absolute rights over A and B schedule properties and your
sons will have absolute right over that property of 15 items as found in
will dated 05/08/1981. You have no right or title over the house property
where in my client is residing since 20 years upto now. You did not file
any suit either for declaration or partition of the properties covered
under your will dated 05-08-1981 since my client, his sons and daughters
and some other persons who are now claiming that property of
Kommuru Yasodamma and her husband Narasa Reddy. You and
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Ramachandra Reddy filed E.P No.40/2008 for partition and separate
possession even that decree in O.S No.18/1989 was only for declaration
of title and delivery of possession and that O.S No.18/1989 is not a
partition suit. Hence the Honourable SENIOR CIVIL JUDGE OF RAJAMPETA
dismissed your E.P No.40/2008 on 21/10/2009. So you are requested to
file declaration suit covering all the properties against all the claimants
including new aspirants and later file another suit for partition.
6. You are coming very often against the interests of my client
by claiming your alleged rights over the property of Kommuru
Yasodamma and her husband. You stated in the reply notice that you are
the absolute owner of shop room property leased out to T.Mahesh and
that you are receiving the rent of thousand P.M from the that T.Mahesh
even though my client is the absolute owner of that property and 27 item
of property.
7. The Junior paternal mother (Chinnamma) aunt named
Kommuru Yasodamma brought my client and his children to her house
about 20 years ago and brought them in her house as her legal
representation for her property. My client is the Sakudu Koduku of
Kommuru Yasodamma since Kommuru Yasodamma voluntarily with
100% interest as her sakudu Koduku for inheriting her properties. Hence
my client and his sons and daughters are legal representatives for the
property of Kommuru Yasodamma and her husband. My client is in
Possession and enjoyment of all the properties of Kommuru Yasodamma
after her murder on 07-05-2014. Now you are trying to claim your alleged
rights over the property of Kommuru Yasodamma even though you lost
your rights on 23-08-2000 and on 21-10-2009 by virtue of Judgment,
decree and order of SENIOR CIVIL JUDGE COURT OF RAJAMPETA.
8. You issued reply notice dated 06/07/2018 with false
allegations bye-passing decrees and judgments competent courts. Your
reply notice states that O.S No.4/2006 was dismissed on 26/09/2016
even though that suit was not decided on merits and no judgment was
passed on merits in O.S No.04/2006 on 26/09/2016. The Honourable
court was pleased to pass orders on 27th September 2016 as O.S
No.4/2006 was disposed as uncontested.
9. You reply notice dated 06/07/2018 is being issued in such an
aspect to threaten my client and close the door of justification in
personation of truth and justice basing on material facts and realities.
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Nobody can take law permanently against the truth and dharma. The law
is open to everybody to take steps as and when required by such
persons. There are about a dozen of persons calming the property of
Kommuru Yasodamma and her husband since they have no issues to
inherit their property.
10. Therefore please take this second legal notice and that you
should not try to claim your alleged rights over the property of Kommuru
Yasodamma which property has been in possession and enjoyment of my
client as absolute owner after the murder of Kommuru Yasodamma on
07-05-2017. Otherwise my client is forced to take appropriate Civil and
Criminal steps against you as per the provisions of law by holding you
liable for costs and consequences.

Advocate