482 FIR Quash Sample 2

 

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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

1 2 / 1 2 /2 01 8

EVENT

The respond respondent ent no. 2 g given iven a wr written itten infor information mation 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 ot other her two ac accused cused 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

 

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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, 5 th  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 nothing has transpired. Of course, on enquiry with Mirale Varadaraju, the first petitioner herein, it as said that both Munivenkatappa and

 

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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 pr prevented evented from tak taking ing rec recourse ourse un under der 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 iinformation. nformation.

On the basis of the advise of on onee

Shanmugappa, the present written information is lodged with jurisdictional  police i.e., the first respondent –  respondent –  police.  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 DATE: 30/01/2019

ADVOCATE FOR PETITIONERS

 

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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:

1. 

2. 

RANK OF PARTIES TRAIL COURT/HIGH COURT

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 

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. 

2. 

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

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 

 

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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. 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  N  No o . 3 6 5 / 2 0 1 8 ( C I S C R N O . 6 / 2 0 1 9 ) 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

 N  No o . 3 6 5 / 2 0 1 8 d a t e d 1 2 / 1 2 / 2 0 1 8 and the written information dated 12/12/2018 and entire proceedings in Crime No.365/2018(CIS CR

 

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 N  NO O . 6 / 2 0 1 9 ) 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 f ormation of road and that on 04/04/2000, the first pe petitioner titioner has written a letter to the Secretary, BDA Bangalore stating in it that the father of the second respondent was residing at No.544, 5 th  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 ttime, ime, 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 –  attorney –  Mirale  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 be aring 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 4 th  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

 

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 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, tthe he present

 

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

 

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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

 

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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 r espect espect 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

 

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the written information dated 12/12/2018, lodged by the respondent no. 2 herein against the petitioners who are accu accuse sed d no no.. 1 aand nd 2 for the off enc es pun ish abl e und er 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

Ci ty ., vi vide de ANNEXURE-“A” and “B”.   b  b))   Quash

the

entire

 N  No o. 3 65/20 18 (CIS

proceedings

CR

N O. 6/2 019 )

in

Crime

against

the

 petitioners who are accused no. 1 and 2 f o r t h e o f f e n c e s  p  pu u nishable un der Sectio ns 4 65, 4 67 , 4 68, 471, 4 20 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 DATE: 30/01/2019

ADVOCATE FOR PETITI ONERS

 

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IN THE HIGH COURT OF KARNATAKA, AT BENGALURU I.A. NO:_______/2019 IN CRIMINAL PETITION NO:_______________/2019(482) BETWEEN:

1.

2.

RANK OF PARTIES TRAIL COURT/HIGH COURT

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  

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.

2.

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

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

 

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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 nece necessary ssary to sstay tay 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 f o r t h e o f f e n c e s p u n i s h a b l e u n d e r 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 agains t the petitioners who are accused no 1 and 2 till disposal of the above  p  pee t i t i o n , in the interest of justice and equity.

PLAC: BENGALURU DATE: 30/01/2019

ADVOCATE FOR PETITI ONERS

 

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  N  NO O . 6 / 2 0 1 9 ) , a l o n g w i t h t yp e d c o p y.

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 settlement.

11.

ANNEXURE-“F1”:-  Copy 27.07.2001. 

of

the

letter

dated

12.

ANNEXURE-“F2”:-  Copy 27.07.2001. 

of

the

letter

dated

13.

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

of

the

full

and

final

 

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 DATE: 30/01/2019

ADVOCATE FOR PETITIONERS