Reserve Bank Of India [RBI] — Opening of new branch of dccb - medak branch on civil dispute land in spite of notices to ceo and directors and managers of the bank

Address: 502279

Respected sir,

Sub: notice & protest petition not to enter into any lease agreement /cancellation /termination of lease for establishment of dccb bank at vantimamidi, gajwel, siddipet district., on the premises in sy. No.72/40 to an extent of 0.31 guntas situated at chinna thimmapur village, mulugu mandal, siddipet district., being the subject matter of civil case in o. S. No.141 of 2007 on the file of hon’ble junior civil judge court at gajwel & also subject matter of lokayuktha case no.4264/2016 and writ petition 4203/2017 on the file of hon’ble high court – request – regarding.

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Under the instructions of my client sri k. Raja reddy s/o k. Papi reddy, r/o chinna thimmapur village, muluug mandal, siddipet district., telangana state., i make representation to your kind authority for necessary action.

1. My client represents to me that he is the owner and peaceful possessor of the open land admeasuring ac.0-31 guntas, in sy. No.72/40, situated at chinna thimmapur village, mulugu mandal, siddipet district.

2. My client submit that the one gowlikar srinivas and his brothers s/o rajaram, in collusion with cherukupally shiva reddy herein have falsely filed the civil case against my client and his vendors and my client’s lessee i. E, bsnl in order to create legal hurdles and to grab my client’s valuable property i. E, admeasuring ac.0-31 guntas, in sy. No.72/40., under fabricated documents without any valid right or title over the said property vide o. S. No.141/2007 on the file of the hon’ble junior civil judge court at gajwel.

3. My client further submits that the cherukupally shiva reddy does not possess any title nor right over the property at any point of time as he is defaulter of non-payment of consideration amount to my vendor i. E., katike baloji and due to which he never handed over the original title deeds nor physical possession to the cherukupally shiva reddy and taking the taking the advantage of his name, become evil minded and conspired and colluded with gowlikar srinivas and his brothers and to grab my client land, as rates of land have gone high and executed a false and fabricated registered sale deed no.7775/2006 and the said sale deed is an invalid document as it has been done with a malafide intention without paying any consideration in order to deceive my clients rights and title over the said property.

4. My client further submits that ch. Siva reddy nor the gowlikar srinivas and his brothers were never inducted into possession of the suit schedule property, kakike bolji never handed over the title nor possession to them and in fact the katike bolji was in uninterrupted physical possession right from the year 1976, when the land has been purchased from one sriram sharma till the physical possession was delivered to my client and since then my client was in physical possession of the above property and my client being the owner and possessor of the above property, my client had leased part of said land to bsnl department for errection of cell tower in the year 2005 and since then the bsnl departmental authorities are regularly paying the rentals to me for the said tower and they are rendering their services uninterruptedly to customers at large.

5. My client further submit that the gowlikar srinivas and his brothers without having any valid title or right over said property and without having any locus-standi and with false cause of action have filed the civil suit against my client vide o. S. No.141/2007 on the file of the hon’ble junior civil judge court at gajwel and obtained exparte ad-interim injunction orders and doing the illegal acts.

6. My client submits that at present the above case is pending before the hon’ble court and already my client had placed all his records before the hon’ble court and my client had already issued a notices to the concerned authorities as stated above not to permit any construction permission/ cancellation of construction permission and to demolish the illegal structures that have been raising during the pendency of the civil suit vide i. A. No.807 of 2016 in o. S. No.141 of 2007.

7. My client also filed the application for restraining the gowlikar srinivas and his brothers restraining them from encroachment and raising illegal structures in and over the suit schedule property along with the acknowledgement copy issued by panchayath raj and gram panchayath authorities., intimating that it would amount to the contempt of the court.

8. My client further submits that the gowlikar srinivas and his brothers without having any valid title or right over said property, under the guise of the above case and illegally encroached into my client property and started making illegal construction of illegal structures in collusion with the sarpanch zapthisingaipally gram panchayath having fabricated and forged the building permission and raised the illegal building on the basis of residential house and constructed the commercial building without any permission from the gram panchayath or any revenue authorities of mulugu mandal, siddipet district knowing fully about the pendency of civil case with regard to title dispute and i. A. No.807 of 2016 in o. S. No.141 of 2007., restraining from raising illegal construction in sy. No.72/40.

9. My client further submits that he had already taken the legal steps and perusing above illegal acts of the gowlikar srinivas and his brothers in collusion with the sarpanch zapthisingaipally gram panchayath for creating fabricated and forged the building permission and raising the illegal building on the basis of residential house and constructed the commercial building before the court of law and also filed applications to restrain from leasing/ rental/ encumbering to the third parties during the pendency of civil suits and also filed application for removing of illegal structures and restoring the physical possession to my client., which has been illegal encroached during the pendency of the civil suit.

10. My client further submits that he also made complaint against the sarpanch before the district panchayath officer, siddipet district., district collector - siddipet district, joint collector, thasildhar mulugu and also to the minister for panchayath raj regarding the indulgence into civil disputes and also misusing his power and position as sarpanch and indulging in illegal acts for illegal gain by issuing building permission in previous dates that of application date and further for non-action against illegal acts in-spite of the above complaints, my client had already filed the complaint before the lokayuktha of andhra pradesh and telangana state on[protected] vide complaint no.4264/2016 and same is under adjudication.

11. My client submits that he came to know that the district coop. Central bank limited, medak, having head office at sanga reddy and branch office at gajwel are entering into a lease agreement with goulikar srinivas for establishing the district coop. Central bank limited, branch at vantimamidi on the premises., which was constructed illegally by encroaching into my client property in sy. No.72/40, to an extent of ac.0-31guntas at chinna thimmapur village, basing upon a fabricated and forged documents during the pendency of the above civil suit and lokayuktha case and pending application restraining from raising illegal construction and creating third party interest by way of lease and encumbrances.

12. My client further submits that the said gowlikar srinivas and others illegal construction of illegal structures over the property which is subject matter of the civil case and title under the dispute before the hon’ble civil court at gajwel, siddipet district., vide o. S. No.141/2007 and the complaint before the lokayuktha of andhra pradesh and telangana state on[protected] vide complaint no.4264/2016 for the inaction of panchayath raj and gram panchayath authorities inspite of notice under section 80 c. P. C., during the pendency of civil suit., being considered as contempt of the court and further the district coop. Central bank limited, medak entering into the lease agreement for establishing the district coop. Central bank limited, branch at vantimamidi on the premises., which was constructed illegally by encroaching into my client property in sy. No.72/40, to an extent of ac.0-31guntas at chinna thimmapur village, basing upon a fabricated and forged documents during the pendency of the above civil suit and lokayuktha case and pending application restraining from raising illegal construction and creating third party interest by way of lease and encumbrances, will be considered as a contempt of court and misleading of judicial proceedings on the civil dispute land.

13. My client states that the district coop. Central bank limited, medak has good reputation and values in the eyes of law and trust among the people at large and inspite of the knowledge about the civil disputes over the said land in sy. No.72/40 and deliberate and intentional entering into a lease on the premises under title dispute., not only amount to cheating my client and also on the trust of public at large and hence my client had already intimated the gajwel and mulugu branch pacs chairmans about the title dispute and pendency of the civil suits will be considered as contempt of the court and irreparable loss and injury with multiplicity of litigation and misleading public at large.

14. My client further states that he had approached the hon’ble high court and filed a writ petition 4203/2017., seeking the removal of illegal structures that have been constructed on my client land by encroaching during the pendency of the above suit and also field wpmp no.5037/2017 and wpmp no.5039/2017 seeking the relief of further construction and also from creating third party interest by leasing on the premises in sy. No.72/40., to an extent of ac.0.31guntas in chinna thimmapur village (Vantimamidi) of mulugu mandal, siddipet district.

15. My client submits that already he had issued a notice/protest petition requesting you to drop the establishment of dccb bank on the said premises on[protected] and inspite of the above notice/protest petition., dccb authorities still going further knowing fully above the litigation on the said premises and it would amount to contempt of court and also false under sec.23 of banking companies (Amendment) act, 1953 and a complaint is also given to the regional director, reserve bank of india
6-1-56, secretariat road, saifabad, hyderabad-500 004.

In view of the above said facts and circumstances, i therefore, request your kind authority to take immediate action by considering my notice, as a protest petition and not to enter into lease agreement for establishing the district coop. Central bank limited, branch at vantimamidi on the premises., which was constructed illegally by encroaching into my client property in sy. No.72/40, to an extent of ac.0-31guntas at chinna thimmapur village, basing upon a fabricated and forged documents during the pendency of the above civil suit o. S. No.141 of 2007 on the file of hon’ble junior civil judge at gajwel and a lokayuktha case no.4264/2016 and writ petition 4203/2017 pending application restraining from raising illegal construction and creating third party interest by way of lease and encumbrances and further to cancel and terminate the lease if any., as it amount to the contempt of court and by considering my protest petition with kindness or else my client had further instructed to take appropriate legal action against yourself for disobedience of this notice.