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Bodige Ramdas Revenue 30012023
Bodige Ramdas Revenue 30012023
ANNEXURE – II
Under Article 226 of Constitution of India and Telangana Rights Pattadar Passbooks
Act -2020
Hyderabad
Date: .1.2023 Counsel for the petitioner
HIGH COURT FOR THE STATE OF TELANGANA
AT HYDERABAD
W.P.No. OF 2023
CHRONOLOGICAL / RUNNING INDEX
16 Vakalath -do-
W. P. NO. OF 2023
Between :
Bodige Ramdas Goud, S/o Lakshmaiah,
Aged about 70 years, Occ: Social Service,
R/o.I1. No. 2-100, Parvathapur
Gandhinagar, Peerzadiguda Municipal Corporation,
Medipally Mandal, Medchal - Malkajgiri District.
..Petitioner
AND
4. The Tahsildar,
Medipally Mandal,
Medchal-Malkajgiri Dist.
...Respondents
AFFIDAVIT
1. I am the deponent herein and I am well acquainted with the facts of the
present case.
2. I humbly submit that, the Respondent State had acquired a private patta land to
an extent of Ac.1-03 Gts situated in Sy.No.152 of Peerzadiguda Village,
belonging to one Mr. Mamindla Bikshapathi, for the purpose of' allocating it as
a graveyard to SC/ST community of Parvathi Village. I submit that, the
Respondent State Government neither paid any compensation to the erstwhile
pattadar, Mr. Mamidla Bikshapathi, nor initiated any land acquisition
proceedings, but convinced the said
pattadar, to accept an alternative Government land to an extent of Ac.1-00 Gts
situated at Sy.No.62 of Medipally Village, way back in the year 1996.
4 I further humbly submit that, the 4th Respondent exercising his powers under
"Rule 16" of the "Land Revenue Rules, 1951", immediately converted the patta
land in Sy.No.152 of Peerzadiguda Village as Khareez'" in favor of the State
Government and accordingly "Form C" under "Rule 16" was issued in the
Janmabandi for the year 1999, vide Proceedings No. A/2913/97, Dt.10/02/1999
issued by the 4th Respondent. The copy of the said document is filed as Exhibit
P2.
6. I further humbly submit that the direction of the 2nd Respondent to handover the
advance possession to the pattadar was duly implemented by the 4th Respondent
vide. Lr.No. LC 2/2559/2002 Dt.20/12/2012, by conducting a "panchanama" on
18/01/2013. Accordingly, the possession of the said land was taken over by
Late Mamindla Bikshapati. The 4th Respondent's proceeding and the
accompanied Panchnama, are filed as Exhibit P4 & P5 for the perusal of this
Hon'ble Court.
7. I further humbly submit that, the 4th Respondent, vide his Lr. N0. B/1028/2012,
Dt.05/ 02/2013, duly intimated the 2nd Respondent that his orders
Dt.24/05/2002, had been implemented by handing over the advance possession.
The Copy of this document is filed as Exhibit P6.
8. I further humbly submit that, even though the entire proceedings are being
conducted in the name of Late M. Bikshapati, who divested his interest in the
said land for a valuable consideration my favor, gives me the locus to file the
present writ petition and to seek reliefs.
9. 1 further humbly submit that, the factum of M. Bikshapati divesting his interest
in my favor was intimated to the 4 th Respondent by duly deposing a sworn
statement before the 4th Respondent along with his family members/legal heirs.
The said 4th Respondent had taken cognizance of the said fact, which can be
discerned from the Letter written by him to the 3 rd Respondent (RDO) on
10/08/2016, vide Lr.No.B/1440/1998. In this letter the 4th Respondent requested
the 3rd Respondent to consider my request of recording my name as pattadar in
regard to the alternative land allotted by the Government in Sy.No.62 of
Medipally Village. The said letter of the 4th Respondent is filed as Exhibit P7
for the perusal of this Hon'ble Court.
10. I further humbly submit that, at the instance of my representation
Dt.14/02/2020, the 4th Respondent once again wrote a letter to the 3 rd
Respondent duly marking a copy to the 2nd Respondent narrating the entire facts
of the case right from 1999 to 2020. In this letter the 4 th Respondent
categorically admitted my legal possession and enjoyment in so far as Ac.1-00
Gts situated at Sy.No.62 of Medipally Village is
concerned and requested the 3rd Respondent to update the revenue records in
my name. The said document is filed as Exhibit P8 for kind perusal of this
Hon'ble Court.
11. I further humbly submit that, the 3rd Respondent in response to the said request
of the 4th Respondent, had instructed the 4th Respondent to update the revenue
records, as per the ROR from time to time, and the relevant G.0's / instructions,
the LRUP (Land Records Updation Programme) guidelines and latest
instructions, if any, from the Government, vide his letter No. D/2263/2020,
Dt.14/09/2020. The
same is filed as Exhibit P9, for the kind perusal of this Hon'ble Court. But till
today, the 4th Respondent neither updated the revenue records nor issued the
Rythu Bandhu Passbook under the "Dharani Policy, aggrieved whereby, I am
constrained to file the present writ petition.
12. And now, since recently, the Respondents have become unresponsive to all my
requests and despite my absolute right, title and possession in respect of Ac.1-
00Gts of land in Sy.No.62 of Medipally Village, they are trying to dispossess
me from my land for reasons best known to them, earlier I filed W.P.No.17981
of 2021 which was withdrawn for non-filing of relevant documents. Since then,
I made several requests before the Respondents but went in vain. Constrained
whereby, I am filing the present writ petition.
13. In the circumstances stated herein above, the petitioner has no other ellicacious
alternative remedy, except to approach this Hon'ble Court, under Article 226 of
the Constitution of India. The petitioner has not filed any other writ petition,
suit or other proceedings, for the relief or reliefs which are being sought for in
the present writ petition.
14. In the light of the above facts, it is most humbly prayed that this Hon'ble Court
may be pleased to issue a Writ, Order, or direction more particularly one in the
nature of Writ of Mandamus- .
iii. To pass such other order(s) as this Hon'ble Court may deem fit and
proper in the circumstances of the case.
15. It is further humbly prayed that, pending disposal of the main Writ Petition, this
Hon'ble Court maybe pleased to restrain the Respondents from dispossessing
the Writ Petitioner from his land admeasuring Ac.1- 0OGts in Sy.No.62 of
Medipally Village, Medchal-Malkajgiri District, which is allotted to him by the
Respondents in exchange of patta land admeasuring to Ac.1-03Gts in
Sy.No.152 of Peerzadiguda Village, Medchal-Malkajgiri Distriet, vide
Panchanama" Dt. 18/01/2013, in the interest of Justice, and to pass any other
order (s) as this Hon'ble Court may deem fit and proper in the circumstances of
the case.
16. It is further humbly prayed that, pending disposal of the main Writ Petition, this
Hon'ble Court may be pleased to direct the Respondents 1o consider and
dispose-of the representation of the Writ Petitioner in regard to the pendency of
updating the revenue records and issuing the Pattadar Passbook cum Title
Deed, in respect of the land admeasuring Ac.1-00Gts in Sy.No.62 of Medipally
Village, Medchal-Malkajgiri District, in the interest of Justice, and to pass any
other order (s) as this Hon'ble Court may deem fit and proper in the
circumstances of the case.
ADVOCATE/HYDERABAD
VERIFICATION