IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE I.A.NO: /2011 O.S.

No: 56/2010 Petitioner/ Defendant : V. Surendra Respondent/ Plaintiff : B. Sankar Reddy

COUNTER FILED ON BEHALF OF THE RESPONDENT/ PLAINTIFF 1. The Petition filed by the Petitioners is not maintainable either in law or on facts and the same is liable to be dismissed in limine. 2. The allegations mentioned in the Affidavit are all false and incorrect and the Petitioners are put to strict proof of each and every allegation except those that are specifically admitted herein to be true and correct. 3. The allegations mentioned in the Affidavit that as the Plaintiff has not admitted the promissory note , Ex.B-1 alleged to have been executed by the father of the Defendant in favour of the Plaintiff, the Petitioner/ Defendant approached the scribe of the said document to give evidence , but he insisted for witness summons and that his evidence is crucial

in the above case to decide the real point in issue are all false and incorrect. 4. It is submitted that the Plaintiffs side evidence was closed on 14-07-2010 and posted for Defendants side evidence to 12-08-2010 months, further and since one year has four been of the Defendant after

prolonging the matter without adducing evidence examination D.W.-1 and wantonly , this petition is filed to summon the scribe of Ex.B-1, who is the supporter of the Defendant and who can come and give his evidence on his behalf without summons, and only to delay the matter, this petition is filed without any real purpose. It is humbly submitted that the Plaintiff clearly denied the execution of the alleged pronote, Ex.B-1, said to have been executed by the father of the Defendant when confronted by showing the same and as such, there is no need to prove the contents of Ex.B-1 when it is flatly denied. such a The Defendant has taken only for purpose of defense

prolonging the matter and there is no grain of truth in it. There is no nexus between Ex.B-1 and the borrowal under Ex.A-1. The said Ex.B-1 is not only Therefore, when inadmissible , but also not relevant for the purpose of the case. Ex.B-1 is not duly stamped and can not be marked and can not be considered, the question of proving the same by summoning the scribe does not arise. There are absolutely no valid grounds to allow the petition. 5. It is therefore most humbly prayed that the Honble court may be pleased to dismiss the petition with costs, in the interest of justice. Madanapalle, counsel the Respondent/ Plaintiff Dt:18-01-2012 for

IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE Plaintiff : Defendant O.S.No: 56/2010 B. Sankar Reddy : V. Surendra

FULL SATISFACTION MEMO FILED ON BEHALF OF THE PLAINTIFF It is humbly submitted that the above matter is compromised between both the parties due to intervention of elders and well wishers of both the parties as a result

of which, the Plaintiff received a sum of Rs.30,000/- (Rs. Thirty Thousands only) from the Defendant in full and final settlement of his claim. memo. Hence, this

It is therefore most humbly prayed that the Hon'ble court may be pleased to record FULL SATISFACTION on behalf of the Plaintiff in the above suit for a sum of Rs.30,000/- (Rs. Thirty thousands only) by dismissing the suit without costs, in the interest of justice.

Madanapalle,

Plaintiff

counsel for the Plaintiff Dt:21-03-2012

IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE Plaintiff : Defendant O.S.No: 56/2010 B. Sankar Reddy : V. Surendra

RECEIPT I, B. Sankar Reddy, the Plaintiff in the above suit received a sum of Rs.30,000/(Rs. Thirty Thousands only) in cash from the Defendant in full and final settlement of my claim in the above suit, on this the 21st day of March, 2012 at Madanapalle.

Madanapalle, Dt:21-03-2012 Plaintiff