IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH

AT AMARAVATHI

W.P. (P.I.L.) No. of 2023

Between:
MANNAM SUDHEER KUMAR
…Petitioner/Party in
person
AND
THE STATE OF ANDHRA PRADESH AND OTHERS …
Respondents

CHECK LIST FOR WRIT PETITION

S. Item No. Page No. Checking

No Officer’s
. Signature
1.
2.
3.
4.
5.

ORIGINAL SET

1) Proof of Service
2) Court Fee Rs.
3) Writ Petition
4) Annexures I & II
5) Affidavit
a) Averment regarding previous proceedings (mention Page No. Para
No. )
b)Averment regarding alternative relief (mention Page No.
Para No. )
6) Verification Statement
7) Enclosure
8) Material Papers to
(Duly Indexed P. Series) to
9) a) Vakalath Rs. /-
b) Power of Attorney/Resolution Authorising to sue if petition is filed
in rep. capacity
10)Sheet containing Respondents' Addresses
DUPLICATE SET

11) Writ Petition

12) Annexures I & II
13) Affidavit to
14) Material Papers
MISCELLANEOUS SET

15) Batta Rs. /-

16) Rule Nisi Forms Filed
17) Covers with Postal Addresses & Ack. Forms Filed
18) Copies of Petition and Affidavits
(As many as the No. of the Respondents + 2) Filed

19. WRIT PETITION MISC. PETITION

(Filed for) Petition Court Fee Rs. /- Batta Rs. /- Notice Papers, Covers with
Postal Addresses and Ack. Forms Filed Proforma Draft Interim Order Filed
Signature of the Scrutiny Officer

Signature of the
Petitioner/P.I.P

IN THE HIGH COURT FOR THE STATE OF ANDHRA

PRADESH
AT AMARAVATHI

W.P. (P.I.L.) No. of 2023

RUNNING INDEX

Date of
Date of
Sl. Exhi filing of Page
Description of Docume
No. bits Docum No.
Document nt
ent
02.0 .20 02.08.2
1. Service Certificate 1
23 023
2. Court Fee -do- -do- 2
3. Writ Petition -do- -do- 3-4
4. Annexure I and II -do- -do- 5-9
Affidavit and Verification
5. -do- -do- 10-21
Statement
6. Annexure 5 -do- -do- 22-24
7. Annexure 6 -do- -do- 25-26
8. Annexure 7A -do- -do- 27-28
9. Annexure 8 -do- -do- 29-30
10. Annexure 10 -do- -do- 31-33
MATERIAL PAPERS
Copy of news report dated 03.07.20
11. P1 -do- 34-39
27.06.2020 23
 Copy of the Proceedings issued 11.11.20
12. P2 -do- 40-41
by the Respondent No.2 22
Copy of the Notification issued by 25.02.20
13. P3 -do- 42-43
the Respondent No.2 22
Copy of the Notification issued by 17.04.20
14. P4 -do- 44-45
the Respondent No.2 23
Copy of the Notification issued
vide
29.04.20 46
15. P5 Lr.Rc.No.14037/19/2021(7248716/
23
2023) K–SEC, Dated:29-4-2023 by
the Respondent No.3
Copy of Agenda by Respondent 26.06.20 47-51
16. P6 -do-
No.7 23
Copy of Proceedings issued by
Respondent No.3 vide 21.06.20
17. P7 52-53
Lr.Roc.No.1403719/2021/G Dated 22
21.06.2022
Copy of Memo issued by
Respondent No.2 vide Memo No. 13.05.202
18. P8 53-54
1456350/MA&UD/JD/2021 2
Dated 13.05.2022
Copy of Bank Details of the
19. P9 -do- 55
Petitioner
03.07.20
20. P10 Copy of Pancard of the Petitioner -do- 56
23
Copy of Aadhar Card of the 11.11.20
21. P11 -do- 57
Deponent 22

Place: Amaravati
Date: .09.2023
Petitioner/P.I.P

SERVICE CERTIFICATE
(PROOF OF SERVICE)

We have served the copies of Writ Petition, Affidavit,

Writ Petition Miscellaneous Petition(s) and Material
Papers on the other side Counsel/Government Pleader.
Place: Amaravati
Date: .09.2023 Petitioner / P.

I .. P
 IN THE HIGH COURT FOR THE STATE OF ANDHRA PRADESH AT
AMARAVATHI

W.P. (P.I.L.) No. of 2023

Between:

MANNAM SUDHEER KUMAR

…
Petitioner/Party in person

AND

THE STATE OF ANDHRA PRADESH AND OTHERS …

Respondents

COURT FEE

Place: Amaravati
Date: .09.2023 Petitioner / P.

I .. P
 MEMORANDUM OF WRIT PETITION
(FILED UNDER ARTICLE 226 OF
CONSTITUTION OF INDIA)

IN THE HIGH COURT FOR THE STATE OF

ANDHRA PRADESH AT AMARAVATHI

(SPECIAL ORIGINAL JURISDICTION)

W.P.(PIL) No. of 2020

Between :
Mannam Sudheer Kumar, S/o. Late M. M. Rao,
Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND
1. The State of Andhra
Pradesh, rep. by its
Chief Secretary,
Secretariat,Amaravathi-
522238.

2. The State of Andhra Pradesh,

rep. by its Special Chief
Secretary,MA & UD, Municipal
Department A P
Secretariat, Amaravathi-
522238.

3. The Commissioner & Director of Municipal Administration,

A.P. Vaddeswaram,
Mangalagiri-522502.

4. The State of Andhra Pradesh,

Represented by its Inspector General
Registrations & Stamps
KSR Park Road, Tadepalli,
Guntur, Andhra Pradesh–522501.

5. The District Collector,

Prakasam district-523001.

6. The Assistant Director,

 Survey & Land Records Department,
Prakasam Bhavan, Ongole,
Prakasam District, Andhra Pradesh–523001.

7. Smt. Gangada Sujatha,

Mayor, Ongole Municipal Corporation,
Ongole, Prakasam District-523001.

8. Shri. Gangineni Vasundhara, Managing Partner,

Sree Constructions, Tangutur, Prakasam Distrcit-523274.

9. U. Srinivas Rao, S/o. Not know,

R/o. Plot No.24, Bhagyanagar IV lane,
Ongole, Prakasam District-523001.

10. N. Chalapathi Rao, S/o. Not Know,

R/o. Plot No.64, Bhagyanagar IV lane,
Ongole, Prakasam District-523001.

.... Respondents

The address of the Petitioner/Party in Person for the purpose of

service of all summons, notices, process etc. is that M/s. M. Sudheer
Kumar, Editor–EENATIKALAM, O/o. Shop No.1, SCS Complex, Opp: ABM
Jr. College, Ongole-523001.

For the reasons stated in the accompanying affidavit, it is therefore

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.

It is respectfully 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.

1. Declaring the action of the respondent No.2 and 3 in allotting the land
to the 8,9,10th respondents to an extent of 345 and 445 gadis in Plot
No.122,123,124,168,177,137,132 in Sy.No.71 to 79, Mamidipalem,
Ongole, Praksam District as illegal, arbitrary and contrary to IDSMT
scheme.

2. Declaring the action of the Respondent No.2 & 3 in allotting the land to
the 8,9,10th respondents on nomination basis without calling for the
 notification or without issuing any auction for lesser price than the
actual value as illegal, arbitrary and consequently direct the
respondents to recover the loss caused to the Government Exchequer
by calculating the amount on par present value.

3. And consequently direct the 1Respondent to cause enquiry with regard

to the fraud taken place in allotting the land to the 8,9,and 10th
respondent for very lessor price than the market value and take
appropriate action against the persons involved in the scam and to
pass such other order or orders as this Honr'ble Court may deem fit
and proper in the interest of Justice.

AMARAVATHI
Date: .09.2023 Counsel for the
Petitioner
 Prakasam District

IN THE HIGH COURT OF

ANDHRA PRADESH
AT AMARAVATHI

W.P.PIL.No. OF 2023

WRIT (PIL) PETITION

Filed by:
Mannam Sudheer Kumar,
R/o. 51-1-62, Kabadipalem
Ongole, Prakasam District,
Andhra Pradesh–523001
Phone : 9703082882.
 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI
W.P.PIL.No. of 2023
Between:
Mannam Sudheer Kumar
……….Petitioner
AND
The State of Andhra Pradesh and 9 Others.
…….Respondents
LIST OF EVENTS
ANNEXURE-I

Sl. Date Description of the Events Page Para

No. No. in No. in
Affidavit Affidavi
t
1. The present PIL is filed aggrieved by the 11 Para – 1
action of the 2nd& 3rd respondent in allotting
the land to the 8th respondent to an extent of
29,155 Sq.ft (or) 345.3875 Gadis in Sy. No. 71,
72, 73, 74, 75, 76, 77, 79/1,2,3 Plot No.132,
mamidipalem, Ongole City, Prakasam District
Commercial Plot for a reserve price of
Rs.3,16,00,000/-(Rupees Three crores and
sixteen Lakhs Only) as per the market rates in
the year 2007 which tune to a loss of fifteen
crores to government as per current land
rates without issuing any notification or
without inviting bids from prospective bidders
is illegal, arbitrary and violates natural justice.
The Petitioner is working as editor of 11 to 12 Para –
eenatikalam monthly magazine, social 2.I
worker and is very active in society in
bringing the burning issues in front of
public was elected best Social worker
award by Hope foundation in the year
2016.
3. 3that I am not involved in any Civil and
Revenue cases but I have been implicated
into several criminal and defamation
Cases due to political vendetta by the
powers that be as a retaliatory action for
my fight against injustice and corruption
which got rooted in society that the
Petitioner is Editor of Eenatikalam Monthly
Magazine / Social worker and permanent
resident of H.No.51-1-62, Kabadipalem,
Ongole Prakasam District 523001, Andhra
 Pradesh State. He is challenging the
action of the 2 respondent in allotting land
to the 8 respondent to an extent of 29,155
Sq.ft (or) 345.3875 Gadis at
Sy.No.71,72,73,74,75,76,77,79/1,2,3 Plot
No. 132, mamidipalem Ongole city,
prakasam district Commercial Plot for a
reserve price of Rs 3,16,00,000/-(Rupees
Three crores and sixteen Lakhs Only) as
per the market rates in the year 2007
IDSMT Scheme published on 22.10.2007
on behalf of Municipal corporation which
tune to a loss of fifteen crores to
government as per current land rates
without issuing any notification or without
inviting bids from prospective bidders is
illegal, arbitrary and violates natural
justice on nomination basis: without
issuing any notification or without inviting
bids from qualified bidders and without
following the due process of law letter
issued by the 2nd
Memo.No.1456350/32/2021 dated
17/04/2023 & L.r.Roc.No.14037/19/2021
dt.29/04/2023 in relation to fixation of
price as per 2007 rates which causes
more than 15 crores loss to the Public
Exchequer as illegal, arbitrary.
4. That thorough research has been 14 3.I
conducted in the matter raised through
the Petition. All the relevant documents
pertinent to the subject as discovered by
the Petitioner is annexed to the petition.
5. That the Petitioner never filed any case
much less Public Interest Litigation in any
other court with regard to the same
subject.
6. that the L.P.No.30/88, IDSMT. Mamdipal, 16 4.III
Ongole, Prakasam District dated
22.10.2007 was issued intending to
develop an area of Ac.33.24 land in
Sy.No.71,72,73,74,75,76,77,79/1,2,3 83/1
of mamdipalem, Ongole city, Praksam
district as a Integrated Township with
basic amenities on as is where is basis
suitable for mixed used development, is
offered for sale to all general public in
different plots sizes, among them, Plot
No.122,123,124,168,177 and 137 along
with 132 was allotted on price fixation and
 bidders has placed bid in the respective
plots but did not paid all the balance
amounts and get it registered at that time
of auction. It is to submit that to utter
shock and surprise after 15 years the 2nd
& 3rd respondents has given allotment of
land to 8,9,10th respondents on
nomination agenda basis passes by
council headed by 7th respondent without
issuing any notification or without inviting
bids from qualified purchasers is illegal.
7. that Without taking into the purpose and 17 `4.IV
object of the said IDSMT scheme 2nd and
3rd respondent unilaterally and
intentionally allotted the land to the
8,9,10th respondents for commercial
activities but not for any other purpose.
8. that a perusal of the letter memo 18 4.VII
No.130411/12/2021 dt.25/02/2022 and
memo No.1456350/12/2021 dt.11/11/2022
and memo No.1256350/J2/2021
dt.17/04.2023 addressed by the 2nd and
3rd respondent to the 8,9,10 th Respondents
informing that the 2 & 3 rd respondent sold
an extent of 345 gadis and other plots
which tune to 445 gadis of land is clear
violation of the said scheme.
9. that the other irregularity in relation to the 18 4.VIII
allotment of land of the 8,9,10th
respondent in the same survey number for
old fixation price by 2 & 3 rd respondents
for a price of Rs.9754.77 /one sq.yard but
as per government existing land value per
square yard is Rs.22000/- per square yard
and market value is Rs.70,000/- per
square yard which tune a huge loss to
government. I respectfully submit the 1st
Respondent who is the supervisory
authority in implementing the government
schemes and Policies has failed in the
instant case by closing his eyes. Taking
advantage of the same, the other official
Respondents causes huge loss of more
than 15 crores to the Public Exchequer.
10. The information furnished by me in the 18 5
Petition has been gathered from various
sources that have been hosted on the
website and various Government
Departments and other sources including
under RTI and therefore I believe it to be
 true.
11. If the respondents not recover the loss 18 6
from the 8,9 and 10th respondent the
same would cause great hardship to
government revenue of more than 15
crores loss to the public exchequer.
12. The Petitioner approached the 18 7
Respondents personally on severally
occasions and made oral request with
regard to the subject matter.
13. On account of the New Rules that have 19 8
been notified and brought, we have been
advised that a new format of Writ Petition
is required to be filed and that for the
compliance of the new rules, there could
be some time that may be taken by the
Registry of this Honorable Court.
Therefore, in the event of this Honorable
Court coming to a conclusion that there is
any delay in approaching this Honorable
Court, the same may be condoned
14.

Respondentz
informing that the2 & 3rd
respondent sold an
extent of 345 gadis and other plots which
tune to 445 gadis of land is clear violation of
the said scheme.
一

Page 1
a) Memo.Lr.No 1456350/J2/2021,
dt.11.11.2022.
b)Memo.Lr.No 130411/J2/2021,
dt.25.02.2022.
c) Memo.Lr.No 1456350/J2/2021,
dt.17.04.2023.
d) Proceedings of Lr.No 14037/19/2021,
dt.29.04.2022.
e) Agenda Notice by Mayor,OMC,Ongole,
dt.26.06.2023.
f) paper cutting from Andhra jyothi and
eenatikalam drt.03.07.27
g) R.T.I application dt.27.05.2023
i. the action of the respondent No.2 and 3
in allotting the land to the 8,9,10th
respondents to an extent of 345 and 445
gadis in Plot
No.122,123,124,168,177,137,132 in
Sy,No.71 to 79,Mamidipalem,Ongole
Praksam District as illegal, arbitrary and
contrary to IDSMT scheme.
ii.
declaring the action of the Respondent
No.2 & 3 in allotting the land to the
8,9,10th respondents on nomination basis
without calling for the notification or
without issuing any auction for lesser
price than the actual value as illegal,
arbitrary andconsequently direct the
respondents to recover the loss caused to
the Government Exchequer by calculating
the amount on par present value.
iii. and consequently direct the 1st
Respondent to cause enquiry with regard
to the fraudtaken place in allotting the
land to the 8,9,and 10th respondent for
very lessor price than the market value
and take appropriate action against the
persons involved in the scam;and to pass
such other order or orders as this Hon'ble
Court may deem fit and proper inthe interest
of Justice.0
ANNEXURE-I
Under Article 226 of Constitution of India
23

1. PARTICULARS OF THE CAUSE/ORDER AGAINST WHICH THE

PETITIO N IS MADE:

SUBJECT MATTER IN BRIEF:

The present PIL is filed aggrieved by the action of the 2 nd & 3rd

respondent in allotting the land to the 8 th respondent to an extent of

29,155 Sq.ft (or) 345.3875 Gadis in Sy,No.71,72,73,74,75,76,77,79/1,2,3

Plot No. 132, mamidipalem ,ongole city, praksam district Commercial Plot

for a reserve price of Rs.3,16,00,000/-(Rupees Three crores and sixteen

Lakhs Only) as per the market rates in the year 2007 which tune to a loss

of fifteen crores to government as per current land rates without issuing

any notification or without inviting bids from prospective bidders is

illegal, arbitrary and violates natural justice.

2. PARTICULARS OF THE PETITIONER

The Petitioner is working as editor of eenatikalam monthly

magazine , social worker and is very active in society in bringing the

burning issues in front of public , was elected best Social worker award

by Hope foundation in the year 2016. I feel that it is bounden duty to

protect the interest of public in protecting the resources of the state. I

am pained by the unilateral actions of the official Respondent in

benefitting certain individuals and firms at the cost of public exchequer

violating the spirit of the above government regulations with a vested

interest. As editor/ Social worker, I have approached the Concern

authorities including Distrcit Collector ,Praksam District, against the

action of the Respondents in violating the rules and deviating basic

purpose for which notification was issued in the year 2007. My

persuasion not to allow loss of revenue to government exchequer in

different forums, including print and electronic media, went unheeded

by the government. It is pertinent to note that several attempts were

made to stifle my fight against this violation of laws and illegal decisions

of respondents. Despite these unabated attempts by the vested

interests, I continue to raise my voice against this injustice. As editor

and social worker, I strive to protect public interest and safeguard the

interest of society by taking up issues with the government to ensure

that good governance is guaranteed to the people.

I submit that despite repeated attempts to reason with the

concerned authorities and powers that be, I could not get any solace

and, hence, constrained to approach this highest court seeking justice

based on the principles of constitutional rule, rule of law, equality before

law and equal opportunities to citizens.

2. I further submit that I am not involved in any Civil and Revenue

cases but I have been implicated into several criminal and defamation

Cases due to political vendetta by the powers that be as a retaliatory

action for my fight against injustice and corruption.

LOCUS STANDI:-

It is submitted that the Petitioner is

Editor of Eenatikalam Monthly

Magazine / Social worker and permanent resident of H.No.51-1-

62,kabadi palem,ongole ,Prakam Distrcit – 523001, AndhraPradesh

State. He is challenging the action of the 2 nd respondent in allotting land

to the 8th respondent to an extent of 29,155 Sq.ft (or) 345.3875 Gadis

at Sy,No.71,72,73,74,75,76,77,79/1,2,3 Plot No. 132,

mamidipalem ,ongole city, praksam district Commercial Plot for a

reserve price of Rs.3,16,00,000/-(Rupees Three crores and sixteen Lakhs

Only) as per the market rates in the year 2007 IDSMT Scheme published

on 22.10.2007 on behalf of Municipal corporation which tune to a loss of

fifteen crores to government as per current land rates without issuing

any notification or without inviting bids from prospective bidders is

illegal, arbitrary and violates natural justice on nomination basis without

issuing any notification or without inviting bids from qualified bidders

and without following the due process of law letter issued by the 2nd and

3rd respondent vide Memo.No.1456350/J2/2021 dated 17/04/2023 &

L.r.Roc.No.14037/19/2021 dt.29/04/2023 in relation to fixation of price

as per 2007 rates which causes more than 15 crores loss to the Public

Exchequer as illegal, arbitrary. The Petitioner as Editor/Social worker is

trying to eradicate such illegal acts done by the Govt. functionaries who

are hand in glove with the private respondents as such, is having locus

standi to file this present Writ Petition by way of Public Interest

Litigation.
3. DECLARATION AND UNDERSTANDING OF THE PETITIONER

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34

years, Occ: Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole

– 523001,Andhra Pradesh State., do hereby solemnly affirm and

sincerely state as follows:-

3.1. That the present Petition is being filed by way of Public Interest

Litigation and the Petitioner does not have any personal interest in the

matter. This Petition is being filed in the larger interest of the society

within the jurisdiction the Respondents herein.

That the entire costs of litigation including batta ,fees or misc expenses

are borne by the petitioner. The PAN number of the petitioner is

CERPM0001E and AadharNo.421242073100.

That thorough research has been conducted in the matter raised through

the Petition. All the relevant documents pertinent to the subject as

discovered by the Petitioner is annexed to the petition.

That to the best of Petitioner's knowledge and research, the issue raised

was not decided and that a similar or identical petition was not filed

earlier by us.

That the Petitioner understood that in the course of hearing of this

petition the court may require any security to be furnished towards costs

or any other charges and the petitioner shall comply with such

requirements.
That the Petitioner never filed any case much less Public Interest

Litigation in any other court with regard to the same subject.

4) FACTS IN BRIEF:

The Petitioner submits that the present Public Interest

Litigation is filed aggrieved by the action of the 2nd & 3rd

respondent in allotting the land to the 8th respondent to an

extent of 29,155 Sq.ft (or) 345.3875 Gadis and to 9 and 10 th

respondents for an extent of 445 gadis in

Sy,No.71,72,73,74,75,76,77,79/1,2,3 Plot No. 132,

mamidipalem ,ongole city, praksam district Commercial Plot for a

reserve price of Rs.3,16,00,000/-(Rupees Three crores and sixteen

Lakhs Only) as per the market rates in the year 2008 which tune

to a loss of fifteen crores to government as per current land rates

without issuing any notification or without inviting bids from

prospective bidders is illegal, arbitrary and violates natural

justice.

I respectfully submit that I am the editor of eenatikalam monthly

magazine , social worker and is very active in society in bringing the

burning issues in front of public , and was elected as best Social worker

award by Hope foundation in the year 2016. I feel that it is bounden

duty to protect the interest of public in protecting the resources of the

state. I am pained by the unilateral actions of the official Respondent in

benefitting certain individuals and firms at the cost of public exchequer

violating the spirit of the above government regulations with a vested

interest. As editor/ Social worker, I have approached the Concern

authorities including Distrcit Collector ,Praksam District, against the

action of the Respondents in violating the rules and deviating basic

purpose for which notification was issued in the year 2007. My

persuasion not to allow loss of revenue to government exchequer in

different forums, including print and electronic media, went unheeded

by the government. It is pertinent to note that several attempts were

made to stifle my fight against this violation of laws and illegal decisions

of respondents. Despite these unabated attempts by the vested

interests, I continue to raise my voice against this injustice. As editor

and social worker, I strive to protect public interest and safeguard the

interest of society by taking up issues with the government to ensure

that good governance is guaranteed to the people.

I respectfully submit that in order to promote Housing to weaker

middle class section the central government along with sate

government has proposed IDSMT (Integrated development of

small and medium towns) and issued a notification in the year

2007 dated 22.10.2007 to 24.10.2007 and auctioned various plot

in the above survey number through bidding/auction. Thereafter

the 5th respondent divided the said land into different sizes of plots

and invited tenders for most of the plots by way of different

notifications in the year 2007 onwards and upon success full

payments the 5th respondents has allotted to bidders in the year

2007.
 I respectfully submit that the L.P.No.30/88,

IDSMT,Mamdipalem ,Ongole, Praksam Distrcit dated22.10.2007

was issued intending to develop an area of Ac.33.24 land in

Sy.No.71,72,73,74,75,76,77,79/1,2,3 83/1 of mamdipalem,Ongole

city,Praksam distrcit as a Integrated Township with basic aminites

on ‘as is where is basis’ suitable for mixed used development, is

offered for sale to all general public in different plots sizes,

among them, P l o t N o . 1 2 2 , 1 2 3 , 1 2 4 , 1 6 8 , 1 7 7 a n d 1 3 7

a l o n g w i t h 1 3 2 was allotted on price fixation and bidders has

placed bid in the respective plots but didi not paid all the balance

amounts and get it registered at that time of auction. It is to

submit that to utter shock and surprise after 15 years the 2 nd & 3rd

respondents has given allotment of land to 8,9,10 th respondents

on nomination agenda basis passes by council headed by 7 th

respondent without issuing any notification or without inviting bids

from qualified purchasers is illegal.

it is to submitted that Without taking into the purpose and

object of the said IDSMT scheme 2 nd and 3rd respondent

unilaterally and intentionally allotted the land to the 8,9,10th

respondents for commercial activities but not for any other

purpose.

I respectfully submit that the major irregularity and the

conspiracy between the 2rd and 3th respondents can be seen in the

manner in which the land was allotted to the 8,9,10th respondents.

 The 2nd and 3rd respondent didinot issued notification not fine or

any other to the above allotted bidders .

The 2nd and 3rd respondent initially allotted p[lots

no.122,123,124,168,177 & 137 to the 9 and 10 th respondents and there

after basing on the request of the 8 th respondent the land in Plot No.132

to an extent of 345.745 gadis was reserved by accepting the same

condition in the year 2007 scheme. The said action is highly illegal and I

have reliably learnt that as perusal of the above said transaction it is

clear that the 2nd and 3rd respondents colluded with 8,9,10th respondents

and are causing huge loss to the Public Exchequer.

I respectfully submit that, I have asked the earlier cancellation

proceedings which were passed on 21.06.202014 video R.O.C

No.17276/1999 through RTI application dated 27/05/2023 but not yet

received credible information on the above proceedings.

I respectfully submit that a perusal of the letter memo

No.130411/12/2021 dt.25/02/2022 and memo No.1456350/12/2021

dt.11/11/2022 and memo No.1256350/J2/2021 dt.17/04.2023 addressed

by the 2nd and 3rd respondent to the 8,9,10th Respondentz informing that

the 2 & 3rd respondent sold an extent of 345 gadis and other plots

which tune to 445 gadis of land is clear violation of the said scheme.

I respectfully submit that the other irregularity in relation to the

allotment of land to the 8,9,10th respondent in the same survey number

for old fixation price by 2 & 3 rd respondents for a price of Rs.9754.77

/one sq.yard but as per governemt existing land value per square yar is

Rs.22000/- per square yard and market value is Rs.70,000/- per syare

yard which tune a huge loss to government. I respectfully submit the 1st

Respondent who is the supervisory authority in implementing the

government schemes and Policies has failed in the instant case by

closing his eyes. Taking advantage of the same, the other official

Respondents causes huge loss of more than 15 crores to the Public

Exchequer.

5. Source of Information: The information furnished by me in the

Petition has been gathered from various sources that have been hosted
on the website and various Government Departments and other sources
including under RTI and therefore I believe it to be true.

6. Nature and extent of injury caused/apprehended : If the

respondents not recover the loss from the 8,9 and 10 th respondent the
same would cause great hardship to government revenue of more than
15 crores loss to the public exchequer.
7. Any Representation made: The Petitioner approached the
Respondents personally on severally occasions and made oral request
with regard to the subject matter.

8. Delay, if any: On account of the New Rules that have been

notified and brought, we have been advised that a new format of Writ
Petition is required to be filed and that for the compliance of the new
rules, there could be some time that may be taken by the Registry of
this Honorable Court. Therefore, in

the event of this Honorable Court coming to a conclusion that there is

any delay in approaching this Honorable Court, the same may be
condoned.
 9. Documents relied upon:

a) Memo. Lr.No 1456350/J2/2021, dt.11.11.2022.

b) Memo. Lr.No 130411/J2/2021, dt.25.02.2022.
c) Memo. Lr.No 1456350/J2/2021, dt.17.04.2023.
d) Proceedings of Lr.No 14037/19/2021, dt.29.04.2022.
e) Agenda Notice by Mayor,OMC, Ongole, dt.26.06.2023.

10. MAIN RELIEF PRAYER IS AS FOLLOWS:

It is respectfully 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

i. declaring the action of the respondent No.2 and 3 in allotting the land
to the 8,9,10th respondents to an extent of 345 and 445 gadis in Plot
No.122,123,124,168,177,137,132 in Sy,No.71 to
79,Mamidipalem,Ongole Praksam District as illegal, arbitrary and
contrary to IDSMT scheme.

ii. declaring the action of the Respondent No.2 & 3 in allotting the land
to the 8,9,10th respondents on nomination basis without calling for
the notification or without issuing any auction for lesser price than
the actual value as illegal, arbitrary and consequently direct the
respondents to recover the loss caused to the Government
Exchequer by calculating the amount on par present value.
iii. and consequently direct the 1 stRespondent to cause enquiry with
regard to the fraud taken place in allotting the land to the 8,9,and
10th respondent for very lessor price than the market value and take
appropriate action against the persons involved in the scam;and to
pass such other order or orders as this Hon’ble Court may deem fit and
proper in the interest of Justice.

11. Interim order prayed for:

It is further prayed that pending disposal of the above Writ

Petition, it is respectfully prayed that this Hon’ble Court may be pleased
to direct the 8,9,10th Respondent not to carry any activities in the land
allotted pending disposal of the Writ Petition and pass such other order
or orders as this Hon’ble Court may deem fit and proper in the
circumstances of the case.

12. Caveat: It is submitted that no notice has been received of

lodging a caveat by the Respondents.

13. I submit that, I had no faced Contempt of Court proceedings under

the Contempt of Courts Act, 1971.

14. I have not been ordered by the Honorable High Court or any other
court not to file Public Interest Litigation cases.

15. I submit that, I am not involved in a Civil, Criminal and Revenue

cases which have any nexus with present Public Interest Litigation.

16. I hereby solemnly state under oath affirm and declare that the writ
petition is being instituted purely in public Interest and not at the
instance of any other person or organization other than the petitioner.

17. I hereby solemnly state on oath and affirm and declare that the
question raised in the Writ Petition has not been raised or agitated
earlier and that there are no other case(s) or Petition(s) filed or that are
pending before this Hon’ble Court or any other forum or court to the
best of my knowledge and, research and belief.

At Amaravathi DEPONENT

VERIFICATION
I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years, Occ:
Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole – 523001,Andhra
Pradesh State.,being the Petitioner/Party in person acquainted with the facts of
the case, do hereby declare that the contents of paras 1 to 17

are true and correct to the best of my knowledge and belief with I believe
to be true and correct.

Hence verified the same on this the day of July 2023 at Amaravathi.
ADVOCATE

DEPONENT

MEMORANDUM OF WRIT PETITION

(FILED UNDER ARTICLE 226 OF
CONSTITUTION OF INDIA)

IN THE HIGH COURT FOR THE STATE OF

ANDHRA PRADESH AT AMARAVATHI

(SPECIAL ORIGINAL JURISDICTION)

W.P.(PIL) No. of 2020

Between :
Mannam Sudheer Kumar, S/o. Late M. M. Rao,
Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND
1. The State of Andhra pradesh, rep.by its Chief Secretary,
Secretariat,Amaravathi-522238.

2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal

Corporation,
Praksam district-523001.
6. The Town Surveyor, Ongole Municipal
Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.
 8. Shri.Gangineni Vasundhra,Manging patner,
Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-
523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-
523001.

....Respond
ents
The address of the Petitioner/Party In Person for the purpose of
service of all summons, notices, process etc. is that M/s. M.Sudheer
Kumar,Editor-EENATIKALAM, , O/o.Shop No.1, SCS Complex,Opp ABM
jR college,Ongole– 523001.

For the reasons stated in the accompanying affidavit, it is therefore

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

It is respectfully 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

1. declaring the action of the respondent No.2 and 3 in allotting the

land to the 8,9,10th respondents to an extent of 345 and 445
gadis in Plot No.122,123,124,168,177,137,132 in Sy,No.71 to
79,Mamidipalem,Ongole Praksam District as illegal, arbitrary and
contrary to IDSMT scheme.

2. declaring the action of the Respondent No.2 & 3 in allotting the

land to the 8,9,10th respondents on nomination basis without
calling for the notification or without issuing any auction for lesser
price than the actual value as illegal, arbitrary and consequently
direct the respondents to recover the loss caused to the
Government Exchequer by calculating the amount on par present
 value.
3. and consequently direct the 1 stRespondent to cause enquiry with
regard to the fraud taken place in allotting the land to the 8,9,and
10th respondent for very lessor price than the market value and
take appropriate action against the persons involved in the
scam;and to pass such other order or orders as this Hon’ble Court may
deem fit and proper in the interest of Justice.

HYDERABAD.

Date : .08.2018 Counsel for the

Petitioner

ANNEXURE – 5

HIGH COURT OF JUDICATURE FOR THE SATE OF ANDHRA

PRADESH

W.P. (P.I.L.) No. Of 2023

BETWEEN :
Between :
Mannam Sudheer Kumar, S/o. Late M. M. Rao,
Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND
1. The State of Andhra pradesh, rep.by its Chief Secretary,
Secretariat,Amaravathi-522238.

2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal

Corporation,
Praksam district-523001.
6. The Town Surveyor, Ongole Municipal
Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.

8. Shri.Gangineni Vasundhra,Manging patner,

Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-
523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-
523001.

....Respond
ents

AFFIDAVIT FILED UNDER RULE 5 OF PIL RULES 2015

 I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34
years, Occ: Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole
– 523001,Andhra Pradesh., do hereby solemnly affirm and state on oath
as follows:

1. I am the petitioner herein and as such I am well acquainted with

the facts of the case.

2. I state that my Aadhar number, Bank Account, and my address

and all particulars furnished in the above cause title is true and correct.

3. I am herewith annexing copies of my Aadhar card, towards my

indemnity and address proof as required under Rule 5 (b) of the PIL
Rules 2015.

4. I submit that, I did not face Contempt of Court proceedings under

the Contempt of Courts Act, 1971.

5. I has not been ordered by this Hon’ble Court or any other court
not to file Public Interest Litigation cases.

6. I submit that I has not involved in a Civil, Criminal and Revenue

Cases but I have been implicated into several criminal cases due to
political reasons, which are not connected to this PIL, which has a nexus
with present W.P.(PIL).

7. I am a party in pending civil or criminal cases that has a nexus

with the subject matter of the above Writ Petition, filed.

Sworn and signed before me

On this the day of july, 2023
At Amaravathi

DEPONENT/P.I.P
 ADVOCATE :: Hyderabad

VERIFICATION STATEMENT

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34

years, Occ: Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole
– 523001,Andhra Pradesh, do hereby solemnly affirm and sincerely state
that what are stated in the paragraphs are true to our own

knowledge and belief and what is stated in the paragraphs are based on
the information and legal advice which I believe to be true and correct.

Hence verified the same on this the day of July, 2023 at

Hyderabad.

ADVOCATE DEPONENT

ANNEXURE 6

HIGH COURT OF JUDICATURE FOR THE SATE OF ANDHRA

PRADESH

W.P. (P.I.L.) No. Of 2023

BETWEEN :

Mannam Sudheer Kumar, S/o. Late M. M. Rao,

Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND

1. The State of Andhra pradesh, rep.by its Chief Secretary,

Secretariat,Amaravathi-522238.

2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
 3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal Corporation,

Praksam district-523001.
6. The Town Surveyor, Ongole Municipal Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.

8. Shri.Gangineni Vasundhra,Manging patner,

Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-523001.

....Responde
nts
DECLARATION FILED UNDER RULE 6 OF PIL RULES
2015

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years, Occ:

Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole – 523001,Andhra

Pradesh, do hereby solemnly affirm and state on oath and declare that the Writ

Petition is being instituted purely in Public Interest and not at the instance of any

other person or organization other than the petitioner.

Hence, verified at Hyderabad on this the day of July, 2023.

DEPONENT/P.I.P

ANNEXURE-7A
HIGH COURT OF JUDICATURE FOR THE SATE OF ANDHRA
PRADESH

W.P. (P.I.L.) No. Of 2023

BETWEEN :

Mannam Sudheer Kumar, S/o. Late M. M. Rao,

Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND

1. The State of Andhra pradesh, rep.by its Chief Secretary,

Secretariat,Amaravathi-522238.

2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal Corporation,

Praksam district-523001.
6. The Town Surveyor, Ongole Municipal Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.

8. Shri.Gangineni Vasundhra,Manging patner,

Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-523001.

....Responde
nts
AFFIDAVIT FILED UNDER RULE 7 A OF WRIT PROCEEDINGS

RULES

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years,

Occ: Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole –

523001,Andhra Pradesh, do hereby solemnly affirm and state on oath as

follows:
1. “I hereby affirm and state on oath that the petitioner herein have no

personal interest in the subject matter of the petition. The petitioner

hereby undertake to pay exemplary costs and / or compensatory

damages as directed by this court in the event of a contrary finding

upon adjudication by the court that the Writ petition is filed for

extraneous / personal considerations or with an oblique motive”.

Solemnly and sincerely

affirm this the day of
July, 2023
and signed his name in my presence. DEPONENT

ADVOCATE :: Amaravathi

VERIFICATION

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years, Occ:

Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole – 523001,Andhra

Pradesh, being the Petitioner/person acquainted with the facts of the

case, do hereby declare that the contents of paras are true and correct

to the best of my knowledge and belief and legal advice tendered by my

counsel with I believe to be true and correct.

Hence verified the same on this the day of july 2023 at

Amaravathi.

ADVOCATE

DEPONENT
 ANNEXURE 8
HIGH COURT OF JUDICATURE FOR THE SATE OF ANDHRA
PRADESH

W.P. (P.I.L.) No. Of 2023

BETWEEN :

Mannam Sudheer Kumar, S/o. Late M. M. Rao,

Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND

1. The State of Andhra pradesh, rep.by its Chief Secretary,

Secretariat,Amaravathi-522238.
 2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal Corporation,

Praksam district-523001.
6. The Town Surveyor, Ongole Municipal Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.

8. Shri.Gangineni Vasundhra,Manging patner,

Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-523001.

....Responde
nts

DECLARATION FILED UNDER 8 OF PIL RULES 2015

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years, Occ:
Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole – 523001,., do hereby
solemnly and sincerely affirm and state on oath and affirm and declare that the
questions raised in the writ petition has not been raised are agitated earlier and
there are no other case(s) or petition(s) filed or that are pending before this
Hon’ble Court or any other form or court to the best of our knowledge, research
and belief.

Hence, Verified at Hyderabad on this the day of August, 2018.

ADVOCATE

DEPONENT
ANNEXURE 10
 HIGH COURT OF JUDICATURE FOR THE SATE OF ANDHRA
PRADESH

W.P. (P.I.L.) No. Of 2023

BETWEEN :

Mannam Sudheer Kumar, S/o. Late M. M. Rao,

Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND

1. The State of Andhra pradesh, rep.by its Chief Secretary,

Secretariat,Amaravathi-522238.

2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal Corporation,

Praksam district-523001.
6. The Town Surveyor, Ongole Municipal Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.

8. Shri.Gangineni Vasundhra,Manging patner,

Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-523001.

....Responde
nts

AFFIDAVIT FILED UNDER 10 OF PIL RULES 2015

I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years, Occ:
Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole – 523001,., do hereby
solemnly and sincerely affirm and state on oath and affirm and declare that the
questions raised in the writ petition has not been raised are agitated earlier and
there are no other case(s) or petition(s) filed or that are pending before this
Hon’ble Court or any other form or court to the best of our knowledge, research
and belief.

1. I state that I have no personal gain or private oblique motive in

filing the above writ petition/P.I.L.

2. I, hereby undertake to pay exemplary costs and / or compensatory

damages as directed by this court in the event of a contrary finding
upon adjudication by the court that the Writ Petition is filed for
extraneous / personal considerations or with an oblique motive.

3. I submit that all the information based on which the writ petition
has been filed based on personal research and contacting the aggrieved
persons. I undertake to furnish any additional information as may be
directed by the Hon’ble Court.

4. I undertake that if I seek permission to withdraw the above writ

petition or if I do not attend the hearing of the case either by myself or
my advocate, I shall bear the costs incurred by the respondents and any
such additional costs as may be imposed in the discretion of this Hon’ble
Court.

5. I undertake that in the event of I wish to withdraw the above writ

petition after the same is admitted, I shall do so only by filing an
appropriate petition and not by any other method except with the leave
of this Hon’ble Court.

Solemnly and sincerely

affirm this
the day of
July, 2023
and signed his name in my presence.

DEPONENT/P.I.P
 ADVOCATE ::

Hyderabad

VERIFICATION

I, I, Mannam Sudheer Kumar S/o. Late M.M.Rao, Aged about 34 years, Occ:
Editor /Social worker R/o. H.No.51-1-62,Kabadipalem,ongole – 523001,., Andhra

Pradesh State., being the Petitioner/person acquainted with the facts of

the case, do hereby declare that the contents of paras 1 to 5 are true
and correct to the best of my knowledge and belief and legal advice
tendered by my counsel with I believe to be true and correct.

Hence verified the same on this the day of July, 2023 at

Hyderabad.

ADVOCATE

DEPONENT

MEMORANDUM OF WRIT PETITION MISC.

PETITION (UNDER SEC. 151 OF THE
C.P.C.)

IN THE HIGH COURT FOR THE STATE OF

ANDHRA PRADESH AT AMARAVATHI

W.P.(PIL) No. of 2020

Between :
Mannam Sudheer Kumar, S/o. Late M. M. Rao,
Aged about 34years, Occ: Editor-eenatikalam
magazine/Socialworker,
R/o. 51-1-62,Kabadipalem, Ongole, Praksam District,
Andhra Pradesh-523001.

AND
1. The State of Andhra pradesh, rep.by its Chief Secretary,
Secretariat,Amaravathi-522238.

2. The State of Andhra Pradesh, rep. by its Special Chief Secretary,MA & UD,
Municipal Department A P Secretariat, Amaravathi-522238.
3. The Commissioner & Director of Municipal Administration, AP
Vaddeswaram,Mangalagiri-522502.
4. The Distrcit Collector,
Praksam district-523001

5. The Commissioner, Ongole Municipal

Corporation,
Praksam district-523001.
6. The Town Surveyor, Ongole Municipal
Corporation,
Praksam district-523001.

7. Smt.Gangada Sujatha,
Mayor, Ongole Muncipal Corporation,
Ongole,Praksam District-523001.

8. Shri.Gangineni Vasundhra,Manging patner,

Sree Constructions,Tangutur,Praksam Distrcit-523274.

9. U.Srinivas rao S/o. Not know,

R/o.Plot No.24,Bhagyanagar IV lane, Ongole,Praksam district-
523001.

10. N.Chalapathi Rao S/o.Not Know,

R/o.Plot No.64,Bhagyanagar IV lane,Ongole,Praksam district-
523001.

....Respond
ents

For the reasons stated in the accompanying this affidavit, it

is therefore prayed that this Hon’ble High Court may be pleased to direct
declaring the action of the respondent No.2 and 3 in allotting the
land to the 8,9,10th respondents to an extent of 345 and 445
gadis in Plot No.122,123,124,168,177,137,132 in Sy,No.71 to
79,Mamidipalem,Ongole Praksam District as illegal, arbitrary and
contrary to IDSMT scheme.
a) declaring the action of the Respondent No.2 & 3 in allotting the land
to the 8,9,10th respondents on nomination basis without calling for the
notification or without issuing any auction for lesser price than the actual
value as illegal, arbitrary and consequently direct the respondents to
recover the loss caused to the Government Exchequer by calculating the
amount on par present value.

b) and consequently direct the 1stRespondent to cause enquiry with

regard to the fraud taken place in allotting the land to the 8,9,and 10 th
respondent for very lessor price than the market value and take
appropriate action against the persons involved in the scam;and to pass
such other order or orders as this Hon’ble Court may deem fit and proper in the
interest of Justice.

AMARAVATHI

Dated: .07.2023

Petitioner/P.I.P