Under instructions from my father sri kada satyanarayana, s/o. Late saheb of indrapalem, Door. 7-69. Kakinada Rural Mandal, East Godavari district, kakinada, andhra pradesh, I issue this notice to you as follows:
1. My father purchased a lorry bearing No. AP 05y 9698 on loan sanctioned by No.2 in the year
2005. My father cleared of the said loan by way of installments. While so, the said lorry
Developed mechanical trouble and transportations of material is hampered and business is
Badly Affected. My father thought over to purchase brand new lorry and again my father
borrowed Loan of RS.2, 95, 000/-from No. 2. on his lorry bearing No. AP 05y 9698, Contract
No. AKAA03128, and has been paying installments regularly.
2. Accordingly my father purchased a brand New lorry AP 05TU 9294, Contract No.
AKAA03071, Ashok Leyland make and carrying on his business on the said two Lorries of
Ashok Leyland make
3. While so, my lorry AP 05TU 9294, met with motor accident. In addition my father lorry
AP 05y 9698 developed mechanical trouble and is getting repairs in garage shed. Due to
that reason my father could not payment installments for the months of March, june and
july and the said fact is intimated to No.2 .
4. In the mean time No.2 deputed that staff agent Govindu and branch manager Koteswara Rao
seizure of the said lorry AP 05y 9698. my father requested them duly informing difficulties
my father is facing. But they did not heed and bent upon for seizure and keeping watch on said
lorry .in this regard my father sustained heavy loss at Rs.3, 000/- and more a day. Ultimately
the said Govindu and Koteswara Rao seized the said lorry AP 05y 9698 with out seizing
order and took it away to the office of No.2.
5. On 30-03 the said Govindu and Koteswara Rao as well as No.2 called upon my father
to come and attend No.2. Accordingly my father attended to the office No.2 where No.3 is
also present. No.2 and 3 as well as the said Govindu and Koteswara Rao Colluded together a
sale deed was drafted for the sale of the lorry No. AP 05y 9698 for Rs. 6, 85, 000/- in favour
of No.3 with view to cause wrongful lose to my father and to have wrongful gain for No.3. An
amount of Rs. 1, 85, 000/- only was paid to my father and promised to pay the balance amount
of Rs. 5, 00, 000/- in the date of 20-04. But not paid the balance amount till now. No.2
office did neither arrange the payment of balance amount of Rs. 5, 00, 000/-nor did No.2
arrange to return back the said lorry AP 05y 9698 to me till now which is quite illegal and
against the principles of natural justice.
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