HIGH COURT of JUDICATURE at HYDERABAD for the State of Telangana and the State of Andhra Pradesh

Bar&Bench (www.barandbench.com)

HIGH COURT OF JUDICATURE AT HYDERABAD For the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015)

W.P. (P.I.L.) No. of 2018

Between:

Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy Hindu, Aged about 50years, Occ: Member of Legislative Assembly, Telangana, R/o.Plot No.854-P, Road No.44, Jubilee Hills Hyderabad – 500 033, Telangana State. [email protected] Aadhar No. 901131447395 PAN No. ABYPA0449G …Petitioner

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana State Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Ranga Reddy District. .... Respondents

1. PARTICULARS OF THE CAUSE/ORDER AGAINST WHICH THE PETITION IS MADE:

SUBJECT MATTER IN BRIEF:

The present PIL is filed aggrieved by the action of the 3rd respondent in allotting the land to the 5th respondent to an extent of13.10 acres in Plot No. 25, 26/P and 29/P and reserving Ac.3.17 gts @19.21 crores per acre in Plot No.27/P situated inRaidurg Pan Maktha Village, Sherilingampalli Mandal, Ranga Reddy District to Bar&Bench (www.barandbench.com)

2 establish a furniture store without issuing any notification or without inviting bids from prospective purchasers and in contrary to the spirit ofG.O.MS No.161 dated:13/02/2006, ITC policy 2005-2010, as illegal, arbitrary.

2. PARTICULARS OF THE PETITIONER

The Petitioner was elected as a Member of Legislative Assembly from Kodangal

Assembly Constituency in the year 2009 & 2014. He was also elected as MLC from 2007 to 2009.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 Member of

Legislative Assembly of Telangana State, I have approached the Concern authorities including Hon’ble Chief Minister and council of Minsters for the State of Telangana against the action of the Respondents in violating the rules and deviating basicpurpose for which notification was issued. 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 peoples’ representative, 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. Bar&Bench (www.barandbench.com)

2.1 LOCUS STANDI:-

It is submitted that the Petitioner is the member of Legislative Assembly and permanent resident ofPlot No.854-P, Road No.44, Jubilee Hills Hyderabad – 500033,

Telangana State.He is challenging the action of the 3rd respondent in allotting land to the 5th respondent to an extent of 13.10 acres in Plot No. 25, 26/P and 29/P and reserving Ac.3.17 gts @19.21 crores per acre in Plot No.27/P situated at Sy.No 83/1,

Raidurg Panmaktha Village, Sherilingampally Mandal, Ranga Reddy District on nomination basis without issuing any notification or without inviting bids from qualified purchasers and without following the letter issued by the 3rd respondent vide

Lr.No.195/IPU/APIIC/2012, dt.09.01.2012 in relation to fixation of price which causes more than 500 crores loss to the Public Exchequer as illegal, arbitrary. The Petitioner as a public representative of this State is trying to eradicate such illegal acts done by the Govt. functionaries who are hand in glove with the private respondents as such, he is having locus standi to file this present Writ Petition by way of Public Interest

Litigation.

3. DECLARATION AND UNDERSTANDING OF THE PETITIONER

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road

No.44, Jubilee Hills Hyderabad – 500033, Telangana 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.

3.2 That the entire costs of litigation including the Advocate’s fee is borne by the petitioner. The PAN number of the petitioner is ABYPA0449G.

Bar&Bench (www.barandbench.com)

3.3 That a 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.

3.4 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.

3.5 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.

3.6 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:

4.1 The Petitioner submits that the present Public Interest Litigation is filed aggrieved by the action of the 3rd respondent in allotting the land in Plot No.25, 26/P and 29/P to an extent of Ac.13.10 gts and reserving Ac.3.17 gts in Plot No.27/P @

19.21 crores in Sy.No.83/1, Raidurg Pan Maktha Village, Sherilingampalli Mandal,

Ranga Reddy District to the 5th Respondent to establish a furniture store without issuing any notification in contrary to the spirit ofG.O.Ms.No.161 dated13.02.2006,

ITC policy 2005-2010, as illegal, arbitrary.

4.2 I respectfully submit that I was elected as Member of Legislative Assembly from

Kodangal Constituency for the two consecutive elections held in the year 2009 and

2014. I was always in the forefront of fighting for the public cause even combined state of Andhra Pradesh and also in new state of Telangana whenever governments of the day have taken decisions against the interest of general public and causing crores of rupees loss to the government exchequer. After bifurcation of Andhra Pradesh, I continued my fight on public issues in the new State of Telangana. In this process, I have raised my voice against the illegalities and irregularities, inter alia, committed by the Respondent No.3 in various forums by way of representations, press meets, and Bar&Bench (www.barandbench.com)

5 expressing the same before print and electronic media including the House of

Legislative Assembly.

4.3 I respectfully submit that the 3rd respondent was established by the composite

State of Andhra Pradesh for the purpose to formulate, promote, finance, aid, assist, establish, manage and control schemes, projects or programs, to provide and develop infrastructure facilities, including factory sites, factory sheds, godowns, marketing facilities, warehouses, facilities of communications, power, water drainage, housing, hospitals and other medical and health and educational institutions and other services of any description in order to promote and assist the rapid and orderly establishment, growth and development of industries and commerce in the State of Andhra Pradesh and the same was adopted by the Telangana Industrial Corporation.

4.4 I respectfully submit that in order to promote sustained growth of ICT Sector not only to enhance the balanced regional socio economic development but also to spread the usage of IT to the last mile of the State for the benefit of common man,

Government has announced the ICT Policy 2005-2010 vide G.O.Ms.No.11, IT,E & C

Department dt.21.03.2005. In the said process the Government has allotted 424.13 acres in Sy.No.83/1, Raidurg Pan Maktha Village, Serilingampally Mandal, R.R.District, as per G.O.Ms.No.161, Rev(UC-II)Department, dt.13.02.2006. Thereafter the 3rd respondent divided the said land into different sizes of plots and invited tenders for most of the plots by way of different notificationsfrom 2007 onwards.

4.5 I respectfully submit that the G.O.Ms.No.161 dated 13.02.2006 (Information

Technology, Electronics and Communication) department, was issued intending to develop an area of Ac.424.00 land in Sy.No.83/1 of Raidurg, Near Hitech City

(Cyberabad), Hyderabad as a prestigious hub for knowledge based Industries and

Integrated Township with world class recreational and support services. Under the

Hyderabad Knowledge City Park on ‘as is where is basis’ suitable for mixed used development, including knowledge based industries, IT/ITES Industry, is offered for sale to Reputed Developers in different plots, among them, three plots (Plot No.25, Bar&Bench (www.barandbench.com)

26/P, and 29/P) consisting of Ac.13.10 gts was allotted and reserved Plot No.27/P to an extent Ac.3.17 gts @19.21 crores to the 5th respondent on nomination basis without issuing any notification or without inviting bids from qualified purchasers. It is also relevant to mention here that since the land was allotted to the 5th respondent for the purpose of establishing retail outlet, there is no such impediment to the 3rd respondent to allot land in some other place. But surprisingly the 3rd respondent allotted the land in an IT Corridor.

4.6 I respectfully submit that the 3rd respondent allotted the above said land to the

5th respondent against the policy and intention of the ICT policy 2005 – 2010. Though the land was earmarked for the purpose of developing the IT sector as per ICT policy2005-2010, contrary to the same the 3rd respondent allotted the valuable land to the 5th respondent for lessor price than the existing market value for the purpose of establishing a furniture retail outlet. As per the said G.O. the land in Sy.No.83, Raidurg

Panmaktha Village, is located in the heart of the Software/IT layout developed by the

3rd respondent over the last decade and it is adjacent to the Cyber Towers, Mind Space,

VENENBURG IT Park etc., hence the said land was allotted to the 3rd respondent for development of Integrated IT Park project. Without taking into the purpose and object of the said G.O. the 3rd respondent unilaterally and intentionally allotted the land to the

5th respondent for establishment of furniture retail outlet. It is also relevant to mention here that the 5th respondent is establishing the said retail outlet only for commercial activities but not for any other purpose.

4.7 I respectfully submit that the major irregularity and the conspiracy between the

3rd and 5th respondents can be seen in the manner in which the land was allotted to the

5th respondent. The 3rd respondent issued notification and auctioned most of the plots by way of inviting the bids from qualified purchasers but surprisingly 3rd respondent allotted the land to the 5th respondent in Plot No.25, 26/P and 29/P toan extent of

13.10 acres and reserved Plot No.27/P to an extent of Ac.3.17 gts @19.21 crores per acre situated in Sy.No.83/1, Raidurg Panmaktha Village, Serlingampally Mandal, Ranga

Reddy District on nomination basis without calling for the bids or without issuing any Bar&Bench (www.barandbench.com)

7 notification. The 3rd respondent initially allotted 13.10 acres to the 5th respondent and there after basing on the request of the 5th respondent the land in Plot No.27/P to an extent of Ac.3.17 gts was reserved by accepting 5% of sale consideration with a condition that as an when the 5th respondent intends to purchase the said property the

3rd respondent has to sell the same @19.21 crores per acre. The said action is highly illegal and I have reliably learnt that as on today also the 3rd respondent have not allotted the above said land and reserved for 5th respondent, if the 5th respondent intends to purchase the property after five years also the 3rd respondent has to sell the same @19.21 crores per acre. A perusal of the above said transaction it is clear that the 3rd and 5th respondents colluded each other and are causing huge loss to the Public

Exchequer.

4.8 I respectfully submit that a perusal of the letter No.195/IPU/APIIC/2012, dt.09.01.2012 addressed by the 3rd respondent to the 4th Respondent informing that the

3rd respondent sold an extent of 105.54 acres of land to eight companies for establishment of IT/ITES Campus and for mixed used development and also for support services. It was further informed that the vacate land available for exclusive use of

IT/ITES Companies is about 167.60 acres and the same can be allotted to the IT/ITES

Companies for construction of their own campuses or to IT Infrastructure developers for onward usage to IT/ITES Companies, the land can be allotted to IT/ITES Companies as recommended by the Government and after entering in the MOU, duly adopting the rate fixed by the Government and as per IT Policy. A perusal of above information clearly indicates that the land can be allotted only to the IT/ITES Companies or IT

Infrastructure developers. In contrary to the same the 3rd respondent allotted the land to an extent of Ac.13.10 gts and reserved Plot No.27/P to an extent Ac.3.17 gts @19.21 crores to the 5th Respondent for establishment of furniture retail outlet.

4.9 I respectfully submit that a further perusal of the letter dt.09.01.2012 the 3rd respondent clearly discloses that the land can also be allotted to IT Infrastructure

Developer Companies for development of IT Towers/Spaces for establishment of

IT/ITES Companies, however the same will be allotted through open auction (or) 1½ Bar&Bench (www.barandbench.com)

8 time of the existing land rate as fixed by the APIIC from time to time as per the allotment regulations of the APIIC. It is further submitted that a further perusal of the above contents it is very clear that the land has to be allotted only to the IT/ITES

Sectors but not for furniture retail outlets.

4.10 I respectfully submit that basing on the letter addressed by the 5th respondent dt.05.03.2015 the 3rd respondent allotted/sold the land in Plot No.25, 26P and 29P to an extent of Ac.13.10 gts in Sy.No.83/1, Raidurg Panmaktha Village, Serlingampally

Mandal, Ranga Reddy District and executed a Sale Deed vide Doc.No.8775 of 2015, dt.09.07.2015 for total consideration of Rs.251,65,10,000/- (Rupees Two Hundred Fifty

One Crores, Sixty Five Lakhs and Ten Thousand Only). The sale fixation of price between the 3rd and 5th respondent was happened in a fraudulent manner since 3rd respondent sold the property in open auction to one ITC Limited by way of Registered

Sale Deed vide Doc.No.10485 of 2011, dt.14.09.2011 to an extent of Ac.5.00 vide Plot

No.5 in Sy.No.83/1 at Raidurg Pan Maktha Village, Serilingampally Mandal, R.R.District for sale consideration @ 25.50 crores per acre which comes to Rs.127.50 Crores

(Rupees One Hundred Twenty Seven Crores and Fifty Lakhs Only) as total consideration. In the same way the 3rd respondent sold the property in open auction and executed a sale deed in favour M/s.Gowra Ventures Pvt. Ltd., vide Doc.No.8171 of

2017, dt.24.07.2017 to an extent of Ac.2.84 vide Plot No.8A and 8B1 in Sy.No.83/1 at

Raidurg Pan Maktha Village, Serilingampally Mandal, R.R.District for a total sale consideration of Rs.121,28,08,960/- (Rupees One Hundred Twenty One Crores, Twenty

Eight Lakhs Eight Thousand and Nine Hundred Sixty Only), if the same is calculated per acre the same comes to Rs.42,50,20,000/- (Rupees Forty Two Crores Fifty Lakhs and

Twenty Thousand Only).

4.11 I respectfully submit that a perusal of the sale transactions with regard to same survey number in relation to ITC Limited the land was sold in open auction @ 25.50 crores in the year 2007 and in relation to M/s.Gowra Ventures Pvt. Ltd., the land was sold in the open auction @ Rs.42,50,20,000/- in the year 2017. Surprisingly and fraudulently the 3rd respondent allotted the land to the 5th respondent @19.21 crores in Bar&Bench (www.barandbench.com)

9 the year 2015 in the same survey numbers. As per the letter dt.09.01.2012 if the 3rd respondent intends to allot the land without any notification, they have to allot the land to the prospective purchasers 1 ½ times to the existing market price. The value of the land sold to ITC Limited which was auctioned in the year 2007 is 25.50 crores, if the same is taken into consideration the 3rd respondent ought to have allot the land to the

5th respondent 1½ times of the ITC Value i.e., 25.50 crores + 12.75 = 38.25 crores

(Thirty Eight Crores and Twenty Five Lakhs) as such there is a loss of 19.04 crores per acre, for Ac.16.17 gts the loss would be 307.87 crores approx. If the 3rd respondent taken into consideration of the sale consideration of Gowra Ventures Pvt. Ltd., the 3rd respondent has to allot the land to the 5th respondent for an amount of

Rs.42,50,20,000/- per acre. As such there is a loss of Rs.28.49 crores per acre and for

Ac.16.17 gts the loss would be Rs.370.86 croresapproximately, apart from the loss to the Stamps and Registration Department for registering the land to the lower price, if the land allotted to an actual price to the 5th respondent the Stamps and Registration

Department would get 6% of stamp duty as a registration charges on Rs.120.00 crores,but the 3rd respondent allotted the land to the 5th respondent who involved in a furniture retail outlet business @ 19.21 crores. I submit that where the land cost in

Sy.No 83/1, Hyderabad Knowledge City, Raydurg is 25.50 crores in the year 2007 and

Rs.42,50,20,000/- in the year 2017 it is not correct on part of the 3rd respondent to say that they have decided to allot the land to the 5th respondent @ 19.21 crores per acre in view of the recent upward trends in the real-estate. The said price is very lessor than the existing price as on the date of sale deed. It is not the out of place to mention here that the 3rd respondent is not a real estate company and cannot sell away the government lands in a hurry manner which were allotted to encourage the IT Sector so as to give the benefit to the rural unemployed youth for getting employment in IT/ITES

Industries.

4.12 I respectfully submit that the 3rd respondent cannot allot the land beyond the scope of ICT Policy 2005-2010 and contrary to the G.O.Ms.No.161, dt.13.02.2006.

Once, the Government decided and framed policy for what purpose the land has to be Bar&Bench (www.barandbench.com)

10 allotted, the 3rd respondent cannot deviate the same and cannot change the priority as per his whims and fancies. Once, the game is started rules cannot be changed illegally and cannot allotted the land to the purpose other than mentioned in the ICT Policy

2005-10.

4.13 I respectfully submit that the other irregularity in relation to the allotment of land to the 5th respondent is that the 3rd respondent again allotted Acres 3.07 in Plot No.27 part on nomination basis in the year 2017 @ 19.21 crores. Where the 3rd respondent executed a sale deed in relation to Gowra Ventures Pvt. Ltd., @ Rs.42,50,20,000/- in the same survey number but in relation to the 5th respondent the same was allotted

@19.21 crores for the reasons best known to them.

4.14 I respectfully submit that it is also relevant to mention here that in the year 2016 the land allotted to the 5th respondent was effected due to road widening to an extent of 0.251202 acres falling on the South eastern boundary, the 3rd respondent allotted the same extent of land on the North western boundary as a compensation to the effected land on South eastern boundary. Once, the sale deed is executed the 3rd

Respondent would become functus officio and is no way responsible to compensate the land which was effected in the road widening. If the land was effected due to road widening it is upto the concern department to pay the compensation to the 5th respondent. But surprisingly the 3rd respondent executed a Deed of Exchange vide

Doc.No.2219 of 2016, dt.20.02.2016 in favour of the 5th respondent by handing over the land to an extent of 0.251202 acres on the North Western boundary. The above action is classic example to show the favoritism towards the 5th respondent by ignoring

Law prevailed.

4.15 I respectfully submit that the Hyderabad Knowledge City is exempted from

Zoning regulations and land conversion charges since the same was allotted to the 3rd respondent under ICT Policy 2005-2010 to develop/encourage the IT/ITES Sectors and

IT Companies to develop World Class IT Infrastructure and create employment to unemployed qualified youth hails from rural areas. But, in contrary to the above said purpose the 3rd respondent allotted the land to the 5th respondent who is establishing a Bar&Bench (www.barandbench.com)

Furniture Retail Outlet by causing loss more than 380 crores approximately of

Government Exchequer. It is also relevant to mention here that in the other states like

Gujarat and Haryana the 5th respondent participated in the auction conducted by the

Government and purchased the land for establishment of their business. But here the

3rd respondent straight away allotted the land @ 19.21 crores per acre on nomination basis without calling for bids or without issuing notification though the 3rd respondent was fully aware that the existing price is higher than the allotted price to the 5th respondent as such there is huge loss of Government Exchequer apart from defeating the very purpose of the scheme in generating employment to the qualified unemployed youth.

4.16 I respectfully submit the 4th Respondent who is the supervisory authority in implementing the ICT Policy has failed in the instant case by closing his eyes. Taking advantage of the same, the other official Respondents have aided the Respondent No.5 in deviating the ICT policy and causes huge loss of more than 380 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 5th respondent the same would cause great hardship to the unemployed youth and also more than 500 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 into force w.e.f. 02-09-2015, 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 Bar&Bench (www.barandbench.com)

12 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:

9.1 Letter vide Lr.No.TSIIC/Projects/IKEA/21/1/2015, dt.25.04.2015. 9.2 Letter vide Lr.No.195/IPU/APIIC/2012, dt.09.01.2012 9.3 Agreement of Sale, dt.09.07.2015 9.4 Deed of Sale, dt.09.07.2015 9.5 Deed of Exchange, dt.20.02.2016 9.6 Deed of Sale, dt.14.09.2011 9.7 Deed of Sale, dt.24.07.2017 9.8 G.O.Ms.No.11, dt.21.03.2005 9.9 G.O.Ms.No.161, dt.13.02.2006 9.10 Letter dt.05.03.2015

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.3 in allotting the land to the 5th respondent to an extent of 13.10 acres in Plot No.25, 26/P and 29/P and reserving Ac.3.17 gts @19.21 crores per acre in Plot No.27/P situated in Sy.No.83/1, Raidurg Panmaktha Village, Serlingampally Mandal, Ranga Reddy District as illegal, arbitrary and contrary to the G.O.Ms.No.11, dt.21.03.2005; ii. declaring the action of the Respondent No.3 in allotting the land to the 5th respondent on nomination basis without calling for the tenders or without issuing any notification 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 with the M/s.Gowra Ventures Pvt. Ltd; iii. and consequently direct the 1stRespondent to cause enquiry with regard to the fraud taken place in allotting the land to the 5th 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: Bar&Bench (www.barandbench.com)

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 5th Respondent not to carry any activities in the land allotted to an extent of 13.10 acres in Plot No.25, 26/P and 29/P and reserved land to an extent of Ac.3.17 gts @19.21 crores per acre in Plot No.27/P situated in Sy.No.83/1, Raidurg Panmaktha Village, Serlingampally Mandal, Ranga Reddy District, 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.

Sworn and signed before me on this the ______day of August, 2018 at Hyderabad DEPONENT

Advocate/Hyderabad

VERIFICATION

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road No.44, Jubilee Hills Hyderabad – 500033, Telangana State., being the Petitioner/person acquainted with the facts of the case, do hereby declare that the contents of paras 1 to Bar&Bench (www.barandbench.com)

19 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 August, 2018 at Hyderabad.

ADVOCATE DEPONENT

MEMORANDUM OF WRIT PETITION (UNDER ART. 226 OF THE CONSTITUTION OF INDIA)

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015) (SPECIAL ORIGINAL JURISDICTION)

WP (PIL).NO. OF 2018

Between:

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana State Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Bar&Bench (www.barandbench.com)

Ranga Reddy District. .... Respondents

The address of the Petitioner for the purpose of service of all summons, notices, process etc. is that of his counsel M/s.Tera Rajinikanth Reddy (11087) and R.Giri Kumar, Advocates, O/o.Flat No.102, Sri Sai Apartments, Prabath Nagar, Chaitanyapuri, Dilsukhnagar, Hyderabad – 060.

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

i) declaring the action of the respondent No.3 in allotting the land to the 5th respondent to an extent of 13.10 acres in Plot No.25, 26/P and 29/P and reserving Ac.3.17 gts @19.21 crores per acre in Plot No.27/P situated in Sy.No.83/1, Raidurg Panmaktha Village, Serlingampally Mandal, Ranga Reddy District as illegal, arbitrary and contrary to the G.O.Ms.No.11, dt.21.03.2005;

ii) declaring the action of the Respondent No.3 in allotting the land to the 5th respondent on nomination basis without calling for the tenders or without issuing any notification 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 with the M/s.Gowra Ventures Pvt. Ltd;

iii) and consequently direct the 1stRespondent to cause enquiry with regard to the fraud taken place in allotting the land to the 5th 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

Bar&Bench (www.barandbench.com)

ANNEXURE – 5

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015)

W.P. (P.I.L.) No. Of 2018

BETWEEN :

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana State Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Ranga Reddy District. .... Respondents

AFFIDAVIT FILED UNDER RULE 5 OF PIL RULES 2015 Bar&Bench (www.barandbench.com)

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 August, 2018 At Hyderabad. DEPONENT

ADVOCATE :: Hyderabad

VERIFICATION STATEMENT

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road No.44, Jubilee Hills Hyderabad – 500033, Telangana State.., do hereby solemnly affirm and sincerely state that what are stated in the paragraphs are true to our own Bar&Bench (www.barandbench.com)

18 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 August, 2018 at Hyderabad.

ADVOCATE DEPONENT ANNEXURE 6

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015)

W.P. (P.I.L.) No. Of 2018

BETWEEN:

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana State Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Ranga Reddy District. .... Respondents Bar&Bench (www.barandbench.com)

DECLARATION FILED UNDER RULE 6 OF PIL RULES 2015

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road

No.44, Jubilee Hills Hyderabad – 500033, Telangana State., 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 August, 2018.

ADVOCATE DEPONENT

Bar&Bench (www.barandbench.com)

ANNEXURE-7A

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015)

W.P. (P.I.L.) No. Of 2018

BETWEEN:

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Ranga Reddy District. Bar&Bench (www.barandbench.com)

.... Respondents

AFFIDAVIT FILED UNDER RULE 7 A OF WRIT PROCEEDINGS RULES

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road

No.44, Jubilee Hills Hyderabad – 500033, Telangana State., 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 August, 2018 and signed his name in my presence. DEPONENT

ADVOCATE :: Hyderabad

VERIFICATION

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road

No.44, Jubilee Hills Hyderabad – 500033, Telangana State., 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 August, 2018 at Hyderabad.

ADVOCATE DEPONENT

Bar&Bench (www.barandbench.com)

ANNEXURE 8

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015)

W.P. (P.I.L.) No. Of 2018

BETWEEN:

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Ranga Reddy District. .... Respondents

Bar&Bench (www.barandbench.com)

DECLARATION FILED UNDER 8 OF PIL RULES 2015

I, Anumula Revanth Reddy, S/o. Late A.Narasimha Reddy, Hindu, Aged about 50 years, Occ: Member of Legislative Assembly, Telangana R/o. Plot No.854-P, Road No.44, Jubilee Hills Hyderabad – 500033, Telangana State., 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

Bar&Bench (www.barandbench.com)

ANNEXURE 10

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

(Rule-4(e) the High Court of Judicature at Hyderabad for the State Telangana and the State of Andhra Pradesh Public Interest Litigation Rules, 2015)

W.P. (P.I.L.) No. Of 2018

BETWEEN:

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

AFFIDAVIT FILED UNDER 10 OF PIL RULES 2015

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 August, 2018 and signed his name in my presence. DEPONENT

ADVOCATE :: Hyderabad

VERIFICATION

Hence verified the same on this the _____day of August, 2018 at Hyderabad.

ADVOCATE DEPONENT

Bar&Bench (www.barandbench.com)

MEMORANDUM OF WRIT PETITION MISC. PETITION (UNDER SEC. 151 OF THE C.P.C.)

HIGH COURT OF JUDICATURE AT HYDERABAD for the State of Telangana and the State of Andhra Pradesh

I.A. (P.I.L.)M.P. No. OF 2018

W.P. (P.I.L.) No. OF 2018 Between:

AND

1. The State of Telangana, rep.by its Chief Secretary, Secretariat, Hyderabad.

2. The State of Telangana, rep. by its Principal Secretary, Revenue Department Secretariat, Hyderabad.

3. The Telangana Industrial Infrastructure Corp. Ltd., Rep. by its Vice Chairman-cum-Managing Director O/o.5-9-58/B, 6th Floor, Parishrama Bhavan Basheerbagh, Hyderabad.

4. The State of Telangana, rep. by its Principal Secretary, Information Technology, Electronics & Communication Department Secretariat, Hyderabad.

5. Ikea India Pvt. Ltd., Rep. by its Chief Financial Officer O/o.Plot No.25 & 26, Hyderabad Knowledge City Raidurg Village, Serilingampally Mandal Ranga Reddy District. .... Respondents

For the reasons stated in the accompanying this affidavit, it is therefore prayed that this Hon’ble High Court may be pleased to direct the 5th Respondent not to carry any activities in the land allotted to an extent of 13.10 acres in Plot No.25, 26/P and

29/P and reserved land to an extent of Ac.3.17 gts @19.21 crores per acre in Plot Bar&Bench (www.barandbench.com)

No.27/P situated in Sy.No.83/1, Raidurg Panmaktha Village, Serlingampally Mandal,

Ranga Reddy District, 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.

HYDERABAD.

Dated: .08.2018 Counsel for the Petitioner