I therefore request the Standing Counsel for Andhra Municipalities,

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1 NTgNCPAL ADMNSTRATON DEPARTMENT Frona, K.Sairam, B.Sc., Commissioner, Tanuku Municipality, TANUKU To, The Standing Counsel, for Andhra Municipalities, Hon'ble High court of A.p, HYDERABAD Roc No. 1165/2O13-G1. Dt: 11-O9-2O1S S.ir sub: PL - Town planning - Tanuku Municipality - pl No. 3g3l2ot3 fi1ed by Sri Manda suryanarayana and another against the Government of Andhra Pradesh Rep.by Principal Secretary pr & RD Dept. Hyderabad and T others - para wise remarks Submitted - Regarding. Ref: 1. Letter No. Nill, dated: o2-og-2o13 of the Standing Counsel for Andhra Municipalities, Hon,ble High court of A.pJ Hyderabad. 2. PrL No. 393/ 2or3 of Honbre High court of A.p., Hyderabad. am to submit that in pursuance of the reference 1"t cited, para wise remarks has been prepared on behalf of the 7th respondent, i.e., Tanuku Municipality and submitted herewith for drafting the cbunter affidavit in pl No' 393/2013 filed by sri Manda Suryanarayana and another Challenging the GoMs No' 101, Dated: and the consequential orders issued in GoMs No's' 194 & 723, Dt cancelling Venkatarayapuram ndustrial area Town Ship and merging the same with Tanuku Municipality, including resolution no. 96, Dt passed by the Town ship committee and Panchayat Secretary. therefore request the Standing Counsel for Andhra Municipalities, Honble High court of A.P., Hyderabad to kindly prepare and file the counter affidavit in the above PL and defend the case on uerrar of the 7th respondent. Yours faithfully, Encl: Para wise remarks and connected record. \ v.-" Comrflrssioner, Tanuku Municipality. t!,,^\' tt\t' :?ry YP-itted to the Principal secretarr. \4A & ud Department, A.p., Hyderabad for kind mlortnatlon. copy submitted to the C & DMA. A.p.. Hyderabad for kind infbrmation. coov submitted to the RD -cum-ac of MA, Rajahmundry for information.

2 .T + N THE HGH COURT OF JUDCATURE OF ANDHRA PRADESH: AT HYDERABAD PL.No. 393 OF 2013 Between:- 1. Manda Survanarayana S/o. Late M. Satyanarayana Hindu" aged 42 years" Occ:Private Ser:vice R,o.D.No i " Ramalal,'am Street Venkatarayapuram Tanuku Rural Mandal. W.G.District. 2. Addala Rama Krishna S/o. A.Venkatachalam. aged 55 1,ears Hindu, Occ :Agri culture R/o.D.No.9-l57ll. Near Bashyam Public School Venkatarayapuram Tanuku Rural Mandal, West Godavari District. Petitioners AND 1. Government of Andhra Pradesh Rep.by it's Principal Secretary Panchayath Raj and Rural Development Dept., Secretariat, Hyderabad. 2. Government of Andhra Pradesh Rep.by its Principal Secretary Municipal Administration & Urban Developntent Dept.. Secretariat, Hyderabad. 3. The Commissioner Panchayath Raj and Rural Development Andhra Pradesh. Hvderahad. 4. The District Collector West Godavari District. Eluru. 5. The District Panchayath Officer Xaviour Nagar. Eluru. W.G.District. 6. The Mandal Praja Parishad Developrnent Ofllcer Tanuku. West Godavari District. 7. Tanuku Municipality Rep.by its Commissioner, Tanuku

3 facts ofthe case. 2. have read the affrdavit filed on behalf of the petitioner herein and deny the material allegations contained therein, which are not specifically admitted herein. 3, n reply to the averments made in Para 3 of the affidavit, it is submitted that the petitioners have the locus stand to file the present PL before this Hon'ble Court. t is submitted that no public interest at large is involved in this PL and therefore the same is not maintainable. t may be pointed out that the G.O.Ms, vvhich are irnpugned in this PL is being challenged already in W.P.No.97B4 af 2013 and the same is pending in this Hon'ble Court. 4. t is submitted that the allegations made in Para 5 to 7 are baseless. t is false to state that the respondent authorities even without ascertaining the views of the public and without following the procedure to be followed as per the Rules and without power or authority. the respondent No.3 had excluded the Venkatarayapuram ndustrial Area Township from Mandapaka Gram Panchayath. \

4 ent and Commissioner, L.P.A. Municipal Administration and Jrban Development Deparlntent hare sent a lett:t'.1t 11-ir:-lrtii) :r rlt: D..t:'t;, f,ll:,: t.. ',.\ --i: -,.:..ul...:...]--.=:,..,,.._,...,,.,..,,,:...'-.,--..,,, to include new colonies in the Per-urban areas in to the accordance s-ith the rules as Fler GO\ls \tr" 6i \L{ & LD tele [tr r Depammenr -T!,lrx :1- a!- ) r1730a0y' ^rr1.d. L ile'j -/ \rr* TXrCnttfffi[Er P,l

5 commissioner, Tarnrku Municrparity to send necessary proposals in the matter vide Roc No.3099/2009/H6, DT: Afteru.ards this Municipalig.placed the matter before the cormcil and the Cormcil of rmtrku Mrmiciparitr" passod resolrrtion in CRNo.l53, DLls $g.i2frdto irchdc ve*maffrm Tostr dlip alongwithsomeothervillagesintamkumunicipaliry-thsairlpqocllm submieed to 4e respondent vi&, r-roc }O'993/AngGl' fl r?{l}2fld' fr ir submitted that while the matter stood thus' on the representation of &e Tmrrktl MLA,theCommissionerandDirectorofMunicipalAdministrationhassenta letter to the 4e respondent to examine the issue of inclusion of peri-urban areas in to Tanuku Municipality. There upon the District Revenue officer' west Godavari District has sent a letter to this respondent to send proposals and remarks for inclusion of the Peri-urban villages in to Tanuku Municipality' A resolution got passedincrno.576,dt throufhspecialofficer,tanuku MunicipalityforinclusionofVenkatarayapuramTownShip,PaidiparuVillage' veerabhadrapuram village Tanuku Municipality' to the Principle Secretary to Government Municipal Administration and urban Development Department' A.P.,Hyderabad,throughtheCommissionerandDirectorof.Municipal Administration, A.p. Hyderabad and through the 4ft respondent, vide; Lr'Roc No' gg3l200gtcl, Dt after obtaining consent resolution passed by the Town ship committee and Panch ayahsecretary in Resolution no' 96' dt' OL?-

6 6. t is further submitted that the 4 respondent has submitted the said --':-rfrl>.:' -.-]r_-,,.111i<<i1111g1.:rnddirecltltof\lrrnlcipaladrllinistration.ap., Lll'.i.::;--::-:-:--: ' -- :1"":'-" - - l-- *:'-' '- -: -' -" - '-,Dt l3.tissubmittedthattheGovernmenthaveissuednotilrcationby rnclr-rdinstheebores:llc"lil;"set1l'll l:l'"1\''\i-':.1-":''ll:-.''ie [i())'f i\r] 1lj MA & -L'rD-.LELFf,!*%ffittlDt'1G ' mmediatel-v 'rs per tre -1:g'i't :iv3olov,o1'.rrr5 1t,}[ 'cl'g --:0f l8?86 ltac

7 r-roti6catic,r.r isstl.-.1 b., :lr.- (irr\c't'l:'.r'ltt altd instnrctiot.ts of the Highcr.{uthorities -_ \ _ '_ "' ' - --1,,'* ' ' ;.. -'''- \'- '-''--t"' ]'l't---t ''t'-' L.-': '-l'.!.:.-: ::,a itr.e t'rthers irli e llled \\ P \c q-si 'i-: i:s.iit-st tl.ic Gtrrenllllellt oi Andhra Pradesh and l2 Others includir-rc this respottdent br Challenging the GOM's NO.101. Panchayath Rai and Rural Der elopment (MDL.ll-A) Deparlment, Dt, and Consequential GOM's No Panchalath Raj and Rural Development (Pts.lv) Department. dt and GOM's NO. 123 Municipal Administrations and Urban Development (Elec.1) Department. dt and the same is nou,pending before this Hon'ble Cour1. 8. lt is slrbmirted that ulrder Sec.3 of A.P. Panchal ath Rai Act. the Gor ernment has po\\ er to denotiti the tou'n ship and merge the same in the '.'.-'t- -:,..::.,,s,: T.tn,-:k,,t T1t.'l'e',..r'e the ilati(rn of t1-re re>frr1ldellt llttthtrt'iiies ill _r"_'''_ - ' '-' ' ' i'r lihr- u d:1\ p "ltfa,.e i. 'O,lSeie.S af is iilegalit) or arbitrariness in present action of ttre respondent. t is submitted that there are no merits in the writ petition warranting any interference from this Hon'ble coutl and the same is

8 t is therefore prayed that this Hon'ble Court ma1' be Pleased to dismiss the writ petition as the same is devoid of anl' merits' Sworn and signed before "" irrir,n. 1[tnaa1' of SePtember' 2oi3 at {o.-,-\\{ before me ATTESTOR: - Cell t B.'P. Ravi Sot kqr t i ADVOCATE 8.A.,8.L..,j Chemutunvalrstreet Near Foot Bridge \ -4 -d

9 \ Eir:,r- i' - -' tr.. K.Se, {"::l > '.' i ''': - "--'"-'-' --l' - -:-;* -': -: :- ' =-'-'' - '--^. :: -:' of Tanuku \luniciraltn. T-,:-.-'"."" ''i' ':' l-r'j':"::. ll l:':'-" -:-: -' -;' -- : -.--:' \\hat has been stated in paras lled ln SLllilr-r11 :i i---; :'---':-''' 1: '- 'i'-.' ''-''--''-'-: petition are true and aoneat to the hc-<t oilll\ \1,-r'.1,-ci;:. ::'-c- -:1J -:-:- --'--i:j : legal adrice given to n]e.. \erilred orl i;1r of Septernber' 1013' ADVOCATE JUg'*'--- /\Jj ) {/. Lfr, - (\" $ ^*, \'

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