-1-

IN THE HIGH COURT OF JUDICATURE: ANDHRA PRADESH AT HYDERABAD W.P. No. Between Y. S.Vijaya W/o late Dr. Y. S. Rajasekhara Reddy Aged about 55 years , Member of Legislative Assembly Honourary President, YSR Congress Party R/o Bakarapeta, Pulivendula Y.S. R. Kadapa District And 1. The Union of India rep. by its Secretary, Ministry of Home, Shastri Bhavan, New Delhi 2. The State of A.P. Rep by its Chief Secretary Secretariat Buildings, Hyderabad 3 . The Government of A.P. rep. by its Principal Secretary, Home Department Secretariat Buildings, Hyderabad 4. The Central Bureau of Investigation rep by its Director, Shastri Bhavan New Delhi. 5. The Enforcement Directorate rep.by its Director 6th floor, Loknayak Bhavan, Khan Market New Delhi 110 003 6. The Director General of Police A.P. Hyderabad 7. The Securities Exchange Board of India Plot No C4-A. G Block, Bandra Kurla Complex, Bandra (East) Mumbai 400 051 rep by its Chairman 8. Sri Nara Chandrababu Naidu S/o N. Kharjura Naidu Aged about 61 years, M.L.A, R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 9. Smt. N. Bhuvaneswari W/o N. Chandrababu Naidu Aged about 55 years Occ. business R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad OF 2011

. Petitioner

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10. Sri N. Lokesh S/o N. Chandrababu Naidu Aged about 28 years Occ. business R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 11 . Sri Ch. Ramoji Rao S/o Venkata Subba Rao Kartha of HUF. Aged about 75 years Chairmans Residennce, Ramoji Film City, Anajpur, R.R. District, Hyderabad 501 512 12. Ushodaya enterprises Private Limited Somajiguda, Hyderabad, Rep.by Sri Ch.Ramoji Rao, Kartha of HUF 13. M/s. Heritage Foods (India) Limited 6-1-541/C, Panjagutta, Hyderabad 500 082 Rep by its Managing Director Smt. N. Bhuvaneswari 14. Mr. Ahobala Rao S/o P.V. Subba Rao Aged about 51 years Occ. Business Plot No. 305A, Road No. 25 Jubilee Hills, Hyderabad 15. Sri V. Nagaraja Naidu S/o Rama Naidu Aged : Major, Occ: Business, R/o Plot No. 1178, Jubilee Hills, Hyderabad 16. Sri Yelamanchili Satyanarayana Chowdhary S/o Yelamanchili Janardhana Rao, aged about 50 years R/o Plot No. 29, Sagar Co-op. Housing Society Road No. 2, Banjara Hills, Hyderabad - 34 17. Madhucon Sugar and Power Industries Limited 1-7-70, Madhu Complex, Jubileepura Khammam 507 003, Rep.by its Founder Sri Nama Nageswara Rao. 18 . Maganti Rajababu alias Murali Mohan S/o Maganti Madhava Rao, aged : Major , Occ. Business R/o A14, Film Nagar, Jubilee Hills, Hyderabad 19. Sri Karnati Venkateswara Rao S/o Kotaiah Aged about 50 years, Occ. Chairman, M/s. Kakinada Sea Ports Limited, 8-2-418, Meenakshi House, 3rd floor, Road No. 7, Banjara Hills, Hyderabad - 500 034 20. Sri Chintakunta Munuswamy Ramesh S/o Munuswamy Naidu, Aged : Major, Occ. Chairman, Rithwik group of Companies , 8-2-269/S/91/B, Road No. 2, Sagar Society Banjara Hills, Hyderabad - 34 Respondents

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AFFIDAVIT FILED BY THE WRIT PETITIONER I, Smt. Y.S. Vijaya, W/o late Dr. Y.S. Rajasekhara Reddy, aged about 55 years Occ. Member of Legislative Assembly, Pulivendula Assembly Constituency R/o Bakarapeta, Pulivendula, Y.S.R.Kadapa District, having temporarily come down to Hyderabad, do hereby solemnly affirm and sincerely state on oath as follows : 1. I am the petitioner herein and as such am well acquainted with the facts of the case. 2. I respectfully submit that the present Writ Petition is being filed in Public Interest seeking the indulgence of this Honble Court under Article 226 of the Constitution of India in regard to causing an enquiry/investigation by an appropriate agency, like the Central Bureau of Investigation into many acts of criminal misconduct committed by the unofficial Respondents during the course of governance of the State during the years 1995-2004 while being in positions of power and authority.

3.

I respectfully submit that, I am the wife of late Dr. Y.S. Rajasekhara Reddy, the former Chief Minister of the State. I have long been socially and politically conscious and have been following the political and social scenario in the State of Andhra Pradesh. I am a sitting Member of the Legislative Assembly from Pulivendula Constituency having been elected in the year 2011 as a candidate of Yuvajana Sramika Rythu Congress Party ( Y.S.R.Congress Party) a registered political Party with the Election Commission of India. I am the honourary president of the said Political Party. I have participated in various social movements in the Assembly Constituency and have

-4-

been organizing programs to create awareness about the rights of the citizens to be governed efficiently and honestly. 4. a. I submit that there are several instances of wrong doing by the

private Respondents, who have acted in concert to ensure that there has been wrongful gain and designed advantage to them and others at the cost of the State exchequer. These activities have continued for several years, and it is only recently, with the advent of the Right to Information Act and the information obtained/received by the Petitioner from time to time from various sources including the media, the Registrar of companies, Land Registration Department, SEBI, AP Government Orders, Tax departments and other credible sources that many new documents have come to light that point at the culpability of the private Respondents at the altar of criminal law. The offences committed by them include those under the Prevention of Corruption Act, the Indian Penal Code, the Prevention of Money Laundering Act, FEMA, the Representation of the People Act, the AP Land Grabbing Act and the Benami Transactions (Prohibition) Act.

b. In regard to securing information in the manner stated above, I had to seek the help and contribution of many people, and primarily including Sri Vijay Sai Reddy, Chartered Accountant, the financial advisor for the family since the year 1985. c. I respectfully submit that I hereby affirm and state on oath that I have no personal interest in the subject matter of this petition and I hereby undertake to pay exemplary costs and/or compensatory damages as directed by this Honble Court in the event of contrary finding upon adjudication by this Honble Court that the writ petition who has been

-5-

is filed for extraneous/personal consideration or with an oblique motive. For the convenience of this Honble Court, the various instances of wrong doing and the documents evidencing the same by the unofficial Respondents are given below. 5. Disproportionate Assets of Sri. Nara Chandrababu Naidu The Respondent No. 8 a. Born in 1951 in a lower middle class farmers family in Chittoor District of Andhra Pradesh, Sri.Naidu went to Sri Venkateswara University College, Tirupati, from where he directly entered politics. As a result, for a continuous period from 1978 to today (2011), Sri.Chandrababu Naidu had no source of income apart from his political career and the income from his original land holding. From 1978 to 1983, he was a Congress MLA and functioned as Minister of State for Animal Husbandry including development of poultry, sheep and pig rearing, dairy development including Dairy Development Corporation, Meat and Poultry Development Corporation and Milk Supply Scheme (1980-81). He was a Minister of State for Archives, Archaeology, museums including Salarjung museum, Public Garden, Public Libraries, Cinematography, Film Development including FDC (1981-82). And also in 1982 he held three different ministries as Minister of State. He was the Minister of State for ground water and APSIDC, Minister of State for Minor Irrigation and Minister of State for Technical Education and Indian Medicine. In the year 1983, he was defeated as a congress contestant and subsequently joined his

-6-

father-in-laws Telugu Desam Party (TDP) and chosen as Chairman of Andhra Pradesh Karshaka Parishad which was challenged in this Honble Court, and it was held that the said appointment is illegal and unconstitutional. b. He used his clout to raise loans from APIDC and APSFC. Sri.Chandrababu Naidu became MLA for a second term in 1989 and he was an opposition MLA till 1994. In 1994, he became Cabinet Minister for Finance and Revenue in Mr NTR cabinet. On 1st September, 1995, taking advantage of rumors that were deliberately spread by certain sections that Mr NTRs health was not good, Mr Naidu mobilized enough support of TDP MLAs to overthrow Mr NTR under whose leadership, hardly in less than a year before, the TDP was able to reduce the Congress Party to a strength of 26 MLAs in a house of 294. It was unconceivable that a tall and honest leader could be overthrown so easily and so brazenly with impunity. This is the biggest ever betrayal by any son-in-law against any father-inlaw in the history of this country. This became possible only because of the support received by Mr Naidu from Sri Ramoji Rao of EENADU paper. Sri Ramoji Rao nursed a grouse against Mr NTR that despite his contribution to the growth of TDP Mr NTR never bothered about him. He firmly believed it was only because of the support extended by his news paper that TDP got foothold in AP and that therefore he was excepting to be respected by TDP. Mr NTR did not believe in this theory that Ramoji Rao was instrumental in his political ascendency. Therefore, the conflict between the two. The very fact that Sri Ramoji Rao in a Sworn Affidavit before the Honble AP High Court, which is reproduced below, goes to prover his role in promoting and nursing the TDP. He averred as follows in WP No 27065 of 2006; I submit that until 1983 the congress was running State in an unchallenged and unilateral manner for the past 30 years. The Congress Party became a threat to the democracy and in

-7-

view of the single party and individual rule by Indira Congress, the opposition in the state was in emaciated condition. It has been reduced to the status of a nominal entity. The dictatorial rule of the congress proceeding without any hindrance. I submit that as the opposition parties were weak and were in helpless situation where they were unable to do any thing inspite of misrule by the ruling party, Eenadu played the role of opposition. I submit that in the elections of the State Assembly held in 1983, the Congress for the first time did not secure a majority in the elections and lost the power to the newly formed Telugu Desam Party. I submit that on the day of poling i.e. January 5, 1983, I issued a signed editorial on the front page of Eenadu supporting the manifesto of Telugu Desam Party and calling on the electorate to vote for Telugu Desam Party giving cogent reasons for the stance taken by me.

Mr Ramoji Rao was actively promoting Mr Naidu as an alternative to Mr NTR became the friend, philosopher and guide of Mr Naidu. Together, they have successfully dethroned the mighty Mr NTR, who openly talked of the unholy nexus between Sri Ramoji Rao and Sri Chandrababu Naidu. Sri Ramoji rao's EENADU was having a market share of nearly 70 percent among vernacular papers in AP in 1995. So, he had phenomenal clout in molding public opinion. He continued to extend full guidance and support to Mr Naidu, who over his nine years tenure, became highly influential both in AP and Delhi. Sri Ramoji never criticized Mr Chandrababu's policies of privatization, clandestine allotments of State largesses on Government to Government basis from the Singapore and Malaysian companies, and pivotal policies of the Government during his tenure as Chief minister. Sri Ramoji Rao has been the backbone of Chandrababu's

-8-

political life in the last three decades whether in power or in opposition. It is because of the patronage of Mr Naidu that Sri Ramoji could violate the RBI Act and AP Chitfunds Act and AP Agricultuiral land ceilings act etc with impunity. None of the Government departments of either the Central Government or of AP Government including the Income Tax deparment had courage to accept any complaint against any of the business ventures of Sri Ramoji Rao. The fact that the Dy Prime Minister of India and Union Defence Ministetr went to Mr Ramojis residence to persuade Mr Naidu not to withdraw support tio NDA Government in the wake of Gujarat riots, shows clearly what was the power and influence Sri Ramoji Rao has been holding on Mr Naidu. In a routine manner, all the TDP functionaries and Ministers would regularly call on Sri Ramoji Rao to be in his good books. Three National Parties viz the Bharatiya Janata Party, the Communist Party of India and the Communist Party of India (Marxists) had published different books on Sri.Naidus corruption and misuse of power as Chief Minister of Andhra Pradesh.

It is significant to note that Sri N. T. Rama Rao did not bequeath any property to his daughter Mrs. Bhivaneshwari. Also, Sri.Naidus parents were farmers in Chittoor District which is in the most backward region of the State (Rayalaseema) where there is no agricultural income surplus. a. Sri Chandrababu Naidu has inherited a meager extent of 2 Acres of agricultural land from his ancestral property by virtue of family partition before 1986 situated in his native village of Naravaripalle in Chittoor District. In an affidavit that was filed

-9-

by Sri Chandrababu Naidu on 30.6.1988 in W.P.No.7606/1988 after his family partitioned the property on 1.4.1986, it is averred by him that he sold his share of the land and bought lands in Nindali and Vakhyam villages of Nellore, from which his income was declared by him to be Rs.36,000 per annum. He reiterated in the affidavit that he was an agriculturist selling hybrid groundnut. b. The spree of amassing property by the Respondent No. 8 appears to have commenced in Nellore District. He purchased 65 acres of agricultural land through his family members at a low rate of about Rs.1000 per acre in 1985. Soon thereafter, a further 250 acres were purchased benami by Sri.Naidu in Sy. Nos. 19, 20, 119, 127, 129, 131, 132 and 138. The attendant circumstances around the transactions and the physical state of affairs in respect of the said property, as detailed hereunder, a detailed investigation into which would unearth the facts in regard to the same, clearly point out that the property is held benami by the Respondent No. 8 .

i. The sources of funds for the initial 65 acres, and the latter 250 acres are the same, i.e. Sri.Chandrababu Naidu. ii. The entire area of 315 acres, in a single stretch encircled by a single farm compound with a fence that runs 12

kilometers in one long stretch. iii. Electric pumpsets (carrying water for over 3 kms from Kaivalya river and 2 kms from Ravooru Lake) were applied for and obtained in Sri.Naidus name for the purposes of the entire land bank of 315 acres.

- 10 -

iv. On 25.08.2001, 4 transactions of large lands in these tracts took place involving Sri.Naidu and his son Lokesh, 2 of which were gifts, and 2 were sales. Such a large number of transactions to and fro are clearly suspicious and lend confirmation to the fact that benami transactions were abounding. v. Apart from the above, large numbers of transfers of the same lands at throwaway prices suggest severe evasion of regulations and of land ceiling and benami transaction law. e. Investigation would also reveal 2 major offences continuing as far as the lands are concerned; i. The lands include several Government lands and four large lakes, the occupation of which would inter alia attract the provisions of the Andhra Pradesh Land

Grabbing Act. It is also pointed out that it squarely violates environmental laws. ii. As many as 14 acres of the land have been assigned by the Government to Scheduled Castes & Scheduled Tribes but illegally appropriated by the 8th Respondent and members of his family. f. Subsequently, in 1992, Sri.Naidu promoted a company known as Heritage Foods (India) Ltd., which states in its Prospectus of 10.10.1994 that: During the period of 1983-88, Sri.Chandra Babu Naidu was not associated with any industry or business activity.

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g. When as Chief Minister of the State, Sri.Naidu made the declaration of his assets in 1999, it showed the value of about Rs.7.83 crores, a massive and inexplicable leap, keeping in view that his agricultural income had been declared only 10 years earlier as being Rs.36,000 per annum, and his income as an MLA was Rs.650/- per month and as Director of Heritage Foods was Rs.20,000/- per month. h. Subsequently, 2 more declarations were made by Sri.Naidu in 2004 and 2009, on the eve of general elections, where the valuations clearly exceeded Sri.Naidus known sources of income, and also omitted mentioning several other assets of his. Equally surprising was the exponential rise in the value of the assets of Sri.Naidus immediate family his wife who was operating Heritage foods and his son who was a minor.

i. The chart of

Mrs.Bhuvaneshwaris Respondent No. 9

holdings as per her husbands declarations of 2004 and 2009 would indicate the nature and quantum of riches accumulated during the period :

Description Shares of Heritage Foods Value of Shares of SCM Infra Developers Ltd. Value of Shares of SVEC Constructions Ltd

2004 19,24,893 NIL

2009 26,65,413 Rs.90.23 lakh

NIL

Rs.10 lakh

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Gold (in gms) Silver (in gms) Other assets Value of agricultural land Value of warehouse

966.70 8000 Rs.25.42 lakh Rs.10 lakh NIL

2779.61 32700 Rs.1265 lakh Rs.900 lakh Rs.1049 lakh

The acquisitions in property, which is arithmetically a few times over and above the earlier possessions, in the shortest possible span of business time and equal time spent in political pursuits by the family, clearly indicate that the sources of income which enabled such acquisition of assets are clearly illegitimate and defy an alibi of natural course of events. The possessions of the family continue earned and held during the period of time, continue the line adopted hitherto the family members of the Respondent No. 8 hold in trust, the possessions of the Respondent No. 8 benami while the Respondent No. 8 exercises all the rights of a true owner of such property and assets and the source of these funds being untraceable, it is clear that the said assets have been acquired from out of the illgotten earnings of the Respondent No. 8 who amassed wealth by abusing his official position and by his corrupt methods while being in power and authority, being the Chief Minister of the State. ASSETS OF SRI NARA CHANDRABABU NAIDU BETWEEN 1999 TO 2009 (Figures in Rupees) SR. NO. CATEGORIES OF ASSETS CHANDRABABU NAIDU 2009 2004 (As per the (As per the 1999 affidavit to affidavit to (Property Values) Election Election

- 13 -

Commission) 1 2 3 4 5 6 7 8 9 10 11 12 CASH DEPOSITS IN BANKS & NBFCs SHARES POSTAL SAVINGS & LIC PROVIDENT FUND MOTOR VEHICLES GOLD SILVER PRECIOUS STONES OTHERS INTEREST / CLAIMS AGRICULTURAL LANDS NONAGRICULTURAL LANDS COMMERCIAL & RESIDENTIAL BUILDS. HOUSE / APARTS. OTHERS INTEREST IN PROPERTY TOTAL 23,400 11,26,453 -1,000 -2,22,500 -----3,30,00,000

Commission) 27,594 4,94,372 -1,000 -2,22,500 -----30,00,000 46,016 1,28,361 1,20,77,280 --1,00,000 ---22,45,656 40,00,000 2,00,00,000

13 14 15

-8,89,75,000 -12,33,48,353

-1,20,78,000 -1,58,23,466

-1,50,00,000 -5,35,97,313

NOTE: Liabilities not included in the chart ASSETS OF NARA BHUVANESWARI BETWEEN 1999 TO 2009 (Figures in Rupees) BHUVANESWARI 2004 (As per the affidavit to Election Commission) 14,800 Rs.7,36,932 14,31,619 13,75,870

SR. NO.

CATEGORIES OF ASSETS

2009 (As per the affidavit to Election Commission) 32,200

1999 (Assets Details Only)

1 2

CASH DEPOSITS IN BANKS & NBFCs

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SHARES

17,02,12,426

16,70,57,430

11,23,100 shares Heritage & Rs.28,01,100 investments in others ---966.7 gms 8 kgs --10.23 acres @ Nindali 2.92 acres @ various places 650 Sq. Yards @ Panjagutta 0 32% in Sri Rama Agri Farm Not Available

4 5 6 7 8 9 10 11 12

POSTAL SAVINGS & LIC PROVIDENT FUND MOTOR VEHICLES GOLD SILVER PRECIOUS STONES OTHERS INTEREST / CLAIMS AGRICULTURAL LANDS NONAGRICULTURAL LANDS COMMERCIAL & RESIDENTIAL BUILDS. HOUSE / APARTS. OTHERS INTEREST IN PROPERTY TOTAL

--91,92,945 34,69,545 5,80,390 -12,65,37,192 9,00,00,000 0

---5,95,487 92,200 90,000 25,42,807 18,30,000 47,51,670

13 14 15

5,69,70,000 0 10,49,63,700 56,33,90,017

1,50,62,000 0 0 19,34,12,264

NOTE: Liabilities not included in the chart

ASSETS OF NARA LOKESH BETWEEN 1999 TO 2009 (Figures in Rupees) LOKESH SR. NO. CATEGORIES OF ASSETS Assets as of date as per the declaration of Sri N. C. Naidu 1999 (Assets Details Only) Rs.1,45,546 Rs. 12.26 lakhs

1 2

CASH DEPOSITS IN BANKS & NBFCs

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SHARES POSTAL SAVINGS & LIC PROVIDENT FUND MOTOR VEHICLES GOLD SILVER PRECIOUS STONES OTHERS INTEREST / CLAIMS

Rs. 284.83 lakhs

31,500 shares in Heritate & 6,25641 shares in others

4 5 6 7 8 9 10

Rs. 12.90 lakhs Rs. 8.76 lakhs

11

AGRICULTURAL LANDS

11.60 acres in Karnataka & Maharashtra excluding the gift of 5 acres of land from his grandmother in madinaguda, near HITECH City,

8.9 acres @ Nindali

12 13 14

NON-AGRL. LANDS COMMERCIAL & RESIDENTIAL BUILDS. HOUSE / APARTS. Rs. 2.36 crores 33% share in Sri Rama Agri Farm Not Available

OTHERS 15 INTEREST IN PROPERTY TOTAL NOTE: Liabilities not included in the chart

The compilation of the above chart including the details of the assets amassed by the Respondent No. 8 and his family members clearly indicate that the nature and value of their possessions could not be secured by known sources of income legitimately earned having regard to the modest beginnings of the family. The details of acts of official favours, nepotism,

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blatant misuse of official machinery and the consequential benefits conferred and received by private individuals and entities compromising public interest, revenues of the State, show that the assets amassed by the family of the Respondent No. 8 is out of the monies received by him as quid pro

quo for the conferment of doles and largesse to private individuals and entities. j . Investigation also needs to be carried out as far as Sri.Naidus mother Smt.Ammanammas transactions are concerned. Admittedly, the only

property that she inherited was 2 acres from Sri.Naidus maternal grandparents in Kuppam village. However, in 2000, she purchased 5 acres of land in Sy. No. 59 of Madinaguda Village of Hyderabad, from one Jasti Panduranga Vittal near Hitec City for Rs.40 lakhs and also a plot of 1,135 sq.yds. in the upmarket Banjara Hills area of Hyderabad for Rs. 35 lakhs..

k.

Exactly a year later, both pieces of property are gifted by Clearly, with no known

Smt.Ammanamma to Sri.Naidus son Lokesh.

sources of income for carrying out these huge purchases, these transactions are also benami by Sri.Naidu, using his mother for that purpose.

l.

The said property was sold to one Mr. J. Satyanaryana within one year

thereafter, who is the father of Ms. Sudha Saradha, W/o Sri Nagaraja Naidu. After such sale, the said Sri Satyanarayana gifted back the property to Ms. Sudha Saradha. The line and sequence of transactions and the close proximity of Sri Nagaraja Naidu with the family of the Respondent no. 8 would show that notwithstanding the ingenious, complex and convoluted route of transactions to erase any link to the family in respect of those assets,

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the property journeyed back to the benami possessions of the family of the Respondent no. 8. m. It is pertinent to mention that one Sri D. Ranveer was holding 19 acres

of land in Sy. No. 51 of Madinaguda Village out of which he sold 10 acres to Sri Bhaskara Rao and 9 acres to Sri Panduranga Vittal. Sri Panduranga Vittal, in turn sold five out the nine acres to Smt. Amanamma in the manner detailed above. n. Sri Bhaskara Rao in turn sold five out of ten acres to one Smt. Sudha

Sarada W/o Sri Nagaraja Naidu who later on sold the same to Smt. Bhuvaneswari W/o the Respondent No. 8. Thus the family of Respondent No. 8 owns 10 out of 19 acres in Sy. No. 51 of Madinaguda village and the entire extent of 19 acres is encircled by a wall and catered to commonly. In all the business initiatives of the family of the Respondent No 8, Sri Nagaraja Naidu is the crucial operator. He was a public servant before joining hands with the Respondent No. 8 in the loot of the States assets. He is a Director of all the group companies of the business initiatives of the

Respondent No. 6 including heritage group, nirvana group etc. 6. Other investments and assets of Sri. Naidu and his family a. On 19-10-1994, at the time of publication of prospectus of Heritage

Foods India Ltd., Sri Naidu as Managing Director has declared that he is not associated with any industry or business activity. But at that time, Sri Naidu promoted M/s. Bhuvaneswari Carbides and Chemicals Pvt. Ltd., and Bhuvaneswari Carbides and Alloys Pvt. Ltd., Both these units have borrowed from the banks and financial institutions, this fact was concealed in the prospectus deliberately.

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c. It is pertinent to note that the investment made by Smt Bhuvaneswari and Sri Lokesh in the year 1999-2000 continued till today in M/s. A 2 Z E multisoft Pvt.Ltd later changed the name as M/s Bizpro Technologies Pvt.Ltd, has not been declared in statement of assets and liabilities submitted to the Election Commission of India and State Legislature of Andhra Pradesh, a perjury liable for prosecution. d. It is a mystery as to how Sri.Chandrababu Naidu could promote a posh Three Star hotel in the most expensive area of Tirupati immediately after joining TDP in 1983. Nobody knows how he could mobilize the equity. He later sold this property to another TDP functionary, who was later made Kadapa ZP Chairman. 7. Rama Agricultural Farms a. In 1989, a family firm called Rama Agricultural Farms consisting of Sri.Naidus mother, wife, son and a relative of them named P.Dasaiah Naidu purchased 3.276 acres of land in Kondapur, at a distance of only half a kilometer from Hitec City, for Rs. 1,00,000 at a rate of Rs.30,487 per acre. The sources of these funds remain unknown. b. In 1996, an announcement is made by the Government headed by Sri.Naidu that an Infotech park called Hitec City would be established in the area abutting Kondapur. With this announcement, the value of the land held by Rama Agricultural Farms multiplies, providing substantial pecuniary benefit to the holders of the land.

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c. In the year 1995, Sri P.Dasaiah Naidu exited from Sri Rama Agricultural Farms as partner, but continued as Managing Director of the said firm. d. On 4.4.1998, a company named Dr.Reddys Laboratories gets a sales tax deferment of Rs.25 crores for 14 years from the State Government headed by Sri.Naidu. This itself is questionable as such exemption is given only to a new industry/Unit. Dr.Reddys was founded in 1984, and is an established, listed company on both the NSE and the NYSE with revenues of $1.67 billion. e. In the year 2000, 3.14 acres of land held in Rama Agricultural Farms is sold to one Sri.Satish Reddy, S/o. Dr. K. Anji Reddy of Dr.Reddys Labs and Smt. Deepti Reddy, wife of Sri Satish Reddy for more than Rs.3 crores, when the market price of the land was only about Rs.12 lakhs. The sequence of events of doling out exemption to a corporate entity and the family of the Respondent No. 8 entering into a sale transaction of the piece of land, at a value far in excess of the market price, would indicate that the monies to be paid as illegal gratification for the official favour, were disguised and paid as market value for the land by the corporate entity. f. This land is then developed by Sri.Satish Reddy with one Divyasree Soft Tech Realtors Pvt. Ltd., and a massive 5,00,000 sq.ft office space is built in a phased manner, which has now been leased to Google at a whopping of Rs.2 crore per month. This property is alleged to be the property of Sri

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Chandrababu Naidu held in the name of Divyasree Group as his benami. g. The Government then allotted an extent of Seven (7) acres of land in favour of a company belonging to the group of Divyasree Soft Tech Realtors Private Limited, under the guise of the State policy of allotment of land to software companies in the area of 600 acres earmarked for software development in Kondapur. Various ingenious methods were devised to ensure that the State Policy and the State largesse ends up in the hands of the private individuals and firms which have had transactions with the family of the Respondent No. 8. h. Sri Naidu who was the pivotal policy maker of the State when he was the Chief Minister selectively leaked the policy formulations of the State in advance for the benefit of individuals and private entities who are related to him. The site and location of infrastructural projects envisaged or potential sites for such development was leaked out to the firms and entities owned and promoted by Sri Ramoji Rao, Sri.Maganti Murali Mohan of Jayabheri Properties and the location and the extents of lands owned by the above named individuals/entitites and several others are the direct evidences in this regard. All such favours need to be examined and misuse of power amounting to loss of hundreds of crores of rupees to the innocent farmers and land owners ought to be suitably redressed.

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8. Sri.Nara Lokesh a. Sri.Nara Lokesh, the only son of Sri.Naidu studied in Hyderabad upto his intermediate education. He was a mediocre student and never had any scholarships to his credit, finally clearing his Science stream at the intermediate stage with just over 50%. However, Sri.Lokesh obtained his Bachelors Degree (1997-2000) from the prestigious Carnegie Mellon University and his Masters (2000-2002) from Stanford University in the USA. As Sri.Lokesh did not have the necessary grades, it was necessary for large endowments to be made to the Universities to consider him for admission. The amounts that were donated from unknown Indian sources were Rs.1o crore to Carnegie Mellon and Rs.12 crore to Stanford. There is reason to believe that these payments came from the accounts of Satyams Sri.Ramalinga Raju in return for the various benefits offered to him. b. Another unanswered question was the funding of huge educational and living expenses amounting to USD 240000 of Sri.Lokesh which were not reflected in the Income Tax records of any of his family including Sri.Naidu. c. Sri Nara Lokesh has no source of income even as a minor and subsequent to attaining majority in 2001 as evidenced by his IT returns. However, he acquired Lands at Nindali village in Nellore Dist of AP and near Bangalore and Mumbai worth of hundreds of crores, apart from the prime property gifted to him by his grandmother.

- 22 -

d. Sri Lokesh has been consistently increasing his stake in Heritage Foods India Limited from nil to 9%. He has substantial stake in holding and investment companies viz., Nirvana Holdings Private Limited, Nirvana power limited, Nirvana logistics and warehousing limited, Nirvana energy limited, Nirvana estates private limited, Niravana Packing private limited, Niravana media private limited, Megabid Finance and investments private Ltd, Heritage foods retail limited, Heritage onpro limited, heritage agro marine private limited, Heritage Fin Lease Limited, Bizpro Technologies Limited, Red Hill logistics and warehousing private limited and Heritage international limited, all of which are from unknown sources. e. Sri Naidu has evidently used his mother, his wife and his son to be the conduits of money laundering, and also to obtain benefits from the various corporate houses that he has favoured. Apart from these three family members among others, he has also utilized the services of several small time businessmen, in making them the recipients of State largesse and the benamis for his illegal transactions, rewarding them both financially and with posts in the TDP, apart from the prestigious Rajya Sabha seats for certain favourites. 9. Bhuvaneshwari Carbides c. In 1984, two companies were founded by Sri.Chandrababu Naidu and his wife. One was named Bhuvaneshwari Carbides and the other Bhuvaneshwari Alloys. Bhuvaneshwari Carbides was granted a loan of Rs.40 lakh from the Andhra Pradesh State

- 23 -

Finance Corporation (APSFC), which was secured by mortgaging 5 acres of land in Renigunta. It is unexplained as to why these lands in Renigunta were not mentioned in the declarations by Sri.Naidu or how he and his wife came to own the same. The loan was to be repaid in 8 years. d. In 1987, one Sri. Sridhar Chowdary was made the Director of both the companies, though it is unclear what Sri.Chowdarys professional qualifications were, and whether any business was being carried on by the companies at all. It would however be important to note that Sri.Chowdarys wife, Smt. Renuka Chowdary was a Rajya Sabha MP owing allegiance to the Telugu Desam Party for two terms from 1986 to 1998 and also the Chief Whip, Telugu Desam Party in Rajya Sabha for two terms. Despite the stewardship of Sri.Chowdary, the loan was not repaid to APSFC, which was an undertaking of the State Government within the 8 year period. There were no attempts by Sri. Naidus Government to recover the dues during the 2 stints enjoyed by Sri. Naidu at the helm of affairs. e. Suddenly and inexplicably, in 2001 while Sri. Naidu was the Chief Minister, a one-time settlement was entered into between Bhuvaneshwari Carbides and APSFC for a measly Rs.11 lakh (a quarter of the loan amount of 17 years ago), despite the fact that the land mortgaged to APSFC was worth about Rs.10 crores at the time. f. This is a glaring instance of the State machinery being directed to do the Chief Ministers bidding to benefit himself, and

- 24 -

continue owning and possessing the very valuable land at Renigunta. This also amounts to a blatant abuse of position by a public servant to cause pecuniary advantage to another, as well as swindling the State exchequer. 10. Heritage Infra Developers g. Heritage Foods and Heritage Infra Developers are 2 companies promoted by Sri.Naidus wife N.Bhuvaneswari and son Lokesh. Having common directors, it is these two companies that are primarily responsible for facilitating the wrongdoing of Sri. Naidu and in covering up his illegal transactions, including those involving money laundering and flow of foreign funds into the country. The modus operandi followed was to transfer assets of Heritage Foods (a widely held public limited company) to Heritage Infra Developers (a closely held private company) at throwaway prices, thereby circumventing

regulations to benefit Sri. Naidu and his family. h. In 1995, on behalf of Heritage Foods India Ltd., Smt. N.Bhuvaneswari ostensibly purchased 3 acres of land in survey Nos 56 and 57 in Kondapur area for Rs.12 lakhs, under 6 separate transactions of 0.5 acres each. This amounted to a payment of Rs.82/ -per sq.yd. In 2003, 1286 sq. yds. of this land was sold for 12.8 lakhs at Rs.1,000/ per sq.yd. i. In 2008, Heritage Foods sold the 3.23 acres in the same survey No., i.e. 56 and 57 of Kondapur area to Heritage Infra Developers for Rs.2.85 crores, at less than Rs.1700/- per sq.yd. This was in a stark and glaring contrast to the then land prices in Kondapur area that are not less than Rs.25,000 per square

- 25 -

yard. Interestingly, the actual land holding in this survey number by Heritage foods is only 3 acres but the company sold nearly Ac. 3.34 guntas. So, it is amply clear and evident that Heritage foods India limited grabbed the land and legalized it with the help of then Chief Minister none other than Sri. Naidu. j. In 1995, Mrs. Bhuvaneswari also bought 928 sq. yds. in Kothaguda village next to Hyderabad for Rs.1.38 lakhs on her name and subsequently in the year 2000, this land was sold to Heritage foods India limited for Rs.4.64 lakhs. However, inexplicably, the same land was sold in 2008 by Heritage Foods to Heritage Infra for Rs.92.90 lakhs. There are severe

discrepancies in the valuation of the lands, which is contrary to any corporate prudence. In any case, the subsequent transactions ensure there is no doubt as to the object of these exchanges. k. In 2008, after the various transfers of assets have taken place to Heritage Infra, 64% of its shares are sold for about Rs.3 crores to Srichakra Merchandising Pvt. Ltd., a company indirectly owned by one Sri. Yelamanchili Satyanarayana Chowdary alias Sujana Chowdary. l. Thereafter, Heritage Infra merged with Srichakra

Merchandising and changed its name to SCM Infra. The lands of the company are then mortgaged in June-July 2008 by SCM Infra with Maharashtras STATE OF INDUSTRIAL &

INVESTMENT

CORPORATION

MAHARASHTRA

LIMITED (SICOM LTD) toward a loan of Rs.45 crores. It is significant that the land which only earlier in the year was

- 26 -

accepted by Heritage Foods to be worth a little more than Rs.3 crores was the only security for the loan, and this land was valued at a whopping Rs.85 crores. It is also important to note that this loan which is a debt of the company is given partly to Sri.Sujana Chowdarys Sujana Towers limited and partly to SCM Infra. m. The possibility of coincidence gives way to criminal concert and deliberate design when it is considered that very same Sri.Sujana Chowdary is a sitting TDP Rajya Sabha MP, against whom there are several other cases pending as well. Sri. Naidu and Sri. Chowdary are close associates, often photographed travelling abroad together to raise funds for the party. It is submitted that Sri. Chowdary owns nearly 100 companies, most of which are sham, and are merely conduits for the passing of hawala money, that not only partly fund the election expenses of the TDP, but also the lavish lifestyles of its leaders. n. It is submitted that the transactions between these companies were so timed to ensure the influx of funds in the run-up to the Andhra Pradesh Legislative Assembly Elections in May 2009. Importantly, shortly after this transaction, Mrs. Naidu resigned from the company as director. The money that came in cash from Sujana Chowdary was for campaign funding, which was used in the May 2009 elections. o. There exists evidence of 20 companies belonging to Sri. Sujana Chowdary which received large amounts from abroad, which were followed by cash withdrawals at the time of the 2004

- 27 -

elections. It is obvious that the same methods were utilized for the 2009 elections as well. p. There are several ingenious ways and means adopted by Sri. Naidu to launder his money through Sri.Chowdary and his group companies. Sri.Chowdary first established a slew of companies to bring Sri.Naidus money under the corporate umbrella. Sri.Chowdary created circular transactions among his corporate entities, thereby orchestrating Purchases and Sales entries running into thousands of crores, so that funds could be moved through books of accounts very effectively and without attracting income tax provisions. However, in the process, Sujana Group was forced to face many Excise and Sales Tax cases. Due to the habitual nature of the Group, these cases are litigated at various stages of the appellate legal process. A cursory glance of the modus operandi given below would give more insight to the scheming and structuring of the total money laundering operations. q. The Total Turnover of Sujana Group companies having manufacturing facilities - Sujana Universal Limited and Sujana Metals Limited (the flagship companies of the Group) - for the financial year 2008-09 was Rs.2149.33 Crores. On the other hand, the group companies which indulged in circular operations involving only trading of Steel Produced by group flagship companies amounted to Rs.4639.38 crores. A perusal of Purchases and Sales and Net Profit given below, shows the clandestine operations indulged by the Group:

- 28 -

NAME OF THE COMPANY

PURCHASES (Rs. IN CRORES) 542.28 457.05 194.92 320.97 479.16 565.90 327.82 325.62

SALES (Rs. IN CRORES) 545.10 462.88 190.96 326.61 456.83 567.92 333.39 327.71

TEJASWINI ENGINEERING PVT LTD FUTURETECH INDUSTRIES LIMITED HANDUM INDUSTRIES LIMITED GANGA EXIM PRIVATE LIMITED GANGA INDUSTRIAL CORPORATION LIMITED OMICRON BIO-GENESIS LIMITED ENDEAVOUR INDUSRIES LIMITED GODAVARI EXPORTS AND IMPORTS PRIVATE LIMITED GLOBAL FORGINGS LIMITED TEJDEEP ENGINEERING ENTERPRISES PVT LTD VICTORIA STEEL ENTERPRISES LIMITED GLADE STEEL PRIVATE LIMITED TOTAL

NET PROFIT (Rs. IN LAKHS) 30 44 (-)534 24 (-)2137 59 67 83

638.28 366.59 401.12 7.51 4627.22

648.80 371.37 400.12 7.69 4639.38

14 16 16 25 378

FUNDS MOVED THROUGH THE BOOKS OF ACCOUNTS FOR THESE COMPANIES FOR THE SAME YEARS WERE AS FOLLOWS:

Name of the company Share

Inflow of funds RS IN CRORES

Out flow of funds RS IN CRORES

Share Unsecu Capital Applic red loans ation money

TEJASWINI
FUTURE TECH INDUSTRIES

Funds from Debtors

Total

Funds paid to
Creditors

Advan Other Total ces

21.51

30.04

376.00

427.55

420.24

5.98

426.22

16.45

90.02

23.53

341.14

471.14

362.00

48.45

65.58 476.03

- 29 HANDUM
INDUSTRIES

0.71 4.43 37.79

292.70 281.34 446.73

293.41 285.77 484.52

269.24 297.97 316.55

25.70 294.94 297.97

GANGA EXIM GANGA INDUSRI AL CORPN LTD OMICRO N BIOGENESIS ENDEAV OUR INDUST RIES
GODAVA RI EXPORTS AND IMPORTS

115.52 52.46 484.53

14.00

89.04

497.30

600.34

520.15

75.46

4.41

600.02

16.49

268.30

284.79

284.72

284.72

19.48

19.65

298.80

337.93

295.58

16.09

13.05 324.72

GLOBAL

36.58

30.44

405.00

472.02

396.58

70.05

0.44

416.07

FORGIN GS
TEJDEEP

13.43

36.29

303.67

353.39

334.48

10.84

4.59

349.91

ENGINE ERING VICTORI A STEEL ENTERP RISE GLADE STEELS 13.45 36.09 356. N40 405.94 309.56 93.06 3.39
406.01

0.23

8.40n

8 . 6 3
4425.43

8.60

8.60

TOTAL

435.45

4369.74

- 30 -

As against the physical moment of funds of Rs.4425.43 crores on the face of the Balance Sheet, an amount of Rs 435.45 crores was shown as withdrawn as advances. Ostensibly, 2009 elections were funded by Sri. Naidu using the vehicle of Sujana Group and making Sri. Chowdary the beneficiary of the coveted MP post. Sri Chowdary, continued his nefarious activities, setting up the entities even outside India. He used the taxhavens of the Cayman Islands, Mauritius, Hongkong and Dubai for this purpose. The money laundering operations have used the Invoice Financing Facility route, which is in vogue for such kind of operations. r. The modus operandi used by Sri. Chowdary for the quid pro quo beneficiaries of Chandra Babu Naidu Government, has been to accept the tainted money in those countries and in return, invoices would be discounted by the banks/financial institutions in Cayman Islands, Mauritius, Singapore, Dubai or Hong Kong and the monies would be remitted to India as export income and funds would be withdrawn as narrated in the paragraphs mentioned above.

NAME OF THE COMPANY

PURCHASES RS IN CRORES 350.99

SALES RS IN CRORES 352.02

PAC VENTURES PTE LTD.,SINGAPORE NAUNCE HOLDINGS LIMITED, HONGKONG

NET PROFIT RS IN LAKHS 51

71.74

72.83

20

- 31 -

s. The following are some of the cases registered against the Sujana Group: 1.Directorate of Revenue Intelligence, Chennai and Vizag: Notification 53/97, dated 03.06.97 and Order No. 01/2008 dated 16.12.2008 Duty and Penalty: Rs.27.10 Crores. 2. Asst. Commissioner of Central Division VI, Customs and Central Excise, Hyderabad. Notice V/7215/116/98, ADJN dated 31/07/1998 Penalty : Rs.67.49 Lacs. 3. Asst. Commissioner of Central Division VI, Customs and Central Excise, Hyderabad. Notice V/7215/7/200 ADJN dated 3/3/2000 Penalty: Rs 12.24 Lacs. 4. Development Commissioner, Vizag SEZ order No 8/EOUS/ADJ/QPR-242/VSEZ/2005/68 dated 04.01.2006 Penalty: Rs 100 lakhs 5. Commissioner of Customs and Central Excise Hyderabad-1 Order No.SCN92/2008/25.06.2008 Order No. 04/2008 dated 25-6-2008 Tax and Penalties: Rs.10.20 Crores 6. Additional commissioner of Customs and Central Excise, Hyderabad-1 Order No. SCR OR No.89/2008 Hyderabad-1 ADJN, Duty and Penalty: Rs.68.41 Lakhs 7. Dy.Commissioner, Panjagutta Commercial tax order Penalty: Rs.5.22 crores 8. CTO Srinagar colony, for assessment year 2003-04 Penalty: Rs. 4.93 crores

- 32 -

9. CTO Srinagar colony, On Deemed export turnover for FY 2002-03 Penalty: Rs.49 Lakhs 10. CTO Srinagar colony for AY 2004-05 Penalty: Rs.Rs.5.16 crores 11. Fraud case in respect of MoU with NAFED under investigation of CBI for Rs.43.46 Crores for duty evasion. In light of the above prima facie evidence of money laundering by Sri.Chandrababu Naidu through the Sujana group of companies, necessary directions are prayed to be issued to Sri Yalamanchili Satyanarayana Chowdary, Chairman of Sujana group of companies to submit to the High Court all the bank statements since 1995 till date in order to facilitate further investigation. 11. Krishna Godavari (KG)Basin

t. The Krishna-Godavari basin is home to one of the most lucrative gas deposits in the world, as was discovered in 2002, and estimated to be almost 40 times that of the Bombay High basin. While the basin is located in the State of Andhra Pradesh, the Government under Sri.Naidu chose to turn an obliging blind eye to its rights to the discovery on its soil, while allowing Sri.Naidus close associate Sri.Ramoji Rao to be the vehicle of the quid pro quo. In fact, there was also a note/letter to Sri.Naidu by the senior officers of the Government cautioning him that the State of AP should also bid for the gas by forming a company like Gujarat had done. This piece of advice was wholly ignored by Sri.Naidu. In the process of exploring gas reserves in KG basin, Reliance industries indulged in many

- 33 -

violations by hindering fishermen and polluting large extent of waters which caused unaccountable damage to environment and marine life. Instead of defending the rights of local people and protecting the environment, Sri. Naidu kept a blind eye and even encouraged Reliance group of Industries with heavy exemptions and incentives. u. Sri.Ramoji Raos company Margadarsi Financiers had fallen on hard times in the year 2007 when its irregularities and violations became public. Subsequently a committee of enquiry was constituted by Govt. of AP which revealed that Rs.2,600 crores of money was collected from public by violating Reserve Bank of India norms and regulations and it was declared that it was impossible for the company to repay its several depositors. Despite the fact that almost all of Sri Raos companies were in severe financial difficulties, Sri Rao surprisingly offered through the news media to repay the full amount of Rs.2600 crores due to the depositors. This was followed by an assurance by him to this Honble Court following which the amount due was repaid. A large portion of amount of so called deposits accounting to nearly Rs.275 Cr was declared as unclaimed initially. The same is deposited with the Union Bank of India in an escrow account. v. In consideration for the favour done by the Respondent No. 8 in allowing the States K.G.Basin claim to be brushed under the carpet, the Reliance group facilitated the payout of Sri Ramoji Raos debts to his depositors. This was carried out through known associates and friends of Sri Mukesh Ambani.

- 34 -

w. Two of these known associates of Sri. Ambani and the Reliance Group are Sri.Nimesh Kampani and Sri.Vinay Chajlani. x. Sri.Nimesh Kampani extended himself in ensuring that Sri.Ramoji Rao would be bailed out. Within a short span of 37 days between December 2007 and January 2008, six shell companies were floated on three addresses, which are shown as Sriram Mills Compound, Worli, which is the official address of Reliance Industries Limited. Reliance diverted Rs.2604 crores of its shareholders money through the shell companies to Ms.Kampanis Equator Trading India Limited and

Sri.Chajlanis Anu Trading.

y. It is inexplicable that within 23 days of the very company Equator Trading India Limited being registered, Sri.Ramoji Rao entered into an agreement with that company, which had no known expertise or business. Several documents were also submitted to the Registrar of Companies regarding these transactions. Of the Rs.2604 crore of Reliance money diverted through shell companies, Rs.1,454 crore was routed through Equator Trading, while Rs.1,150 crore was through Anu Trading. Despite Sri.Ramojis Ushodaya Enterprises having incurred a loss of Rs.59.19 crore, these companies purchased its Rs.100 shares at an astronomical premium of Rs.5,28,630 per share. Form 2 dated 30.1.2008 filed by Ushodaya Enterprises with ROC shows shares allotted to Equator Trading Enterprises Ltd at a premium of Rs 5,28,630 per share. The curious part of

- 35 -

the valuation exercise that preceded this grand purchase was that a library comprising film rights of the telugu movies in which thespians like Sri N.T. Rama Rao and A.Nageswara Rao among others acted, was shown as an asset of Ushodaya Movies one of the proprietary concerns in the HUF of Sri

Ramoji Rao at Rs. 1200 crores. The said proprietary concern had a carry forward loss of around Rs. 1200 crores and the asset was shown as having been sold to Ushodaya Enterprises Private Limited, and shown as an asset of Rs. 1200 crores in the Company which was factored in while valuing the enterprise value of the said Company, leading to a buy-out of a stake at a an astronomical premium unheard of in commercial history in the country. The twin advantages of the above operation are that Ramoji Rao HUF in which Ushodaya Movies is a proprietary concern, had the accumulated losses set off by the profits shown in the transaction of sale of film rights to the Company and the Company had swollen its asset base, which is notional, in the form of rights in respect of those movies, which have been taken into consideration for arriving at the enterprise value of Ushodaya Enterprises Private Limited at Rs. 6500 crore. No dividend has been declared by the above Company which is valued to be flourishing and it is a sham transaction which is not imbued by considerations of gain and commerce and it is clear that the laundered money has been infused to protect the interests of Sri Ramoji Rao.

- 36 -

z. The following issues arise for consideration having regard to the unnatural course of events leading to Ushodaya Enterprises being bailed out of its financial constraints in complete defiance of commercial prudence and established market practices : i. The interest shown by Reliance group in coming to the rescue of Ushodaya Enterprises headed by Sri Ramoji Rao, whose proximity to the Respondent No. 8 and his

family is well-known, so as to impel it to invest in a loss making firm of Ushodaya Enterprises is clearly in defiance of any prudent profit-based corporate entity.

ii. The conduit for the above act of altruism shown by Reliance since as per market norms, Reliance does not get gain any returns by virtue of that investment.

There is no doubt, that just as has been discovered in the 2G Spectrum Scam case, that the above was a payoff by Reliance towards non-interference / non participation in the bidding process by the Government of AP in the KG Basin issue. Undoubtedly, Sri Naidu was a monetary beneficiary as well, and it is these funds that also have permitted him and his family to acquire such vast assets amounting to several hundred crores. The flow chart of funds evidencing the trail of money is depicted below.

- 37 -

- 38 -

The above structure has been designed in such a manner that it can be dismantled at any point of time to enable Sri.Naidu to acquire control over the Special Purpose Vehicle companies without any further investment and loss of time. This enables Sri.Naidu to protect his vested interests in media in Andhra Pradesh in order to serve his political and financial interests.

aa. Reliance Industrial Investment & Holdings (RIIHL) is a 100 percent subsidiary of Reliance Industries. RIIHL is the vehicle through which 10.47 crore (6.66 percent) treasury shares of RIL

- 39 -

were held. The RIL Annual Report 2007-08 shows RIIHL as a 100 percent subsidiary. The shareholding pattern of RIL for December 2008 shows the shareholding of the Petroleum Trust. The Petroleum Trust through the Trustees for the sole beneficiary M/s RIIHL owning 6.66 percent. Since then Mukesh Ambani has extinguished the treasury stock through a complicated buy back. RIIHL held the treasury stock through the Petroleum Trust and Sri. Kampani was the Trustee of the Petroleum Trust. The scheme of Merger of Reliance Petroleum Ltd and Reliance Industries Ltd., of 2002 shows the provisions of the Trust created for five years. bb. On 9.12.2004, the newspaper Business Standard reported that Petroleum Trust was not part of the promoter holding in RIL. It said - Following the amalgamation of Reliance Petroleum with RIL, the shares of RIL were allotted to the trust. RIIHL, being a 100 percent subsidiary of RIL could not hold the shares of the parent company under law. So, the Petroleum Trust was created to house the newly created shares of RIL after the merger. But since the property belonged to RIIHL, it was named the sole beneficiary, implying that all the financial benefits arising out of the ownership of RIL shares would flow to RIIHL. cc. When the merger was announced in April 2002, it was stated by then RIL M.D. Anil Ambani that 12.2 percent (7.5 percent then held by the Trust and 4.7 percent held by RIL associate companies) would be sold to strategic investors, financial institutions or overseas via ADRs or GDRs in five years. The two trustees of the Trust were Nimesh Kampani and

- 40 -

Vishnubhai B Haribhakti. But the BSE continues to show the Trust holding as part of promoter holding. dd. A whole host of intermediary companies ensured that the money trail would be obfuscated, but it cannot be hidden, because as per Government of India norms, all transactions are recorded with the Registrar of Companies. ee. The Form 2 dated 30.1.2008 filed by Ushodaya with the RoC shows shares allotted to Equator and premium of Rs.5,28,630 per share paid. Ushodaya is the holding company of Sri.Ramoji Rao. Prior to the deal with Kampani, he owned 99.86 percent of Ushodaya. ff. An additional advantage to Sri.Ambani is that he has now achieved a major foothold in the powerful regional media of Sri. Ramoji Rao, which is important for the purpose of his public relations campaign, especially in light of recent media revelations about the KG Basin. gg. It is interesting to note that the balance sheets of Ms.Ramoji Raos companies (including Ushodaya Enterprises Pvt. Ltd.) show continuous losses for nearly 2 decades, which almost crosses Rs.1200 crores. In addition Land Ceiling litigation has been initiated against Sri.Ramojis companies, concerning 1500 acres of allegedly excess land held by him. As a result, even the land will have no value to a potential investor. Yet, Reliance along with Sri.Kampani and Sri.Chajlani chose to pay stratospheric and unrealistic amounts in order to acquire shares of these largely sick and dormant entities.

- 41 -

hh. Also surprising is the fact that as much as Rs.275 crores of depositors money in an escrow account of Sri.Ramoji Raos remain unclaimed. Clearly, all the depositors would have made claims for the amounts due to them, and be still awaiting the same. However, in the circumstances, there is no doubt that almost all this amount belongs to Sri Naidu, which he is deliberately not seeking to withdraw as this would result in the income source of his assets being questioned. This conclusion is supported by the fact that Sri Ramoji Rao filed an affidavit in court with a list of depositors and the amounts deposited, but out of that list, it is not made clear as to who have not claimed the amount. He refuses to divulge those details, despite there being enough safeguards to protect them. It is obvious that many of the people on that list are benami. The flow of money to Margadarsi Financiers from the day one to the day end has to be investigated. It can be said that many of these deposits are bribes received by Sri Naidu and had chosen the route that cannot be verified by the Reserve Bank of India or the government institutions. It is therefore submitted the entire deposits to Margadarsi Financiers are to be investigated in the lines of serious fraud and misuse of power. ii. It is also important to note that, the private urban co-operative banks in Andhra Pradesh had faced severe malicious campaign by Sri. Ramojiraos Eenadu newspaper and the Govt. of Andhra Pradesh headed by Sri. Chandrababu Naidu. Sri Naidus Govt. took several steps to weaken the urban co-operative banks in the name of protecting depositors interests, where as the

- 42 -

original idea is to assure the flow of funds to Margadarsi financiers, contrary to the urban co-operative banks which is not a legal entity. 12. The Shamshabad Airport jj. Between 1997 to 2001, in Palmakole village just adjoining Shamshabad, Margadarsi Chit fund private limited (a company in which Sri.Ramoji Rao and his family members were partners), along with many of Sri.Ramoji Raos employees with as low income as Rs.10,000/- p.m. bought a huge extent of 360 acres of land, when the market value was just Rs.50,000/-. As agricultural land ceiling was in existence, it was not possible for a single individual to hold large tracts of this land. Sri.Ramoji Rao bankrolled the transactions entered into by his employees in order to facilitate this single piece of land to be transferred. kk. The fact that this land was purchased at ten times its market price ought to have been enough to arouse the suspicion of the authorities. Shortly after the purchase, Sri.Naidu directed the Government to grant permissions to the benami holders to convert their land to non-agricultural purposes, thereby avoiding the application of the ceiling law in regard to agricultural holdings. ll. Immediate upon conversion, all the various pieces of land were sold to Sri.Ramoji Rao at almost the same price1. For example, there were as many as 10 transactions in the name of Sri.Kolli Bapineedu Choudhary (now Vice President of Ramoji Film City), but not a single land stands in his name now. Sri.Naidus

- 43 -

role during the period has to be examined not only because of his silence during his regime on the huge land banks of Sri.Ramoji Rao amounting to nearly 2500 acres in the State capital, but also in facilitating clearances and favours from the State Government to Ramoji Film City. This is a matter of conspiracy against public interest and a blatant concentration of wealth at their cost. It is strange that one of the oldest and respected of national dailies the Hindu - has more or less the same circulation as that of Sri Raos Eenadu and is running with little or no profit margins, Eenadus owners accumulation of huge wealth is a matter of concern, as there are no other sources of revenue, with all his other companies suffering severe losses for over 2 decades now. This must be thoroughly investigated to ascertain the benefits heaped on Sri.Ramoji Rao when Sri.Chandrababu Naidu was the Chief Minister. mm. Sri. Naidu, as Chief Minister had shortlisted 2 locations

for the new airport, which were Shamshabad and Ibrahim patnam. Both locations would be of unique benefit to one person who was Sri Naidus close friend Sri Ramoji Rao. Adjoining Shamshabad, Sri.Ramoji Rao now owned 360 acres as outlined above, and in Ibrahimpatnam he already held 1800 acres where his Ramoji Film City was located. nn. In 1998 , Sri.Naidu announced Shamshabad as the location for the airport. The G.O. formalizing the same followed shortly thereafter in 2003. With this announcement, the value of the land in Palmakole became almost Rs.20 lakh/acre, which was 4 times at which Sri. Ramojirao bought. As of now, the land is

- 44 -

worth about Rs.3 crores per acre. Hence, Rs.18 crores spent by Sri.Ramoji Rao then has now become Rs.1080 crores, by virtue of the decision of the Government headed by the Respondent No.8 to locate the airport at Shamshabad. Wastage of public money, favouring his own people and treating new and giant projects as milking cows of political corruption are the three dimensions in Sri Naidu announcing the Shamshabad Airport. Sri Ramoji Rao had started banking of land in the State Capital in the name of constructing Film City. Naidus Government accepting such a huge land banking on the name of Film City, and subsequently trying to build another airport near to two huge land banks of Ramoji is showing the biggest land cum power scandal in the entire history of the nation. One can note that there is no need of constructing such a huge international airport with the private participation and allotting 5500 acres of government land, by shutting down the government owned airport in the heart of the city. oo. Not only has a policy decision been dictated by the personal benefit for an individual, but this has involved a conspiracy to cheat the State for the profit of Sri.Ramoji Rao and the policy decisions of the State were manicured to suit the personal benefits and possessions of Sri Ramoji Rao.

pp. The other dimension of their relation is to be enquired. The Entire episode of Margadarsi Financiers hasbeen challanged on the technical grounds, that is whether Ramoji as HUF has any right to take the deposits from the public. It is also important to

- 45 -

note that these deposits were never verified before 2006, and genuineness of these depositors has not been verified. CBCID of Andhra Pradesh had verified and found that majority of the depositors are fictitious. It is clearly evident that the quantum rise in the deposits significantly during 1995 to 2004 in

Margadarsi Financiers when Chandrababu was the chief minister indicates the fact that the ill-gotten money of Sri Chandrababu Naidu earned through ingenious ways has been routed through in the fictitious names to Margadarsi Financiers. In the absence of any controls, investigations, verifications by RBI, Union Government and State Government the ill-gotten money was safely parked with Margadarsi Financiers. This is precisely the reason why Sri Ramoji has consistently been refusing to divulge the details of unclaimed depositors in Margadarsi Financiers. The funds in the escrow account created in the Union Bank of India is a clear proof of the unholy nexus, quid pro quos defeating public interests and loot which can be established by further probe. 13. Hitech City qq. In 1996, one Sri. Maganti Murali Mohan of Jayabheri Properties / MM Financiers purchased 2.34 acres in the village of Gachchibowli. These purchases were made for a total consideration of Rs.10 lakh. Sri.Murali Mohan is a close friend and associate of Sri.Naidu, who was then the Chief Minister of the State. Shortly thereafter, Sri Naidu announced the Hitec City Project, which was to be coincidentally located in the villages of Kondapur, Gachchibowli and Madhapur.

- 46 -

Immediately thereafter, the prices of the lands in those villages rose dramatically, which was taken advantage by Sri.Murali Mohan who entered into several Development Agreements (8 projects) between 1996 and 1997 around Hitec City. Sri Naidu showcaused the internationally reputed IT/Software/ ITES companies by allotting approximately 1/3rd of 645 Acres in Sy.No.65 of Madhapur area fuelling escalation in real estate prices and grabbed the rest of 2/3rd land through a slew of fictitious / benami paper companies at his behest. The very fact that most of these companies were Non IT/ software objective based companies and very few of them just start up Software companies incorporated with the sole intention of getting the land and other tax benefits from Government of Andhra Pradesh lends credence to the fact that Sri Naidu benefited from the same. In all these allotments, Sri Naidu either received illegal gratification in the form of cash or end beneficiary through Sri Maganti Murali Mohan and others. For instance, companies floated by one Sri.Valluripalli Nagarjun in several names like Valluripalli Agrotech and Arjun Computers and Software got the lands from the government agencies for throw away prices. After getting allotment, some of the said companies transferred the lands to Murali Mohan and his group companies. rr. The Hitech City Project was first announced in 1996 initially for 600 acres, to be developed in a 3-phased manner. Bids were invited for the project, and even though the bid of M/s. Larsen & Toubro Ltd., (L&T) was higher by more than Rs.500 crores,

- 47 -

the same was accepted by the Government headed by Sri Naidu. In addition, L&T benefitted from the munificence of the State by getting as much as 150 acres of the land for itself. ss. The Project is fashioned as being developed by L&T through its Special Purpose Vehicle, L&T Hitech City Limited, a joint venture company of L&T Infocity Limited and Andhra Pradesh Industrial Infrastructure Corporation Limited. The L&T Infocity is the first software technology park layout in Hitech City, which attracted some of the major information

technology companies like Accenture, Microsoft, Oracle, Dell, Motorola, Deloitte, HSBC, GE and Convergys. What is

important to note is that several plots were sold to infrastructure companies ostensibly to enable faster delivery to the customer companies. In this, these middlemen have also profited at the cost of the people of Andhra Pradesh and severe losses have been suffered by the State. Some of the instances of such abuse of state largesse are: iii. The sale of plots between 1000 sq. yds. to 110 acres being made to relatives and associates of Sri Naidu. iv. 7 acres of land were given to Divyasree Soft Tech Realtors Pvt. Ltd., which, as submitted above, already had a close personal and political nexus with Sri Naidu. The very fact that Divyasree dictated the price at which the purchase would be made suggests certain underhand dealings with Sri Naidu. v. Meanwhile the Government of Andhra Pradesh in the year 2001, through G.O.Ms.No.538 dated October 28,

- 48 -

2001 announced a plan to add another city to the Twin cities namely Cyberabad. A Cyberabad Development Authority was created for this and 51.70 sq.km of land came under this authority. This authority got the powers of imposing more betterment charges and strict guidelines regarding constructions in that area. The astonishing fact is that the Kondapur area which is in the center of Cyberabad Development Authority plan is not included in this plan merely because Sri Naidu, Sri. Muralimohan and their friends had lands in this area and they subsequently built huge buildings on the said lands without paying the charges which are being paid by remaining areas of CDA. This caused huge losses to the Government exchequer and the real beneficiary of this is the then Chief Minister Sri Naidu himself. tt. Sri.Murali Mohans Jayabheri properties and Sri.Naidus family have large properties in Kondapur which are all exempt from the Governments betterment charges at the instance of Sri Naidu. Despite the fact that all other lands around have severe restrictions, the isolated tracts in Kondapur village occupied by these entities have been exempted without any rationale. This in itself shows the misdeeds of Sri Naidu in indulging in malfeasance, favouritism and embezzlement. 14. Power Producers Scam The Government of Andhra Pradesh, with a view to overcoming the power shortages that the State was facing in 1994, on the basis of a report of Sri Hiten Bhayya, a former

- 49 -

member of the Planning Commission of India, decided to promote in the private sector several projects, as short gestation power projects, that were expected to be completed within 24 months from the date of signing the PPAs. The global competitive bids were invited when Mr. NTR was the Chief Minister. In the mean time, on 1st September 1995, Mr Naidu became the Chief Minister, who entrusted the job of evaluation of various bids received in the global competitive bids to ICICI. The ICICI had carried out a detailed evaluation of the bids and awarded marks seperately for the (a) background of the promoters, (b) background of the EPC contractor, (c) location (d) financial closure support certificates and (e) schedule of implementation. So the entire evaluation was highly promoter specific and EPC contractor specific. The State Government signed PPAs with six developers for implementation of 8 short gestation power projects on 31-03-1997, with the last of the projects to come up within 24 months from the date of signing of PPAs i.e. on or before 01-04-1999. Wheat happened later is that Mr. Naidu permitted virtual sale of the projects by bargaining with each of the promoters with whom the PPAs were signed and has given his consent for change of the promoter, change of the EPC contractor, change of the fuel and change of the due date for implementation several times. None of the projects were implemented even after the five years from the first due date. None of the original promoters of any these projects continued to be the actually implemented projects, thus making the entire process of the global competitive bids a big mockery only with a clear design to personally benefit financially by allowing concessions and changes to PPAs to the disadvantage of the State Government. The opposition Parties raised this issue several times both inside and outside the Assembly without any avail. Same is the case with the two gas based projects viz GVK and Spectrum, which were allowed huge increases in capital outlays to the utter disadvantage to APSEB and much

- 50 -

against the then prevailing industry norms. The State Government itself implemented in October 1997 a 174 MW combined cycle gas base power project at Vijjeswaram for Rs.474 Crores i.e.at Rs.2.72 Crores per MW. What is shocking is that Mr. Naidu, by collecting huge monies, allowed a capital cost of Rs 875 Crores to Spectrum Project @ Rs 4.20 per MW and Rs.925 Crores for GVKs 216 MW project @ Rs4.28 per MW. Both these projects have come up around the same time as that of the Vijjeswaram Project. This was a huge loss to State Government. Despite the entire Opposition raising hue and cry the capital cost increases to these projects could not be stopped because of the personal interest of Mr Naidu. If it was a genuine mistake, Mr Naidu would have easily corrected this blatant hike. He did not do so because of the money he allegedly got from the promoters. In fact, based on a complaint from

APTRANSCO, the CBCID is probing the hike in the capital cost of SPECTRUM. uu. The whole issue therefore has to be entrusted to CBI for a thorough probe. vv. As part of allowing the change of promoters for short gestation projects, Mr Nadu, clearly with a view to doing favour to his colleague in TDP and a major fund raiser for that party allowed change of promoter of Konaseema Oakvell Project in favour of Sri M V V S Murthy, a TDP MP from Visakhapatnam. The Government of Andhra Pradesh originally had agreement with Singapore based OAKWEL group as a barge mounted project using furnace oil as fuel. With a view to benefitting Mr Murthy, Mr Naidu not only allowed change of status from barge mounted to land based project but also unilaterally allowed change of promoter from OAKWEL to Mr Murthy and also the change of fuel and schedule of implementation by more than

- 51 -

three years for a project that was already delayed by five years. Later they formed a new entity named Konaseema gas power limited. It is argued in the Legislative Assembly by the then opposition congress party that the whole episode is illegal and against the norms laid by Govt. One Sri M.V.Mysoora Reddy who was an MLA of Congerss Party now turned as Telugu Desam Partys MP openly alleged that Big Boss got all the money in Konaseema power issue. Every one concerned with this issue knows that the said Big Boss is none other than Sri. Chandrababu Naidu, the then Chief Minister of the State. This Konaseema gas power limited is owned by Sri Naidus close aide Sri. M.V.V.S.Murthy, who was also a MP of TDP. Interestingly a prime area of 80 acres of land next to the sea in Visakhapatnam was allotted to Sri M.V.V.S.Murthys

GITHAM University by then Chief Minister Sri Naidu at a throwaway price of Rs.18,000/- per acre. ww. Towards these favours done by him, many of the owners

of the power projects have made payments to Sri Naidu in cash, which have been either routed to land purchases which are all traceable to Sri Naidu or to Sujana Group Companies held in Mauritius, Cayman Islands and Dubai laundering of the same takes place. 15. NTR Memorial Trust xx. On 15.2.1997, the NTR Memorial Trust was founded, with the Chief Minister Sri Naidu as both the Settlor and the Trustee, and Sri Seetharamaiah (his auditor) and Sri D.Srinivasa Rao (Member, TDP) as the other Trustees. Ostensibly the object of through which the

- 52 -

the Trust was charitable in nature. It is to be understood in no uncertain terms that although NTR Trust is registered as a Public Charitable Trust, Mr Naidu has absolute strangle hold on the organization. The Trust holds highly valuable real estate and other projects, all of which can become the private empire of Mr Naidu as the present Members of the so called Public Charitable Trust are Mr Naidu, his wife and his auditor, who has no personal stake. yy. Within a few months, this Trust applied to the Government for allotment of land, which was granted by Sri Naidu with alacrity. As a result, a piece of land in the prime area of Banjara Hills admeasuring 4000 sq. yds. was granted to the Trust on a 30-year lease on a nominal lease/rent. The G.O. issued in this regard made it clear as a condition of the lease that the land would not be used for political activities or commercial purposes. zz. However, within a few weeks, the Trust applied once again to the Government to grant a relaxation to permit it to rent the land for the purpose of political activity. Unsurprisingly, the Government obliged and the G.O was duly amended permitting for political use occasionally. But is has been used continuously for the political purposes and the basic concept of Charity and other motives of the trust are totally defeated. aaa. It is submitted that Sri Naidu was declared a lifetime

trustee in his personal capacity, and the Trust cannot in any way be inherited by his political party, the TDP.

- 53 -

bbb.

Over the next 2 years, a massive building was

constructed at the site and that too by the very L&T who were beneficiaries of Sri Naidus generosity in granting them the contract for Hitech City. That such favours were illegal is borne out by the fact that the entire construction was done free of cost. It may be noted that while the income of the Trust was only Rs.8 lakh, the value of the construction ran into several crores. ccc. In 1999, after the construction of the building was

completed, it became the official headquarters of Sri Naidus Telugu Desam Party and promptly started being used for political purposes. The TDP has also been paying rent to the Trust for this purpose. ddd. It is submitted that with the Trust and the TDP

headquarters in the same location, large infusions of foreign funds are being made via the Trust, and then being utilized for the purposes of the party and Sri Naidu, without being accounted for or shown in the books of accounts. This amounts to a violation of both the Foreign Exchange Management Act and the Prevention of Money Laundering Act. eee. Nearly Rs.2-5 crores is donated to the Trust annually, and

this commenced from 2000 onwards. Notable donations in India include Rs.1 crore by the Satyam Group and Rs. 20 lakhs each by Madhucon Sugars and the Hayagreeva Estates Pvt. Ltd., all of whom have been the beneficiaries of Sri Naidus decisions while in power. A parallel may be drawn with the CBI investigation in the 2G scam into Chennai Sangamam, a so-called charitable trust of which Ms.Kanimozhi was a Trustee

- 54 -

and who received substantial donations from companies who were beneficiaries of allotment of spectrum. In the same vein, Sri Naidu also ought to be investigated. fff. In addition, the Trust is in violation of its own Deed by carrying on non-charitable activity carried on at trust land by having a party office there. Clearly, the substantial/ major purpose of the activity carried on there is political. Hence, the very purpose of the trust is defeated, and must be considered by the Government to terminate the lease. 16. Kakinada Port a. With a pre-determined mind to award the Kakinada Sea Port deep water project to a consortium comprising the son of the former Prime Minister of Malaysia and son of the former TDP Minister of Commercial Taxes, Smt J Padmavathi who was allegedly acting as a benami of Sri Chandrababu Naidu, Mr. Naidu in a brazen way, manipulating the advice tendered by RITES, the independent agency entrusted with the responsibility to evaluate the global competitive bids received in response an advertisement of the AP Government for privatization of Kakinada deep water Port, has managed to hand over the said project to the said consortium. Smt. Padamvathi is incidentally is the daughter of elder brother of Sri Bolla Bulli Ramaiah, a TDP functionary and a former Union Minister for Commerce. The Government of Andhra Pradesh has indeed called for a global competitive bid to privatize Kakinada Sea Port and entrusted the job of evaluation of various bids to RITES, a Government of India Organization. The RITES, after carrying out detailed analysis of the bids, has assigned marks to each of the applicants and forwarded the same to the Government of Andhra Pradesh. Mr. Naidu, the then Chief Minister, on finding out that the in the evaluation report of the RITES, the consortium he wanted to favour did not figure, completely altered the recommendation made by the RITEs and

- 55 -

awarded the project to the consortium that he was interested namely to the consortium led by the then Malaysian Prime Minister. The terms and conditions of the award of the contractor was, on several occasions, amended to the benefit of the private developers, entailing huge loss to the State Exchequer. This project has since become highly profitable. Just off the coast of Andhra Pradesh at Kakinada, the presence of a small island called Hope Island provides a natural harbor. There are 2 ports here, an Anchorage port and a Deep water port, of which the decision was taken by Sri.Naidu that the latter must be privatized in order to expand and develop 15 more berths for the ships. b. The Government had constructed 3 berths with in a span of 3 years i.e. from 1996 to 1999, and there was an increase exponentially every year for the cargo taken. As per the statistics available for the year 1998-99, thirteen lakh tonnes were moved at this port. c. In 1999, pursuant to the decision taken by Sri.Naidu, the port handed over to International seaports consortium led by Malaysian Prime Ministers son Mirzan bin Mahatir on Devolop-operate-Transfer (DOT) basis. They have given 18 months time period to develop another 2 berths. But the consortium failed to fulfil it's commitment and the construction work of another berth started only 5 years later in 2004,

thereby belying Sri.Naidus claim that present load exigencies required the project to be set up immediately. In addition, as per the contract, the consortium needs to pay Minimum guaranty amount (MGA) every year but it didn't do so even though started making revenue from Day 1 itself, which was found fault with by the CAG, with losses to the State exchequer calculated at Rs.53 crores for the period from 1999-2007.

- 56 -

d. In fact, to make matter worse, when the contract was renegotiated with Sri.Naidus government in 2003, the

amendments carried out were to the benefit of the consortium so that instead of paying Minimum Guarantee Amounts (MGA), they agreed to pay a share of the profits, which would of course await their completion of the project and its commencement. e. Significantly, partners of the consortium created sham Mauritius companies like PSA Bulk terminal limited, SSA Asia holdings limited which were allotted shares in Kakinada Seaports Ltd and subsequently, those shares transferred to L and T. So, it is evident that Sri.Naidu who violated all the norms for this consortium largely benefited from these companies. Interestingly, Everlink Asia Investment (a

mysterious company which made misrepresentations to the RoC, ICRA and Ministry of finance (PPP toolkit) regarding its location and registration) had a substantial stake holding, which was later claimed to be transferred to L&T. Here a purported beneficiary of the entire transaction is amply clear and it is none other than Sri. Naidu. It may be noted that L&T was a major beneficiary of Sri.Naidus largesse in the State, as is evident from Hitec City and the construction of the NTR Trust Bhavan free of cost. f. Shares were also found to be allotted to Sri.Bolla Bulli Ramaiahs South India Infrastructure development Company. Sri.Ramaiah was a TDP MP from Eluru constituency between 1999 and 2004, which was the critical time when the port

- 57 -

transactions were made. Notably, he was also a founder member of Sri.Naidus Heritage Foods India Ltd. g. The role of Sri.Karnati Venkateswara Rao who is presently CEO of Kakinada port is to be investigated as he is holding Chandrababus interests in fiduciary capacity in the name of various companies incorporated in Singapore, Malaysia and Mauritius mentioned supra. h. Infact, instead of expanding Kakinada port, The consortium expanded to SEZ operations with Kakinada SEZ limited. Sri. Karnati Venkateswara Rao is holding the entire shares in this company through Kakinada investments and holding limited (KIHL). 17. Privatization Policies under Sri Naidu a. The Public Sector Undertakings (PSUs) in Andhra Pradesh have received a major jolt with the policies of the State Government under Sri Naidu. Sri Naidu with the help of Implementation Secretariat had undertaken a so-called Public Enterprise Reform Programme with three major objectives namely a) to foster sustainable economic and social development and a competitive market economy that

encourages investment, employment and trade, b) to withdraw Govt. from commercial activities and reduce and eventually eliminate Govt. financial support to commercial enterprises and c) to increase ownership, management and control of economic activities by the private sector. Since 1999 the state government had identified 87 State Level Public Enterprises (SLPE) for

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initiate the reforms. Out of these 87 SLPEs, the state government has changed the fortune of 54 state level enterprises by closing 22, restructuring 12, privatizing 11 and disinvesting 9 between 1999 to March 2004. This was the most in the country for any State. b. Sri Naidus one sided approach was criticized by Opposition and industry experts. According to the reports of CPI (M), the State Government has lost huge amounts by doing favours to certain industries by liquidating the assets for nominal rates. The Government had ignored the reports of District Collectors and higher officials of firms and liquidated the state level enterprises and cooperatives for a sum of mere Rs.209 crore where the market value of those firms was accounted for Rs.636 crore. There was also clear suspicion that most of the lands and enterprises were handed over to the ruling party members and their associates.
STATE LEVEL PUBLIC ENTERPRISES IN ANDHRA PRADESH - REFORMS
(Rs. in Crores)
SR.NO PUBLIC ENTERPRISES DATES VALUE OF IMMOVABLE ASSETS TAKE OVER PRICE HANDED OVER TO

ENTERPRISES PRIVATISED / DISINVESTED

1 2 3 4 5 Sri Hanuman Co-operative Sugar Mill ASM Co-operative Sugar Mill Adilabad Co-operative Spinning Mill Rajahmundry Co-operative Spinning Mill Nizam Sugars Limited a) b) Chagallu Distillery Shakarnagar sugar Mill 11-Jul-01 03-Apr-02 3.95 9.00 Jeypore Sugar Company Delta Paper Mills Limited 31-Dec-02 25-Feb-03 23-Oct-02 10-May-01 7.10 2.44 2.11 11.40 3.30 4.75 3.52 Delta Paper Mills Limited Delta Sugars Limited Sree Astalaxmi Spinning Mills Pvt. Ltd Krishna Enterprises (Tadi Tata Rao)

Goldstone Exports (Gelcon) Joint Venture - 51% for Delta and 49% for NSL/AP Govt. Goldstone Exports (Gelcon) Joint Venture - 51% for Delta and 49% for NSL/AP Govt. Goldstone Exports (Gelcon) Joint Venture - 51% for Delta and 49% for NSL/AP Govt. Goldstone Exports (Gelcon) Joint Venture - 51% for Delta and 49% for NSL/AP Govt.

c)

Shakarnagar Distillery

03-Apr-02

Delta Paper Mills Limited

d)

Mombojipalli Sugar Mill

03-Apr-02

Delta Paper Mills Limited

e)

Metpalli Sugar Mill

03-Apr-02

Delta Paper Mills Limited

- 59 f) g) h) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Latchayapet Sugar Mill Madhunagar Sugar Mill Mombojipalli Distillery 10-Jan-03 16-Aug-03 07-Oct-02 15-Sep-03 23-Oct-02 04-Feb-03 17-Dec-03 15-Oct-03 29-Dec-02 10-Jun-03 08-May-03 08-May-03 07-Jun-03 23-Mar-03 23-Mar-03 23-Mar-03 23-Mar-03 23-Mar-03 8.78 3.52 2.65 2.47 5.75 9.49 9.40 18.10 7.00 6.01 5.25 4.59 9.58 36.00 14.50 5.31 NCS Estates Pvt. Ltd. Trident Sugars Limited Continental Coffee Ltd Sree Rayalaseema Sugar & Energy Limited Nuziveedu Seeds Limited Jayavenkataramana Industries Madhucon Sugars Limited Andhra Sugars Jeypore Sugar Company (Smt. Rajeswary Ramakrishnan) TATA Sons Limited

Nandyal Co-operative Spinning Mill Nagarjuna Co-operative Sugar Mill Parchur Co-operative Spinning Mill Palair Co-operative Sugar Factory West Godavari Co-operative Sugar Mill NVR Co-operative Sugar Mill, Jampani Voltas Limited Rural Electricity Supply Co-operative, Anakapalli Rural Electricity Supply Co-operative, Chipurapalli Godavari Fertilisers and Chemicals Limited Vazir Sultan Tobacco (VST) Tata Motors (TELCO) Associated Cement Companies (ACC) Sirpur Paper Mills Andhra Pradesh Paper Mill

DISINVESTED DISINVESTED DISINVESTED DISINVESTED DISINVESTED DISINVESTED DISINVESTED DISINVESTED

STATE LEVEL PUBLIC ENTERPRISES IN ANDHRA PRADESH - REFORMS

(Rs. in Crores)
SR.NO PUBLIC ENTERPRISES DATES VALUE OF IMMOVABLE ASSETS TAKE OVER PRICE HANDED OVER TO

ENTERPRISES CLOSED
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 AP Small Scale Industries Development Corporation AP Textile Development Corporation Allwyn Watches Limited Nellore Co-operative Spinning Mill Chirala Co-operative Spinning Mill Chilakaluripeta Co-operative Spinning Mill Andhra Pradesh Non-Resident Indian Investment Corporation (ANRICH) Andhra Pradesh Federation of Consumer Co-operative Societies (FEDCON) AP Fisher Development Corporation AP Electronics Development Corporation Sri Krishnadevaraya Oil Seeds Growers Union Sri Vijayavardhani Oil Seeds Growers Union AP State Federation of Cooperative Spinning Mills Limited (SPINFED) Karimnagar Co-operative Spinning Mills AP SUGARFED Chittoor District Co-operative Milk Producers Union Sri Rajarajeswara Co-operative Spinning Mills Rural Electricity Supply Co-operative, Atmakur Rural Electricity Supply Co-operative, Rayachoti Rural Electricity Supply Co-operative, Kadiri East Rural Electricity Supply Co-operative, Kadiri West Rrural Electricity Supply Co-operative, Jogipet. Phase I (1999-2002) Phase I (1999-2002) 18-Oct-99 26-Jun-01 2000 December Phase I (1999-2002) Phase II (2002-2004) 16-Nov-01 Phase II (2002-2004) Phase II (2002-2004) Phase II (2002-2004) Phase II (2002-2004) Phase II (2002-2004) 01-Nov-91 Phase II (2002-2004) 31-Aug-02 1999 01-Jul-03 01-Jul-03 01-Jul-03 01-Jul-03 01-Jul-03 ENTERPRISES RESTRUCTURED 1 2 3 4 AP State Irrigation Development Corporation AP State Meat Development Corporation AP State Agro Industries Development Corporation AP Handicrafts Development Corporation Rs. 65 crore liabilities in total for all the five RESCOs CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED CLOSED

- 60 5 6 7 8 9 10 11 12 AP Seeds Development Corporation Girijan Co-operative Corporation AP Technology Services AP Film Theatre and Television Development Corporaton AP State Warehousing Corporation AP SERIFED APCO NEDCAP

c. The decision-making process of the then policy leading to disinvestment and privatization of State owned entities conducted with the Respondent No. 8 at the helm, and decisions were taken by fine-tuning the valuation of the enterprises got done by valuers who had no track-record in assessing the

potential of the state-owned enterprises. M/s. Vignewswara Technical and Management Consultants Private Limited, Hyderabad an obscure entity in the field, was entrusted the job of valuation of the above Firms while discarding the credible agencies like CRISIL. The valuation in respect of Palair Sugars and Nizam Sugars was got done perfunctorily without any real time assessment of the potential of the enterprise to get back to profiting ways. In regard to Palair Sugars, the same was

privatized and sold out to M/s. Madhucon Sugars, which was a company registered a month prior to the agreement of takeover. M/s. Madhucon Sugars, which has had no past track record of prudent management of enterprises, was the purchaser of Palair Sugars, owned by and promoted by Sri Nama Nageswara Rao, presently Member of Parliament, TDP. Sri Nama Nageswara Rao owes allegiance to the Respondent No. 8 politically and personally and has been a close associate of Sri Naidu. Thus, the valuation of a State-owned enterprise, was deliberately diminuted without exploring the prospects of reviving the said

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enterprise, and sold for a farthing to M/s. Madhucon. A state owned enterprise, built by public funds and State contributions, was allowed to be dissipated and designed to be handed over for exploitation by private entities, for a price which caused considerable loss to the State, its citizens and the public exchequer. d. The Government of Andhra Pradesh had appointed a committee to enquire into the allegations on privatization of the above said state public sector undertakings and the committee inter alia, made the following recommendations regarding Nizam Sugars privatization.: i. To cancel joint venture which was fraudulently approved by a single member cabinet subcommittee and order probe against CSC members especially Yanamala Ramakrishnudu, the then finance minister in Sri Naidus Government. ii. Recommended to enquire with regard to three CSC members i.e. Ministers for finance, sugar and major industries for violating all rules and norms under the Swiss challenge method. iii. The detailed recommendations made by the above committee are enclosed. 18. Chittoor Dairy a. The Chittoor Dairy was a cooperative under the State, which

was destroyed by Sri.Chandrababu Naidu for the benefit of his own dairy named M/s. Heritage Foods India Limited. How he misused his power is depicted in several studies. The National Institute of Rural

- 62 -

Development has published a case study about this, the excerpts of which are as follows: The Chittoor Dairy, which was established in 1969 with 6000 litres. per day, reached to the capacity of 2.5 lakh litres per day in 1989-1990. The huge surplus milk was converted in to milk powder and the dairy could not sell the milk powder due to slump in the prices in the country. The dairy could not pay the farmers milk bills and the dairy went into loss making unit and finally was closed down on 31-08-02. Due to liberalization policy for privatization, number of private milk dairies started procuring milk from the villages. Their number in the district increased from 16 to 37 from the year 1999-2000 to 2004-05. Due to continuous drought years owing to crop failures, more farmers started keeping cows for their livelihoods and started selling milk to Private Dairies. The Private Dairies joined together and formed a syndicate to exploit the milk producers by paying Rs. 5 to 7 per litre from 2000 to 2005. In absence of competition from public sector/ district milk cooperative unions, private dairies exploited the farmers without enhancing the milk price till 2005. b. A book titled Dilemmas In Agriculture - A Personal Story published by Vasudaiva Kutumbakam narrates the murder of milk co-operatives by Sri Naidu as Chief Minister, excerpts are as follows: Elections to the cooperatives right from the village to the district level were a big political affair and even the secretary of the cooperative at the village used to make a lot of money, taking a little extra milk officially for testing and asking people to pour over the brim of the liter measured, etc. The milk for testing would never be tested. The society dairy was soon reeking of corruption and they were unable to pay bills to farmers for milk

- 63 -

supplied to them for over a year. After much agitation, the bills were paid, but the cycle repeated. At this juncture the Government allowed private dairies to operate, with our Chief Minister Chandrababu Naidu (in opposition then) taking a lead by starting a big dairy (Heritage Foods). The private dairies have formed a cartel and they do not raise the price of milk, despite there being several buyers (so much for the multi buyer model of the World Bank). II. One of the major policy decisions taken by the then Chief Minister Chandrababu Naidu within a few days after he took over the office helped his own firm, Heritage Foods Limited by the way of deferment of sales tax payments. According to the Tax Deferment Scheme of New Industrial Policy 1995, a certain percentage of payment of sales tax is postponed depending on the expenditure incurred for installation of machinery by the industries. The New Industrial Policy 1995 authorized the Government of Andhra Pradesh to decide the percentage of sales tax amount and the period for which the payment of the same could be postponed, as an incentive. III. Sri.Chandrababu Naidu issued all the necessary orders in favour of Heritage Foods Limited to make use of the benefits under Tax Deferment Scheme. Within three weeks after he became Chief Minister, all the relevant permissions were given to postpone the payment of sales tax for a period of 14 years and Narkatpalli facility of Heritage Foods was given tax incentives on 21.11.1995. Heritage Foods has gained a total of Rs.15,23,46,180 by the way of subsidies and sales tax concessions from the Government of Andhra Pradesh during 1996 to 2002. It also indicates that

- 64 -

Heritage didnt wait for the maximum period of 14 years to collect the tax incentive amount for the total of Rs.15 crore. To achieve this target Heritage Foods have followed a clever method to immediately increase the percentage of sales tax on milk from 6 % to 10% and then roll it back to the normal after collecting the total allowed amount on the basis of sales tax incentive. Heritage Foods Limited has earned at least a minimum of Rs.100 crore during the last 14 years under Tax Deferment Scheme of New Industrial Policy 1995. IV. As per the provisions of the New Industrial Policy 1995, Heritage Foods Limited is allowed to keep a sum of Rs.15 crore collected on behalf of the sales tax for a period of 28 years from 1996 to 2024. Within this period of 28 years, Heritage Foods Limited will be saving at least a minimum of Rs.300 crore in terms of basic rate of interest given for the deposits by the National Banks. V. Heritage Foods Limited has opted for the initial public issue (IPO) on 17th November 1994 and the promoters share capital was Rs.4.3 crore when compared to the Rs.6.5 crore of public share capital.
DETAILS OF FINANCIAL ASSISTANCE FROM GOVERNMENT NAME OF THE PERMISSION SALES TAX SUBSIDY UNIT DATE CONCESSION Chandragiri, 19.06.1997 11,32,13,650 20,00,000 Chittoor Bayyavaram, Vizag 12.11.1996 2,08,23,030 20,00,000 Narketpalli, 13.1.1996 1,07,77,500 15,00,000 Nalgonda Putturipalem, 24.1.2001 N/A 10,32,000 Ongole Madhira, Khammam 6.4.2002 N/A 10,00,000 TOTAL 14,48,14,180 75,32,000

h. It is clear from all the above that Sri Naidu has abused his office yet again to provide his own company with severe

- 65 -

monetary advantages, while at the same time totally causing the demise of the State co-operative. This is blatant instance of fraud, cheating and corruption that must be brought to book. i. It is evidently clear that the Heritage Public Issue was never subscribed/contributed by the public but Sri Naidu siphoned off his bribe monies, put them in finance companies and then, through his agents put back those amounts as public contribution in response to the public issue. In reality, the entire amount of share money through public issue is Sri Naidus own ill-gotten money and reinvested back in the name of the Company, which is nothing but the parking place of Sri Naidu. 19. Money laundering and Foreign assets of Sri Chandrababu Naidu a. Despite the partnership summits which were organized in Hyderabad during Sri.Naidus regime, and his official trips to Europe and USA, no substantial FDI was received by the state of Andhra Pradesh from the West. Interestingly, almost all the contracts like Kakinada Sea Ports, Raintree park situated at Hyderabad, GMR International Airport, Ascendas IT park, AP Gems and Jewellery Park, and Emaar township were awarded to international companies of Malaysia, Singapore or UAE. b. The then Prime Minister of Malaysia Sri. Mahathir Mohammed had stepped down after facing severe corruption charges in his country. Sri.Naidus personal friendship with Mahathir is not a secret to the observers of international relations. Sri Mirzan Bin Mahathir, the elder son of Mahathir Mohammed was the Chairman of the International Seaports Consortium and even has a majority stake in the said company which got the

- 66 -

Kakinada sea port contract under Public-private partnership basis. It is also equally important to note that the national press in India and investigative journals like Tehelka had revealed Sri Naidu has investments in the hospitality industry in Malaysia and Singapore. One can understand the nature of bribes in such a case which were not taken here, but were received and invested in the same country. An ordinary citizen of India cannot investigate the facts of the matter and it is the Enforcement Directorate under the aegis of the Union Government that can only examine this by issuing Letters of Request under the PMLA Act. c. In addition, as far as the AP Gems & Jewellery Park is concerned, Sri Naidu via APSTC gave 2.6 acres in 2002 in Banjara Hills to Chukkapalli Suresh (MD of AP Gems and the brother of a TDP candidate). A company named IOI India headed by C.Suresh gets financial funding from its holding company IOI Mauritius. Sri Naidu is the owner and beneficiary of IOI Mauritius, which is using its subsidiary in India to launder illegal moneys. d. In the year 2002, the newsmagazine Tehelka reported about Sri.Chandrababu Naidus disproportionate assets by naming him as the richest politician in India. They have further reported his indirect holdings in the Hotel industry and with having shopping complexes in Singapore and Malaysia respectively. Further enquiries in this regard revealed that the land on which the hotel building is located in 1, Unity Street, Singapore, 237983 is owned by M/s Parksing property pte. limited. The

- 67 -

hotel is managed / administered by the famous Park Group on payment on royalty basis. It is interesting to note that 100 percent equity in Parksing property pte. limited is held by a company incorporated in British Virgin Islands namely Eagle Force Profits Limited, P.O.Box 957, Road Town, Tortola, British Virgin Islands. This BVI Company in turn is owned by a private discretionary trust in which family Members and relations of Sri Chandrababu Naidu are the beneficiaries. This is yet another aspect that requires examination. 20. Yeleru Land Scam i. Is 15 years now eversince the infamous Yeleru Scam was unearthed in our state. In the name of paying enhanced compensation to farmers who lost their lands for the construction of Yeleru canal, politicians and top bureaucrats ate crores of rupees. Though the perpetrators of the fraud planned and executed their design with a combination of bureaucratic and political power, none of the representatives of these two domains were punished so far. If the scam was unearthed and a further plunder of Rs 400 crore was stopped, it was mainly because of the joint effort made by a vibrant judiciary and a dynamic media. Both the bureaucracy and the political class looked with contempt at this joint effort launched by the third and fourth estates of our constitution. A larger investigation into this episode is essential mainly because of the following grounds. ii. The prime accused Peela Pothinaidu opened a joint account and made fixed deposit for Rs 2 crore in 1996 at Vella branch of Vysya Bank in East Godavari district immediately after the state government headed by the then chief minister N Chandrababu Naidu released an amount of Rs 6.5 crore in the name of `compensation' to the farmers. Though this FD was supposed to contain two names, it carries the name of Pothinaidu as the second beneficiary while leaving blank the space meant to fill the name of the first beneficiary. This name is believed to be that of the then chief minister himself. Hence a CBI probe is

- 68 -

essential to find out the truth in it because the CID which was entrusted to look into the matter had failed to do so in the last 15 years. It could not even pinpoint the role of senior IAS officers who unlawfully processed the files and facilitated the release of funds in Yeleru scam. The authorities were willing to release exhorbitant compensations rather than filing appeals against them in the higher courts. This was part of the modus operandi of a clever design that kept the judiciary in the forefront of the scam. A sub judge was suspended, jailed and dismissed and not a single politician that masterminded the fraud was booked in the scam so far. This was despite a letter reaching the Chief Minister forewarning him about the ongoing Yeleru fraud and the involvement of Ministers and Chief Minister himself. Even after this letter was officially received by the CM's office, further troches of money was released. iii. The appointment of Justice B. K. Somasekhara Commission of Inquiry to probe into Yeleru scam was quashed twice by the AP High Court on pure technicalities and never on merits and hence there is no legal impediment for the court to order a CBI probe into the matter. In fact Supreme Court found fault with the AP High Court for looking at technical aspects alone and not merits at public interest and loss to the exchequer.

iv. Yeleru scam is a combination of four scams. Yeleru, Pisinikada, Yalamanchili and vizag steel plant land acquisitions were targeted and even the orders of the Supreme Court were misinterpreted in Pisinikada case and the whole issue was sought to be shown as more a judicial scam rather than a political scam. It is all the more the reason why the judiciary to order a CBI probe into it to bring out the real truth in it. 21. Rithwik Projects Ltd., a. Mr.C.M. Ramesh is a senior TDP functionary and a close aide of Sri Chandra Babu Naidu. Sri Ramesh is the Chairman of Rithwik Projects Limited, a Contracting company. Rithwik Projects Private Limited is another company which holds Sri Chandra Babu Naidus ill-gotten money. This is the reason for the elevation of Mr.C.M.Ramesh as the top functionary in the TDP.

- 69 -

b. From a small turnover of Rs.61 Crores in 2003, Rithwik Projects returned a turnover of Rs.488 crores by 2009 as a Sub-Contractor which speaks about the inexplicable and phenomenal growth of the company. There was regular infusion of capital into the company annually, which is surprising, especially when even a Singapore based Private Equity Firm - Baring Private Equity Asia IV Mauritius invested in this small contract firm from Andhra Pradesh. The list of Shareholders is enclosed herewith. c. The infusion of Share Capital into Rithwik Projects Limited is illustrated below: YEAR SHARE CAPITAL RS IN CRORES SHARE PREMI UM RS IN CRORE S 3.60 SHARE APPLICATIO N MONEY RS IN CRORES 0.62 4.29 TOTAL RS IN CRORES

20032004 20042005 20052006 20062007 20072008 20082009 TOTAL

1.8 0

6.02 4.29

3.7 2

116.27

8.50

128.49

5.5 2

119.87

13.41

138.80

a. Funds moved through the operations of Rithwik Projects Private Ltd. and indicative expenditure heads of cash nature are depicted below: Year Share Capital Rs in cr Collecti ons From Debtors Rs in cr Others Rs. in cr Total Rs in cr Payme nt To Credit ors Fixed Others Assets Rs in cr Total

- 70 -

2003-04 2004-05 2005-06 2006-07 2007-08 2008-09 2009-10

6.02 4.29

128.49 138.80

99.43 111.14 173.20 219.75 312.33 437.02 1352.87

9.45 29.23 41.21 27.95 47.66 242.56 398.06

Rs in cr 114.90 5.42 144.66 5.14 214.41 16.67 247.70 12.35 488.48 21.29 679.58 93.55 1889.73 154.42

17.98 37.94 28.84 14.25 27.87 33.68 160.56

114.90 144.66 214.41 247.70 488.48 679.58 1574.75 1889.73

91.50 101.58 168.90 221.10 439.32 552.35

b. Foreign currency transactions were carried out in a SubContracting company which need a thorough verification as foreign exchange outflow has been shown as below: YEAR 2004-05 2005-06 2006-07 2007-08 2008-09 Rs in Cr 3.89 3.13 9.34 5.86 6.31

c. By the year 2009 when the Elections for the AP State Assembly were conducted, enormous amounts of cash balances were accumulated and a lot of cash expenses were booked running into Crores of Rupees. In view of this, the Honble Court may direct the investigation of the affairs of Rithwik Projects Private Limited to unearth the ill-gotten money of Sri Chandra Babu Naidu. 22. The IMG MoU and the Rao Brothers a. The Government of A.P. headed by Mr.Chandrababu Naidu as the Chief Minister of the State entered into a MoU on 9.8.2003 with IMG, a company registered under the Companies Act, 1956 incorporated by Mr.Ahobala Rao and Mr.Prabhakara

Rao for transfer of 855 Acres of land and to develop Stadia in Hyderabad and Ranga Reddy District. Of this, 400 Acres of land was at the University of Hyderabad, to develop, own and

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operate sports academies and do all lawful business, and another 450 Acres of land in Sy.No. 99/1 at Mamidipalli was for extensions of facilities and activities relevant to its sporting academies. A further 1(one) to 5 (five) acres of land on the main road of Banjara Hills was offered to establish its head office and to do all lawful business. The terms of this MoU clearly indicate that the invaluable public property and lands were provided to be alienated without there being any control of the Government in regard thereto. The said company was registered under the Companies Act, 1956 on 5.8.2003 with a paid up share capital of Rs.1.00 (ONE) Lakh. Of this, 999 shares of Rs 100/- denomination were held by Mr.Ahobala Rao and one share by his brother Mr.Prabhakar Rao. b. It is interesting to note that these very 2 brothers were earlier engaged by Mr.Naidu in the Kuppam Project in his own Assembly constituency of Chittor. Mr.Ahobala Rao is a close associate and confidante of Mr.Naidu since 1994 according to the print and electronic media. He acted hand in glove with Mr.Naidu, and since the entrustment of the Kuppam Project to the Rao brothers, they became very close to Mr.Naidu. IMG

did not even have a proposed office or address to function at the time of incorporation. In the Memorandum of Association submitted to the Registrar of companies, the registered office address was shown as the State of Andhra Pradesh. According to the MoU the 400 Acres of the lands agreed to be transferred to IMG were part of the University of Hyderabad Campus which is serving the best interests of the State and the

- 72 -

General public. It is a prestigious institution imparting several courses to the students and conducting research studies in various subjects. The other block of land was an extent of 450 Acres near the proposed Shamshabad International Airport which has now become very prime and valuable after the commencement of International Airport. c. The Stadia promised to be conveyed under the MoU were recently developed, spending nearly 125 Crores of Rupees. The Government further agreed to pass on several concessions on Tax, Power, Water and sewerage tariffs in addition to the concessions that are available to the educational institutions in the State, under clause 2(XV) of the MoU. d. The terms of the MoU were settled in such a way that even when the State in exercise of its legislative powers annuls the deal, the Rao brothers were provided protective clauses to enforce damages against the State. e. Yet another facet of the MoU is clause 2(II)(ii) and Annexure-5 of the MoU. According to the said clause all the existing stadia in Hyderabad and Ranga Reddy district shall be leased out to IMG (Maintenance grant of Rs. 2.5 Crores payable by the landlord, the State) for a period not less than 45 years with the option to IMG to purchase all such properties at the price deduced according to the formula in Annexure-5 of the MoU. According to Annexure -5 the price of the Property shall be the basic value of the property around the Stadia as on the date immediately prior to the date of the MoU (9.8.2003) minus (-) expenditure incurred by IMG towards the maintenance and

- 73 -

upkeep (MU) and the depreciation on the buildings. In the course of 45 years lease period the value of the buildings will become negligible. In this regard, when elections were held in 2004 and Mr.Naidu was a caretaker Chief Minister of the State, he ensured that the State Government executed a hurried sale deed dated 10.2.2004 conveying 400 Acres of land in Sy.No.25 Kancha Gachchibowli village to IMG. It is respectfully submitted that the entire transaction was conducted with collusive haste and speed with the sole aim of conferring pecuniary and other benefits to the Rao brothers, thereby depriving the State and its people of the fruits of disposal/alienation of State largesse. The entire transaction is unconscionable and was a result of a conspiracy hatched by Mr.Naidu and the Rao brothers with the connivance of the Principal Secretary of the Ministry of Youth, Tourism & Culture, Mrs.Chandana Khan. f. After the general elections in the year 2004, a review of the same was directed and having regard to the clear compromise with public interest and the loss to the State, the Government issued an ordinance, which was later enacted as the A.P. Government Property (Preservation, Protection and

Resumption) Act, 2006 to nullify the above referred transaction between the State and IMG. This legislation was challenged by IMG in W.P. No. 24781/2006 and the matter is pending resolution before this Honble Court. g. According to the counter affidavit dated 01.02.2007 filed in the above pending matter by Sri. J.R.Anand, the subsequent

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Principal Secretary to Government, Youth, Tourism and Culture Department, in the following sequence, the entire transaction was completed, with sinister intent and motive underpinning every movement of the transaction: i. A note file bearing No. 111080/S1/03 was moved by the Prl. Secretary YAT&C Dept on 06.08.2003 for approval of the Draft MOU. ii. Four Ministers of the State Cabinet of the then Government of Mr. N.Chandrababu Naidu and the then Chief Secretary of the State approved the note file

(MOU) on the same day and the Chief Minister approved the note file on 08.08.2003 with an endorsement to place the file in the next cabinet meeting for approval. iii. The MoU was clandestinely signed in haste on 09.08.2003 by the then Prl. Secretary YAT&C Dept Smt.Chandana Khan on behalf of the State Government without even placing the same before the cabinet for approval. Therefore, from conception to actual

completion, the entire transaction was done in under 3 days. iv. IMG has also falsely claimed to be the subsidiary of IMG Academies, Florida, USA, an expert Sports School. Except in the note file, there was no record of any deliberations or dialogue between the Government and the Florida Company.

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v.

Office note bearing No. 111080/S1/03 is the only foundation for the MoU for transfer of 400 Acres of land belonging to the University of Hyderabad, and promise for transfer of other lands and developed properties. There was not even a notice to the Vice Chancellor of the University to part with the land when the MoU came into existence. The Executive council/Managing committee is the lawful owner of all the properties of the University. The Price of the land agreed to be sold was settled at Rs. 50,000 per acre. The Market price of the land at that time was about Rs.3 crores per Acre.

vi.

Another

450

Acres

of

Government

lands

at

Mamamidipalli near Shamshabad airport was promised to be sold at Rs. 25,000/- per acre at the time of Registration and another Rs 25,000/- to be paid after the commencement of International Airport which should be spent for the development of the roads and infrastructure to the site. The market price of the said land was about Rs. 1 Crore per acre. vii. Further the State Government undertook to establish a company called AP Sports Events Company which was to be conferred with the title and ownership of all the Government Sports Stadia and IMG was given the liberty to take on lease or purchase all the Stadia owned by A.P.Sports Events Company after it came into existence

- 76 -

at a price to be worked out according to the formula annexed to the MoU. viii. Thus A.P.Sports Events Company was conceived and destined to act as a Special Purpose Vehicle to perish after effecting transfer of its properties to IMG, especially when these properties were recently

constructed and developed at an expense of Rs 125 Crores by the State. ix. Further, so long as IMG does not please to take over the ownership of the Stadia of APSEC, the Government was to pay a sum of Rs. 2.5 Crores per year towards maintenance and upkeep of the leased stadia. x. According to Annexure 5 to the MoU the price of the Stadia shall be the basic value of the land around the stadia as on the date immediately prior to the MOU + Actual construction costs of the Stadia less (-) the amount spent for maintenance by the company and depreciation thereof. The basic rate of the surrounding properties in the year 2003 is just 10% of todays price. During 45 years of lease, after deducting the depreciation, IMG can just payback the maintenance costs received from the Government of A.P towards the price of the Stadia on the day when it so pleases to purchase. It is surprising to note that for the purpose of valuation of the stadia properties, the criteria is the basic value of the lands surrounding the stadia as on August 2003 and for the purpose of valuation

- 77 -

of buildings thereon the value is that of the building (minus) depreciation. xi. There are absolutely no returns to the State and the general Public out of the said MoU, but only concessions to IMG. xii. The entire contract was entered into in conspiracy by the political and bureaucratic executive of the day with the Rao brothers to cause loss to the State exchequer. xiii. It is respectfully submitted that each and every term of the MoU entered into between the Government and IMG was deliberately entered into without due diligence, to cause illegitimate gain and benefit to the private individuals and IMG and deliberately cause loss to the Government and the public at large. This was clearly a reciprocal arrangement between the Chief Minister and the Rao brothers, where Mrs.Khan was a necessary and willing accomplice. Lands worth several thousands of crores were bartered away with no protection to the State and no assured return to the State to a fledgling company with no qualifications or competence. xiv. The rights created for IMG over the properties were worth Rs. 7000-8000 Crores, and IMG itself had paid up capital of just Rs. 1.00 Lakh. It is reiterated that IMG was incorporated on 05.08.2003 and the MoU running into nearly 40 pages was prepared and approved on 06.08.2003 and signed on 09.08.2003. The self styled

- 78 -

description of the company that it is a 100% subsidiary of IMG Academies East Ltd. Florida is not verified either by the Authorities of the State nor has the Chairman Mr. Andrew Krieger signed on the Articles of association submitted to the Registrar of companies. Curiously, the Registrar of Companies registered the said company without the signature of the Chairman of IMGAE whose name was shown in the Articles of Association and without disclosing the registered address for the office. xv. Mr.Ahobala Rao signed the Articles of Association as Director, but in W.P.No. 24781/2006 he has deposed as co-chairman of IMG, in an attempt to try and avoid the obvious culpability that will follow. xvi. The State Assembly was dissolved on 14.11.2003 and the State Government executed a sale deed conveying 400 Acres of land in Gachchibowli and delivered advance possession of 450 acres of land at Mamidipalli to IMG. It is also reliably learnt that major part of the consideration towards University lands was met from the fee paid by the State Government as consultancy for advice in conducting the Afro-Asian games during the relevant period. xvii. Subsequently, with the change in Government at the State, when this scam surfaced, the new dispensation decided to secure investigation into it by issuing its consent for investigation by the CBI under Sec. 6 of the

- 79 -

Delhi Special Police Establishment Act, 1946 vide G.O.Ms.No. 310 Home (SC.A) Department dated 13.12.2006 for exercise of powers and jurisdiction of the members of the Delhi Special Police Establishment in the State. Before issuing the notification, the State

Government addressed a letter to the Central Government marking a copy to the CBI to investigate into the above said deal, and after several reminders the above said Notification was issued as it was done in several cases like the Outer ring road case, Paritala Ravindra murder case and Obulapuram Mining Company Case. Nearly five years have lapsed after the State Government accorded its consent under Section 6 of the 1946 Act. xviii. Having regard to the delineated spheres of activity under the Act on legal advice, it is submitted that once the State is prima facie satisfied of the commission of the offences and is of the view that having regard to the contours of the same, it needs to be investigated by the CBI, the Central Government is duty bound to honour and respect the said request of the State as a matter of course and ought not to be guided by convenience or expediency of the time and matter, and effectuate the same by issuing a consequential notification under section 5 of the Act, in public interest to facilitate investigation into an offence. xix. Alternatively, it is submitted that once a notification under Section 6 of the Act is issued by the State, the

- 80 -

Central Government ought to apply its mind to the subject matter and the material before the State Government, and take immediate action in regard thereto, on objective consideration of the material available. In the event of the Central Government not being in favour of facilitating a CBI investigation, the same has also to be communicated to the State in order to enable the State to take a decision on entrusting the investigation to any of the State Agencies. The power of the Central Government under section 5 of the Act is coupled with a duty to act expeditiously in accordance with law, with due application of mind to the facts and circumstances of the case. xx. The Central Government cannot be permitted to abdicate its duty towards the people, conferred on it under the Act, having regard to the involvement of public interest in the matter. By reason of the inaction of the UoI, no case is registered by the CBI and no investigation is conducted. There is existence of material and circumstances which show that offences under Section 34, 120B, 409, 420, IPC r/ w Sections 13(2) and 13(1)(c)&(d) and also sections 8 and 9 of Prevention of Corruption Act have been committed. h. Obviously, all the above facts show that IMG is a shell company incorporated with the sole purpose of handling the assets of the State that was transferred with such haste for a

- 81 -

throw-away price. This was clearly pursuant to a conspiracy whereby Mr.Naidu would receive his dues for the outrageous favours done to the Rao brothers, and the proceeds of this disproportionate gain would be shared by the principal actors. i. It is respectfully submitted that the sequence and contents of the events narrated above clearly and demonstrably evidence the following : Criminal Conspiracy between the political executive of the Government at the relevant point of time with private individuals; with a view to cheat the State of its legitimate revenues accruable from the sale of public assets; and to commit criminal breach of the trust reposed in them by the public at large of public resources; to confer undue and illegal pecuniary and other advantages to private individuals by depriving the State of the same; and abetment of criminal misconduct by known and unknown public servants with the common object of defrauding the public and belying their trust. The said Sri Ahobila Rao was also indicted by Justice Chalapathi Commission which enquired into the transaction entered into by the Government and the BHC Agro (India) Private Limited for an irrigation project in Kuppam which resulted in various findings of dereliction of duty, culpable negligence and various recommendations were issued. The Government also accepted the recommendations. At that juncture, Sri Ahobila Rao moved W.P. No. 4976 of 2009

- 82 -

contesting that the findings have been tendered without notice to him. This Honble Court by its interim order dt. 30-03-2009 was pleased to stay all further proceedings including prosecution of the petitioner therein pursuant to the acceptance of the report of commission of inquiry. I am taking steps to implead myself in the said W.P. and seek appropriate orders for ensuring that the proceedings initiated reach their logical conclusion. The above averments are likely to be multiplied and magnified on further investigation, disclosing several other offences that will need to be investigated as well. Several individuals have conspired with Sri Naidu to subvert the system by causing pecuniary advantage to themselves, and draining the States exchequer. Offences of cheating, criminal breach of trust, corruption, money-laundering and several others are made out by all the above facts. It is in the greatest public interest that Sri Naidu and the other private Respondents be investigated at the earliest by both the CBI and the ED, as the offences are of a national and international nature, and which have ramifications across the nation. It is therefore not possible for the State police to investigate the same, and it requires one of these important agencies to do the needful on the directions of the court. It may also be noted that as far as the State of Andhra Pradesh is concerned, it has given its consent to the CBI under Section 5 of the DSPE Act, 1946 to investigate the case of the IMG MoU, but after 5 years of continued inaction by the Central Government, it is most appropriate that the CBI be directed by this Honble Court to go ahead with investigation into the above.

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24. On legal advice, I submit as under: I. That a Public Interest Litigation is maintainable under Article 226 of the Constitution of India to ensure that probity, transparency and integrity in governance is maintained so as to ensure that the constitutional goal of governance by rule of law does not fall by the wayside. II . That the ideals of the Constitution contemplate a Limited Government where the State and its instrumentalities including the political executive acts as a custodian or the trustee of the assets of the State, which are in turn, the assets of the citizens of the State. III The State being the principal dispenser of largesse would be required to

act with rectitude and each of its decisions and the decision making process ought to be informed by the concerns of public interest and the greatest good of the largest number. IV. The instances named above, which would only amount to a negligible

percentage of the acts of omissions and commissions of the powerful political executive under the stewardship of the Respondent No. 8 has caused loss to the State exchequer, caused concentration of state wealth in the hands of a few people, who had close proximity with the Respondent No. 8 and perpetuated their interests by reason of the unholy nexus of these

private businessmen/entities and brief-case Companies.

V.

The policy making of the State under Respondent No. 8 was

manipulated and manicured to further the business and personal prospects of each of these private individuals/entities to the depletion of the State exchequer and substantial public assets were disposed of and dispensed with utter disregard of public interest and revenues.

- 84 -

VI .

As a quid pro quo for such State Policies and State decisions to grant

largesse, the Respondent No. 8 and his family members made a huge fortune and in the process amassing huge wealth disproportionate to their own sources of income and also a huge vortex of complex and convoluted transactions have been made in regard to purchase and sale of lands, and the like, to erase any link or tracing of the trail back to the Respondent no.8 and his family. VII. The ingenuity with which the entire process was put in place, each cog in the process aimed, designed and calibrated to suit the private interests of the Respondent No. 8 and his family and the members belonging to his political family and his relatives, at the cost of the State exchequer and also the interests of the citizens, requires an investigation by a competent and credible agency, which has the wherewithal to unravel the complex web of transactions authored by the Respondent No. 8 and members of his family. VIII . The clout wielded by the Respondent No. 8 and his family in the

national scene virtually depleted the strength of the law enforcement agencies and notwithstanding the open and at times brazen display of the political power to silence the critics and also the investigative agencies, the existing architecture of the investigating agencies, could not proceed further in investigating into any of the issues concerning the criminal conduct of the Respondent No. 8 and his members of family. The life and political career of the 8th respondent has been a saga of manipulation, malevolence and acts of personal corruption and public interest, as is detailed above, was his last concern. While his public posturing has been one of exhortation of the values of probity in public life, good governance and honest transactions with the people at large, the governance of the State during his tenure as

- 85 -

Chief Minister only yielded benefit to the a small cross section of people, primarily led by his family, near and dear relatives and the party men owing allegiance to Telugu Desam Party. For a good period of 9 years, the State and its resources were deployed only to perpetuate the interests of the family of the 8th respondent and his henchmen resulting in concentration of State wealth in a few hands, which is antithetical to the rule of law. I shall cooperate with any enquiry which may be undertaken in the subject matter and shall furnish such other information as I might secure during the course of the pendency of the W.P. IX. In regard to securing information in the manner pleaded above, I had to seek the help and contribution of many people, and primarily including Sri Vijay Sai Reddy, Chartered Accountant, who has been the financial advisor for the family since the year 1985. X. I submit that law enforcement agencies independently investigating

into the subject matter is not even remotely possible against the Respondent No. 8, his family members and his friends and well wishers. The evidence in this regard is the inaction of the UOI in regard to investigation under the Delhi Special Police Establishment Act in the matter concerning IMGA Bharata case. I have impleaded the parties who are centrally the beneficiaries of the acts of omission and commission of the Respondent No. 8 during his tenure as the Chief Minister of the State and in as much as the relief in the present W.P. is limited to seek directions to investigate, primarily, the role, conduct and other decisions of the 8th Respondent when he was the Chief Minister of the State between 1995-2004, any other known or unknown beneficiaries and colluders would be brought to light only after investigation and all the parties, who are necessary to be made parties, in the

- 86 -

context of the present lis, have been impleaded as party Respondents. In view of the above submissions, I am constrained to file the present Writ Petition.

25.

I have no other alternate and effective remedy except approaching

this Honble Court in extra-ordinary original jurisdiction under Article 226 of the Constitution of India.

26.

I have not filed any writ nor initiated any suit or other proceedings

before any other Court of law seeking for the relief sought for in the present Writ Petition.

27.

It is therefore prayed that this Honble Court may be pleased to issue a

writ, order or direction, more particularly one in the nature of Mandamus declaring the inaction of the Respondents No.1 to 7 in initiating penal action against the 8th Respondent and his associates, i.e., Respondents No.9 to 20 under the provisions of Prevention of Corruption Act, 1988 and the Money Laundering Act 2002 and other applicable penal laws as illegal, arbitrary and consequently direct the Respondents No.1 to 6 to initiate proceedings under law including by issuing a further direction to the 4th Respondent to conduct an investigation/probe in respect of allotment of lands, granting of licences, decisions of disinvestment and amassing disproportionate wealth and assets by the Respondents No.8 to 10 and the involvement of the Respondents No. 11 to 20 and prosecute the unofficial respondents and others in accordance with law and pass such other order or orders as this Honble Court may deem fit and proper in the facts and circumstances of the case.

- 87 -

28.

Pending disposal of the Writ Petition, it is further prayed that this

Honble Court may be pleased to direct the 4th Respondent to conduct a preliminary enquiry into the subject matter and submit a preliminary

enquiry report to this Honble Court in regard to the acts of omission and commission of the Respondent No. 8 during his tenure as Chief Minister of the State including in the matter of allot of lands, grant of contracts,

conferment of incentives and concessions and benami holdings of the 8th respondent and his family members and pass such other order or orders as are deemed fit and proper in the facts and circumstances of the case.

Solemnly affirmed and signed on this the 13th day of October, 2011 at Hyderabad BEFORE ME,

DEPONENT

ADVOCATE, HYDERABAD

- 88 -

VERIFICATION I, Smt. Y. S. Vijaya, W/o late Dr. Y. S. Rajasekhara Reddy, aged about 55 years, Occ: MLA, being the Petitioner herein, do hereby declare that the facts stated in paragraphs (1) to (23) are true and correct to the best of my knowledge, belief and information and the contents in paragraphs No.24 to 27 are believed to be true and correct on the legal advice of my counsel. Hence verified on this the 13th day of October, 2011 at Hyderabad.

Place : Hyderabad Date : 17-10-2011 PETITIONER

- 89 MEMORANDUM OF WRIT PETITION

( Filed under Article 226 of the Constitution of India ) IN THE HIGH COURT OF JUDICATURE:.ANDHRA PRAADESH AT HYDERABAD Special Original Jurisdiction W.P. No. Between Y. S. Vijaya W/o late Dr. Y. S. Rajasekhara Reddy Aged about 55 years , Member of Legislative Assembly Honourary President, YSR Congress Party R/o Bakarapeta, Pulivendula Y.S. R. Kadapa District And 1. The Union of India rep. by its Secretary, Ministry of Home, Shastri Bhavan, New Delhi 2. The State of A.P. Rep by its Chief Secretary Secretariat Buildings, Hyderabad 3 . The Government of A.P. rep. by its Principal Secretary, Home Department Secretariat Buildings, Hyderabad 4. The Central Bureau of Investigation rep by its Director, Shastri Bhavan New Delhi. 5. The Enforcement Directorate, rep.by its Director 6th floor, Loknayak Bhavan, Khan Market New Delhi 110 003 6. The Director General of Police Andhra Pradesh, Lakadi-ka-pool, Hyderabad 7. The Securities Exchange Board of India Plot No C4-A. G Block, Bandra Kurla Complex, Bandra (East) Mumbai 400 051 rep by its Chairman 8. Sri Nara Chandrababu Naidu S/o N. Kharjura Naidu Aged about 61 years, M.L.A, R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 9. Smt. N. Bhuvaneswari W/o N. Chandrababu Naidu Aged about 55 years Occ. business R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad OF 2011

. Petitioner

- 90 -

10. Sri N. Lokesh S/o N. Chandrababu Naidu Aged about 28 years Occ. business R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 11 . Sri Ch. Ramoji Rao S/o Venkata Subba Rao Kartha of HUF. Aged about 75 years Chairmans Residennce, Ramoji Film City, Anajpur, R.R. District, Hyderabad 501 512 12. Ushodaya enterprises Private Limited Somajiguda, Hyderabad, Rep.by Sri Ch.Ramoji Rao, Kartha of HUF 13. M/s. Heritage Foods (India) Limited 6-1-541/C, Panjagutta, Hyderabad 500 082 Rep by its Managing Director Smt. N. Bhuvaneswari 14. Mr. Ahobala Rao S/o P.V. Subba Rao Aged about 51 years Occ. Business Plot No. 305A, Road No. 25 Jubilee Hills, Hyderabad 15. Sri V. Nagaraja Naidu S/o Rama Naidu Aged : Major, Occ: Business, R/o Plot No. 1178, Jubilee Hills, Hyderabad 16. Sri Yelamanchili Satyanarayana Chowdhary S/o Yelamanchili Janardhana Rao, aged about 50 years R/o Plot No. 29, Sagar Co-op. Housing Society Road No. 2, Banjara Hills, Hyderabad - 34 17. Madhucon Sugar and Power Industries Limited 1-7-70, Madhu Complex, Jubileepura Khammam 507 003, Rep.by its Founder Sri Nama Nageswara Rao. 18 . Maganti Rajababu alias Murali Mohan S/o Maganti Madhava Rao, aged : Major , Occ. Business R/o A14, Film Nagar, Jubilee Hills, Hyderabad 19. Sri Karnati Venkateswara Rao S/o Kotaiah Aged about 50 years, Occ. Chairman, M/s. Kakinada Sea Ports Limited, 8-2-418, Meenakshi House, 3rd floor, Road No. 7, Banjara Hills, Hyderabad - 500 034 20. Sri Chintakunta Munuswamy Ramesh S/o Munuswamy Naidu, Aged : Major, Occ. Chairman, Rithwik group of Companies , 8-2-269/S/91/B, Road No. 2, Sagar Society Banjara Hills, Hyderabad - 34 RESPONDENTS

- 91 -

The address of the Petitioner for the purpose of service of all notices and summons is that her Counsel, M/s. Kasa Jagan Mohan Reddy (459), Advocate, 5-9-839, Gun Foundry, Hyderabad. For the reasons stated in the accompanying affidavit, the Petitioner herein prays that this Honble Court may be pleased to issue a writ, order or direction, more particularly one in the nature of Mandamus declaring the

inaction of the Respondents No.1 to 6 in initiating penal action against the 8th Respondent and his associates, i.e., Respondents No.9 to 20 under the provisions of Prevention of Corruption Act, 1988 and the Money Laundering Act 2002 and other applicable penal laws as illegal, arbitrary and consequently direct the Respondents No.1 to 6 to initiate proceedings under law including by issuing a further direction to the 4th Respondent to conduct an investigation/probe in respect of allotment of lands, granting of licences, decisions of disinvestment and amassing disproportionate wealth and assets by the Respondents No.8 to 10 and the involvement of the Respondents No. 11 to 20 and prosecute the unofficial respondents and others in accordance with law and pass such other order or orders as this Honble Court may deem fit and proper in the facts and circumstances of the case.

Place : Hyderabad Date : 17-10-2011

COUNSEL FOR THE PETITIONER

- 92 -

MEMORANDUM OF WRIT PETITION MISCELLANEOUS PETITION ( Filed under Article Section 151 of C.P.C.) IN THE HIGH COURT OF JUDICATURE:.ANDHRA PRAADESH AT HYDERABAD W.P.M.P.NO. IN W.P. No. Between Y. S. Vijaya W/o late Dr. Y. S. Rajasekhara Reddy Aged about 55 years , Member of Legislative Assembly Honourary President, YSR Congress Party R/o Bakarapeta, Pulivendula Y.S. R. Kadapa District . Petitioner/Petitioner And 1. The Union of India rep. by its Secretary, Ministry of Home, Shastri Bhavan, New Delhi 2. The State of A.P. Rep by its Chief Secretary Secretariat Buildings, Hyderabad 3 . The Government of A.P. rep. by its Principal Secretary, Home Department Secretariat Buildings, Hyderabad 4. The Central Bureau of Investigation rep by its Director, Shastri Bhavan New Delhi. 5. The Enforcement Directorate, rep.by its Director 6th floor, Loknayak Bhavan, Khan Market New Delhi 110 003 6. The Director General of Police Andhra Pradesh, Lakadi-ka-pool, Hyderabad 7. The Securities Exchange Board of India Plot No C4-A. G Block, Bandra Kurla Complex, Bandra (East) Mumbai 400 051 rep by its Chairman 8. Sri Nara Chandrababu Naidu S/o N. Kharjura Naidu Aged about 61 years, M.L.A, R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 9. Smt. N. Bhuvaneswari W/o N. Chandrababu Naidu Aged about 55 years Occ. business R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad OF 2011 OF 2011

- 93 -

10. Sri N. Lokesh S/o N. Chandrababu Naidu Aged about 28 years Occ. business R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 11 . Sri Ch. Ramoji Rao S/o Venkata Subba Rao Kartha of HUF. Aged about 75 years Chairmans Residennce, Ramoji Film City, Anajpur, R.R. District, Hyderabad 501 512 12. Ushodaya enterprises Private Limited Somajiguda, Hyderabad, Rep.by Sri Ch.Ramoji Rao, Kartha of HUF 13. M/s. Heritage Foods (India) Limited 6-1-541/C, Panjagutta, Hyderabad 500 082 Rep by its Managing Director Smt. N. Bhuvaneswari 14. Mr. Ahobala Rao S/o P.V. Subba Rao Aged about 51 years Occ. Business Plot No. 305A, Road No. 25 Jubilee Hills, Hyderabad 15. Sri V. Nagaraja Naidu S/o Rama Naidu Aged : Major, Occ: Business, R/o Plot No. 1178, Jubilee Hills, Hyderabad 16. Sri Yelamanchili Satyanarayana Chowdhary S/o Yelamanchili Janardhana Rao, aged about 50 years R/o Plot No. 29, Sagar Co-op. Housing Society Road No. 2, Banjara Hills, Hyderabad - 34 17. Madhucon Sugar and Power Industries Limited 1-7-70, Madhu Complex, Jubileepura Khammam 507 003, Rep.by its Founder Sri Nama Nageswara Rao. 18 . Maganti Rajababu alias Murali Mohan S/o Maganti Madhava Rao, aged : Major , Occ. Business R/o A14, Film Nagar, Jubilee Hills, Hyderabad 19. Sri Karnati Venkateswara Rao S/o Kotaiah Aged about 50 years, Occ. Chairman, M/s. Kakinada Sea Ports Limited, 8-2-418, Meenakshi House, 3rd floor, Road No. 7, Banjara Hills, Hyderabad - 500 034 20. Sri Chintakunta Munuswamy Ramesh S/o Munuswamy Naidu, Aged : Major, Occ. Chairman, Rithwik group of Companies , 8-2-269/S/91/B, Road No. 2, Sagar Society Banjara Hills, Hyderabad - 34 Respondents/Respondents

- 94 -

For the reasons stated in the affidavit filed in support of the above Writ Petition, the Petitioner herein pray that this Honble Court may be pleased to direct the 4th Respondent to conduct a preliminary enquiry into the subject matter and submit a preliminary enquiry report to this Honble Court in regard to the acts of omission and commission of the Respondent No. 8 during his tenure as Chief Minister of the State including in the matter of allot of lands, grant of contracts, conferment of incentives and concessions and benami holdings of the 8th respondent and his family members and pass such other order or orders as are deemed fit and proper in the facts and circumstances of the case.

Place : Hyderabad Date : 17-10-2011

COUNSEL FOR THE PETITIONER

- 95 ADDRESSES OF THE RESPONDENTS 1. The Union of India rep. by its Secretary, Ministry of Home, Shastri Bhavan, New Delhi 2. The State of A.P. rep by its Chief Secretary Secretariat Buildings, Hyderabad 3 . The Government of A.P. rep. by its Principal Secretary, Home Department Secretariat Buildings, Hyderabad 4. The Central Bureau of Investigation rep by its Director, Shastri Bhavan New Delhi. 5. The Enforcement Directorate, rep.by its Director 6th floor, Loknayak Bhavan, Khan Market New Delhi 110 003 6. The Director General of Police Andhra Pradesh, Lakadi-ka-pool, Hyderabad 7. The Securities Exchange Board of India Plot No C4-A. G Block, Bandra Kurla Complex, Bandra (East) Mumbai 400 051 rep by its Chairman 8. Sri Nara Chandrababu Naidu S/o N. Kharjura Naidu M.L.A, R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 9. Smt. N. Bhuvaneswari W/o N. Chandrababu Naidu R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 10. Sri N. Lokesh S/o N. Chandrababu Naidu R/o Plot No. 1310, Road No. 65 Jubilee Hills, Hyderabad 11. Sri Ch. Ramoji Rao S/o Venkata Subba Rao Kartha of HUF. Aged about 75 years Chairmans Residennce, Ramoji Film City, Anajpur, R.R. District, Hyderabad 501 512 12. Ushodaya enterprises Private Limited Somajiguda, Hyderabad, Rep.by Sri Ch.Ramoji Rao, Kartha of HUF 13. M/s. Heritage Foods (India) Limited 6-1-541/C, Panjagutta, Hyderabad 500 082 Rep by its Managing Director Smt. N. Bhuvaneswari 14. Mr. Ahobala Rao S/o P.V. Subba Rao Plot No. 305A, Road No. 25 Jubilee Hills, Hyderabad 15. Sri V. Nagaraja Naidu S/o Rama Naidu R/o Plot No. 1178, Jubilee Hills, Hyderabad 16. Sri Yelamanchili Satyanarayana Chowdhary S/o Yelamanchili Janardhana Rao, R/o Plot No. 29, Sagar Co-op. Housing Society Road No. 2, Banjara Hills, Hyderabad - 34 17. Madhucon Sugar and Power Industries Limited 1-7-70, Madhu Complex, Jubileepura Khammam 507 003, Rep.by its Founder Sri Nama Nageswara Rao. 18 . Maganti Rajababu alias Murali Mohan S/o Maganti Madhava Rao, R/o A14, Film Nagar, Jubilee Hills, Hyderabad 19. Sri Karnati Venkateswara Rao S/o Kotaiah Chairman, M/s. Kakinada Sea Ports Limited, 8-2-418, Meenakshi House, 3rd floor, Road No. 7, Banjara Hills, Hyderabad - 500 034 20. Sri Chintakunta Munuswamy Ramesh S/o Munuswamy Naidu, Chairman, Rithwik group of Companies , 8-2-269/S/91/B, Road No. 2, Sagar Society, Banjara Hills, Hyderabad - 34

ADVOCATE

COUNSEL FOR THE PETITIONER

- 96 IN THE HIGH COURT OF JUDICATURE : ANDHRA PRADESH: AT HYDERABAD W.P NO. Between : Smt. Y.S.Vijaya And The Union of India rep. by its Secretary, Ministry of Home, Shastri Bhavan, New Delhi and 19 others Petitioner OF 2011

Respondents

PRAYER TO THE WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

That this Honble Court may be pleased to issue a writ, order or direction, more particularly one in the nature of Mandamus declaring the inaction of the Respondents No.1 to 6 in initiating penal action against the 8th Respondent and his associates, i.e., Respondents No.9 to 20 under the provisions of Prevention of Corruption Act, 1988 and the Money Laundering Act 2002 and other applicable penal laws as illegal, arbitrary and

consequently direct the Respondents No.1 to 6 to initiate proceedings under law including by issuing a further direction to the 4th Respondent to conduct an investigation/probe in respect of allotment of lands, granting of licences, decisions of disinvestment and amassing disproportionate wealth and assets by the Respondents No.8 to 10 and the involvement of the Respondents No. 11 to 20 and prosecute the unofficial respondents and others in accordance with law and pass such other order or orders as this Honble Court may deem fit and proper in the facts and circumstances of the case.
COUNSELS: FOR PETITIONER: FOR RESPONDENTS No.1, 5 & 7: SOLICITOR GENERAL FOR RESPONDENTS NO.2, 3 & 6 : G.P.FOR HOME FOR RESPONDENTS NO.8 TO 20 : BATTA PAID

- 97 -

HYDERABAD : DISTRICT

IN THE HIGH COURT JUDICATURE ANDHRA PRADEH:AT HYDERABAD

W.P.NO.

OF 2011

MEMORANDUM OF WRIT PETITION

FILED BY : M/s. KASA JAGANMOHAN REDDY ( 459) ADVOCATE COUNSEL FOR THE PETITIONER

- 98 -

HYDERABAD : DISTRICT

IN THE HIGH COURT JUDICATURE ANDHRA PRADEH:AT HYDERABAD

W.P.M.P.NO. IN W.P.NO.

OF 2011

OF 2011

DIRECTION PETITION

FILED BY : M/s. KASA JAGANMOHAN REDDY (459) ADVOCATE COUNSEL FOR THE PETITIONER

- 99 -

IN THE HIGH COURT OF JUDICATURE: ANDHRA PRADESH AT HYDERABAD W.P NO. Between : Smt. Y.S. Vijaya And The Union of India rep. by its Secretary, Ministry of Home, Shastri Bhavan, New Delhi and 19 others Respondents Petitioner OF 2011

RUNNING INDEX S.No. Description of Document 1 2 3 4 5 6 Service Certificate Court Fee Writ Petition Annexure Affidavit Verification
MATERIAL PAPERS Book No. 1 VIII

Date of Paper

Date of Filing

Page Nos. 1 2 35

Ex.No.

16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011

10

11

Additional Counter 30-06-1988 16-10-2011 Affidavit filed Sri Chandrababu Naidu in W.P.No.7606/1988 Various Orders in 14-12-2004 16-10-2011 Rc.No.B1 2837/2002 of RDO, Guduru. Various Encumbrance 16-10-2011 Certificates issued by Sub-Registrar, Venkatagiri, Nellore Photographs relating to 16-10-2011 Nindali Village Lands belongs to Sri Chandra Babu Naidu Self declaration of 02-04-1999 assets by Sri Chandra Babu Naidu & Family

101 - 107

P1

108 - 116

P2

117 178

P3

179 - 187

P4

188

P5

- 100 -

12

13

14

15

16

17

18

19 20 21

before the speaker of A.P.Assembly Newspaper Clipping Self declaration of assets by Sri Chandra Babu Naidu & his family before the Election Commission Self declaration of assets by Sri Chandra Babu Naidu & his family before the Election Commission Settlement Deed executed by Smt. N.Ammannamma in favour of N.Lokesh Self Declaration of assets by Sri Chandra Babu Naidu Sale Executed by J.P.Vittal in faviour of N.Ammannamma Gift Deed executed by Smt. N.Ammannamma in favour of N.Lokesh Sale Deed executed by Smt. N.Ammanamma & Lokesh in favoure of J.Satyanarayana Annual return of M/s. Bizpro Technologies MOA of M/s. Bizpro Technologies

02-04-2004 16-10-2011

189 - 196

P6

29-03-2009 16-10-2011

197 - 206

P7

20-12-2001 16-10-2011

207 - 213

P8

02-09-2011 16-10-2011

214 - 219

P9

11-12-2000 16-10-2011

220 - 229

P10

Dec.2001

16-10-2011

230 - 231

P11

24-03-2004 16-10-2011

232 - 241

P12

10-01-2003 16-10-2011 19-02-2000 16-10-2011

242 - 250 251 260 260 - 271

P13 P14 P15

22

23

24

Sale Deed executed by 27-07-2000 16-10-2011 Smt. N.Bhuvaneswari and others in favour of K.Satish Reddy Sale Deed executed by 27-07-2000 16-10-2011 Smt. N.Bhuvaneswari and others in favour of K.Preeti Reddy Statutory Notification 16-10-2011 of Cyberabad Development Authority Memorandum for 13-03-2009 16-10-2011 recording creation of Mortgage by depositing title deeds by Divyasree

272 - 281

P16

281 - 284

P17

285 - 302

P18

- 101 -

25

26

27

28

29

30

31

32

33 34

Certificate of Incorporation of Bhuvaneswari Carbides and Chemicals MOA of Bhuvaneswari Carbides and Chemicals AOA of Bhuvaneswari Carbides and Chemicals Certificate of registration of Mortgage of Bhuvaneswari Carbides & Chemicals Creation of Charge Document of Bhuvaneswari Carbides & Chemicals Creation of Charge Document of Bhuvaneswari Carbides & Chemicals Creation of Charge Document of Bhuvaneswari Carbides & Alloys Creation of Charge Document of Bhuvaneswari Carbides & Chemicals Mortgage Certificate Creation of Charge Document of Bhuvaneswari Carbides & Chemicals Creation of Charge Document of Bhuvaneswari Carbides & Chemicals Annual return of Bhuvaneswari Carbides and Chemicals Certificate of Incorporation of Bhuvaneswari Carbides and Allyos

21-06-1983 16-10-2011

303 - 304

P19

21-06-1983 16-10-2011

305 - 308

P20

21-06-1983 16-10-2011

309 - 312

P21

20-02-1984 16-10-2011

313

P22

05-06-1984 16-10-2011

314 - 315

P23

11-07-1983 16-10-2011

316 - 317

P24

21-08-1984 16-10-2011

318 - 319

P25

28-07-1983 16-10-2011

320 - 322

P26

02-02-1985 16-10-2011 05-06-1984 16-10-2011

323 324 - 325

P27 P28

35

19-07-1984 16-10-2011

326 - 327

P29

36

31-03-2003 16-10-2011

328 - 332

P30

37

20-01-1984 16-10-2011

333 - 334

P31

- 102 -

38 39 40

AOA of Bhuvaneswari Carbides of Allyos

19-01-1984 16-10-2011

335 339 340 344 345 - 348

P32 P33 P34

MOA of Bhuvaneswari 19-01-1984 16-10-2011 Carbides of Allyos Certificates of Charge of Bhuvaneswari Carbides and Alloys Audit Report of Bhuvaneswari Carbides and Alloys Annual returns of Bhuvaneswari Carbides and Alloys Annual Reports of Bhuvaneswari Carbides and Alloys Name change of Heritage Infra to SCM Infra Annual return of Heritage Infra 16-10-2011

41

28-08-2003 16-10-2011

349 - 351

P35

42

16-10-2011

352 - 368

P36

43

16-10-2011

369 - 399

P37

44

11-12-2008 16-10-2011

400 405

P38

45 46

2007-2008

16-10-2011

406 414 415 - 426

P39 P40

47

48

49 50 51 52

Mortgage Agreement 25-06-2008 16-10-2011 between Heritage Infra and SICOM Ltd., Mortgage Document 16-10-2011 and Incorp. Certificates of Heritage infra & SCM Annual report of 2008-09 16-10-2011 Sujana Universal Industries and subsidiaries 12th Annual Report of 2008 - 09 16-10-2011 Global Forgings Ltd., Annual Report of Tejaswini Engineering Annual Report of Tejdeep Engineering Annual Report of Glade Steel private limited Annual Report of Futuretech industries Annual Report of Victoria Steel Annual Report of Endeavour industries 2008-09 2008-09 2008-09 16-10-2011 16-10-2011 16-10-2011

427-435

P41

436 - 558

P42

559 - 584 585-606 607-630 631-653

P43 P44 P45 P46

53 54 55

2008-09 2008-09 2008-09

16-10-2011 16-10-2011 16-10-2011

654-684 685-709 710-734

P47 P48 P49

- 103 -

56

57 58 59 60

Annual Report of Godavari Exports and imports Annual report of Ganga Exim pvt ltd Annual Report of Handum industries Annual Report of Omicron Bio-genesis Annual Report of Ganga Industrial corporation Annual Report of Ushodaya Enterprises Annual Report of Devaki Commercials Pvt Ltd Company Petition filed by RPL, In Gujarat HC Scheme of Amalgamation News Paper Clipping Annual Return of Shinano Retail Pvt. Ltd Annual Return of teesta Retail Pvt. Ltd. Annual Report of Devaki Comm. Pvt. Ltd. Audited A/c of RIIHL Form 2 of Equator Trading Enterprises Form 2 of Altitudde Mercantile Pvt. Ltd. Form 32 of Equator Trading Enterprises Form 32 of Altitudde Mercantile Pvt. Ltd. Form 18 of Equator Trading Enterprises

2008-09

16-10-2011

735-755

P50

2008-09 2008-09 2008-09 2008-09

16-10-2011 16-10-2011 16-10-2011 16-10-2011

756-779 780-824 825-851 852-872

P51 P52 P53 P54

61 62

2007-08 2007-08

16-10-2011 16-10-2011

873-875 876-885

P55 P56

63 64 65 66 67. 68

16-4-2002 --7-4-2009 2007-08 2007-08 2007-08

16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011

886-888 889-905 906-908 909-920 921-932 933-941

P57 P58 P59 P60 P61 P62

69 70 71 72 73 74

2007-08

16-10-2011

942-960 961-964 965-969 970-973 974-977 978-979

P63 P64 P65 P66 P67 P68

30-01-2008 16-10-2011 29-01-2008 16-10-2011 ----1-2-2008 16-10-2011 16-10-2011 16-10-2011

- 104 -

75 76 77

Form 18 of Altitudde Mercantile Pvt. Ltd. Annual Report of Shinano Retail Pvt. Ltd Annual Return of Devaki Comm. Pvt. Ltd. Annual Returns of Kavindra Comm. Pvt. Ltd. Form 2 of Ushodaya Enterprises Form 2 of Equator Trading News Paper Clippings Regarding Kampani deal Form 18 of Kavindra Commercials Annual Return of UEPL Form 32 of UEPL Auditors Report of UEPL Annual Return of UEPL Proceedings of Land Reforms Tribunal Newspaper Clipping related to KG Basin

1-2-2008 2007-08 2007-08

16-10-2011 16-10-2011 16-10-2011

980-981 982-993 994-1011

P69 P70 P71

78

---

16-10-2011

1012-1036

P72

79 80 81

30-1-2008 30-1-2008 2-2-2008

16-10-2011 16-10-2011 16-10-2011

1037-1040 1041-1044 1045-1047

P73 P74 P75

82 83 84 85 86 87 88 89 90 91

--2006-07

16-10-2011 16-10-2011

1048-1049 1050-1059 1060-1062 1063-1076 1077-1085 1086-1098 1099 1100 1101-1102 1103-1104

P76 P77 P78 P79 P80 P81 P82 P83 P84 P85

28-12-2007 16-10-2011 17-11-2009 16-10-2011 2008-09 8-8-2007 31-1-2007 16-10-2011 16-10-2011 16-10-2011

Amendment to GO MS 02-02-2001 16-10-2011 No.506 IT incentive policy GO MS No.2 Stamp Duty Exemption to Reliance Infocomm. GO MS No.127 Stamp Duty Exemption to Reliance Infocomm. Incentive policy GO MS No. 11-1-2001 19-2-2001 16-10-2011 16-10-2011

92 93

19-2-2001 16-3-2001

16-10-2011 16-10-2011

1105-1106 1107-1109

P86 P87

- 105 -

94

95

96

97 98

Exemption of Property Tax and Transfer duty. GO MS No.156 MA 100 percent exemption of Transfer Duty GO MS No.157 MA Exemption Santion of Transfer Duty GO MS No.164 MA IT incentive policy GO MS No.27

24-4-2001

16-10-2011

1110-1111

P88

24-4-2001

16-10-2011

1112

P89

26-4-2001

16-10-2011

1113

P90

28-4-2001

16-10-2011 16-10-2011

1114-1116 1117-1118

P91 P92

99

100

101

102

103 104

Rebate in Registration 30-5-2001 Charges to Catalytic software - GO MS No.33 Rebate in Registration 30-5-2001 Charges to JVP Soft GO MS No.34 Rebate in Registration 17-9-2001 Charges to Soham software - GO MS No.42 Rebate in Registration 17-9-2001 Charges to Soft ProGO MS No.43 Opening of Escrow 4-12-2006 A/C by Margadarsi Financiers India Today Story on 12-09-2011 Ramoji Land grabbing Encumbrance certificates and Registered sale deeds of Palmakole Lands Registered sale deeds in favour of Maganti Murali Mohan Concessions, permits granted by IT and C Dept. Land allotments to IT companies By APIIC Land allotments to IT companies By CM/ Cabinet Land allotment with Rebate on cost of land and various subsidies RTPP lands allotted to BPL power- GO MS No.57 ---

16-10-2011

1119-1121

P93

16-10-2011

1122-1123

P94

16-10-2011

1124-1126

P95

16-10-2011

1127

P96

16-10-2011 16-10-2011

1128-1129 1130-1169

P97 P98

105

19-3-1996

16-10-2011

1170-1201

P99

106

--

16-10-2011

1202-1204

P100

107 108

-----

16-10-2011 16-10-2011

1205-1209 1210

P101 P102

109

---

16-10-2011

1211-1228

P103

110

20-5-2000

16-10-2011

1229-1230

P104

- 106 -

111

112

113

114

115 116 117 118 119 120 121

RTPP lands allotted to BPL power- GO MS No.112 RTPP lands allotted to BPL power- GO MS No. 2 Newspaper Clipping on Konaseema powerProbe order Newspaper Clippings on Konaseema powerbribe issue Photograph of NTR Trust Bhavan Registration of NTR Trust under IT ACt NTR Trust reciptspayments NTR Trust deed and Amendment Deed

27-11-2000 16-10-2011

1231-1233

P9105

1-1-2001

16-10-2011

1234-1235

P106

28-7-2004

16-10-2011

1236-1237

P9107

29-9-2003

16-10-2011

1238-1242

P108

--

16-10-2011

1243 1244 1245-1246 1247-1272 1273 1274-1275 1276-1312

P109 P110 P111 P112 P113 P114 P115

11-12-1997 16-10-2011 31-3-2004 15-2-1997 16-10-2011 16-10-2011

Induction of new 28-12-2007 16-10-2011 trustee in to NTR Trust Resignation of Trustees- NTR trust Income Tax assessment Order and related documents IT returns and related documents of NTR Memorial Trust Donors list of NTR Memorial Trust CAG Reports on Kakinada port Annual Return of Kakinada sea ports Annual Report of Kakinada sea ports Annual Return of Kakinada sea ports ICRA rating for Kakinada Sea portmisleading info on Everlink Asia 16-11-2007 16-10-2011 ---16-10-2011

122

2003-04

16-10-2011

1313-1408

P116

123 124 125 126 127 128

31-12-2009 16-10-2011 31-3-2004 2003-04 2004-05 2004-05 6-4-2010 16-10-2011 16-10-2011 16-10-2011 16-10-2011 16-10-2011

1409-1438 1439-1445 1446-1458 1459-1485 1486-1499 1500-1501

P117 P118 P119 P120 P121 P122

- 107 -

129

130 131 132 133

Info on KSPL at Ministry of finance Website- misleading info on Everlink Asia Shareholders list and Consent letters- KSPL Annual Return of South India Infra Form 23AC of Salgaocar mining

---

16-10-2011

1502-1503

P123

24-9-2005 2003-04 2007-08

16-10-2011 16-10-2011 16-10-2011

1504-1512 1513-1522 1523-1530 1531-1538

P124 P125 P126 P127

134

135

136

137

138

139

140

141

142

Privatization of Palair 17-12-2003 16-10-2011 Sugars- in favour of Madhucon Sugars- GO MS No.72 Privatization of 10-1-2003 16-10-2011 Latchayyapeta Sugarsin favour of NCS Sugars- GO MS No.7 Privatization of 16-8-2003 16-10-2011 Madhunagar Sugars- in favour of Trident sugars - GO MS No.49 Privatization of 4-2-2003 16-10-2011 Parchur cotton mills in favour of JVR Industries- GO MS No.10 Privatization of 20-11-2002 16-10-2011 Chagallu Distillery - in favour of Jeypore sugars- GO MS No.44 Disinvestment in 7-6-2003 16-10-2011 Godavari FertilizersGO MS No.32 Privatization of 17-5-2003 16-10-2011 Nagarjuna Sugars - in favour of SCM - GO MS No.26 10-1-2003 16-10-2011 Privatization of Rajahmundry spinning mill - in favour of NRKR Textiles - GO MS No.6 Privatization of ASM 25-2-2003 16-10-2011 Sugars- in favour of Delta papermills - GO MS No.14 Privatization of 20-11-2002 16-10-2011 Adilabad spinning mill - in favour of Astalaxmi Spinning -

1539-1553

P128

1554-1563

P129

1564-1567

P130

1568-1585

P131

1586-1587

P132

1588-1591

P133

1592-1597

P134

1598-1603

P135

1604-1606

P136

- 108 -

143

144

145 146

GO MS No.45 Privatization of 31-12-2002 16-10-2011 Hanuman Sugars - in favour of Delta Sugars - GO MS No.50 Sale of farm lands of 18-10-2002 16-10-2011 Nizam Sugars - GO MS No.100 Sale of lands of Nizam 11-3-2003 16-10-2011 Sugars - GO MS No.31 Dispose of Un Economic Farm lands of Nizam Sugars- GO MS no.49 Restructuring of APSFT&TDCL- GO MS no.34 Restructuring of APSWC- GO MS no.33 Restructuring of APTS- GO MS no.24 Restructuring of NEDCAP- GO MS no.25 Amendment orders for Disinvestment proposal of Godavari Fertilizers GO MS No.102 Annual Return of Vighneswara Technical MoA Of Madhucon Sugars Annual Report of Maducon Sugars State Government policy of privatization 30-3-2001 16-10-2011

1607-1610

P137

1611-1612

P138

1613 1614

P139 P140

147

12-6-2003

16-10-2011

1615-1617

P141

148

12-6-2003

16-10-2011

1618-1622

P142

149 150

19-4-2003 19-4-2003

16-10-2011 16-10-2011

1623-1624 1625-1626

P143 P144

151

25-8-2001

16-10-2011 1627

P145

152 153 154 155 156

2007-08

16-10-2011

1628-1635 1636-1643 1644-1667 1668-1714 1715-1727

P146 P147 P148 P149 P150

26-10-2002 16-10-2011 2009-10 2004 16-10-2011 16-10-2011

157

158

House Committee -16-10-2011 Recommendations on Nizam Sugar unites Sale- Related GOs Implementation of 23-12-2002 16-10-2011 VRS to Chittoor dairyRelated GOs Photograph of Heritage --16-10-2011 foods corporate officeHyderabad

1728-1740

P151

P152 1741

- 109 -

159 160

MOA of Heritage foods india limited Photograph of Park Hotel Clarke quaySingapore Land holding details of Park Hotel Clarke quay Share holding details of Park Hotel Clarke and Parksing property Mauritius holdings in IJM India limited MOA of IJM India Certificate of IncorpAP Gems and Jewellary park Annual return and annual reports of Ap Gems and Jewellary Mauritius holding in AP Gems& Jewellary MOA of AP Gems and Jewellary Park ltd Letter to CM Chandrababu naidu on Yeleru scam by MLAs Post facto approval of funds by CM Chandrababu Naidu Deposition of Sri Kosal Ram before Justice Somasekhara Commission Statement of decretal charges granted and paid Deposition of Sri M.S.Rajaji before Justice Somasekhara Commission Annual reports of Rithwik Projects

18-5-1992 ---

16-10-2011 16-10-2011

1742-1748 1749

P153 P154

161 162

---

16-10-2011 16-10-2011

1750-1755 1756-1761

P155 P156

163 164 165

3-1-2007 1-1-1998 24-9-2002

16-10-2011 16-10-2011 16-10-2011

1762-1769 1770-1828 1829

P157 P158 P159

166

2003-04

16-10-2011

1830-1839

P160

167 168 169

--23-9-2002 Feb-1996

16-10-2011 16-10-2011 16-10-2011

1840-1862 1863-1874 1875-1877

P161 P162 P163

170

1-10-1996

16-10-2011

1878

P164

171

6-3-1999

16-10-2011

1879-1945

P165

172

--

16-10-2011

1946-1953

P166

173

24-3-1999

16-10-2011

1954-1967

P167

174

2007-08 2009-10

16-10-2011

1968-1998

P168

175

Annual Return of Rithwik projects

2007-08

16-10-2011

1999-2084

P169

- 110 -

176 177 178 179

MOA of IMG Academies Bharata Regd. Sale deed in favour of IMG Bharata Act 11 of 2007 Chronological developments and minutes of meeting Letter to Revenue secretary from APIIC VC and MD Letter to MD, APIIC by Spl secy to CM Communications between CCLA and Collector, Rangareddy Dist. related docs Letter to Revenue Secy by Spl secy To CM Memorandum for the council of ministers and MOU CBI enquiry about IMG land deals GO MS No.310 Counter affidavit filed by J.R.Anand in W.P. No.24781 of 2006 Report of the commissioner of inquiry on Kuppam project allegations by Justice Chalapathi

4-8-2003

16-10-2011

2085-2095 2096-2105 2106-2110 2111-2118

P170 P171 P172 P173

10-02-2004 16-10-2011 11-4-2007 29-9-2003 16-10-2011 16-10-2011

180

24-1-2004

16-10-2011

2119-2120

P174

181 182

22-1-2004 30-1-2004

16-10-2011 16-10-2011

2121 2122-2138

P175 P176

183 184

19-2-2004 Feb-2004

16-10-2011 16-10-2011

2139-2141 2142-2190

P177 P178

185

13-12-2006 16-10-2011

2191

P179

186

1-2-2007

16-10-2011

2192-2208

P180

187

19-4-2007

16-10-2011

2209-2424

P181