Land along with a bungalow, garage and an out-house bearing Khata No. 50 (Old Sy.No.

37,
New Nos. 139 and 142) lin Pattandur Village, K.R.Puram Hobli, Bangalore South Taluk, nearly
measuring 2 acres and 2 guntas. The said property is more-fully described in the schedule to
this
plaint and herein after refereed to as the "suit schedule property" As per the survey sketch,
Sy.Nos. 139 and 142 were adjoining lands. A portion of Sy.No.142 abutting and adjoining
Sy.No.139 with the portion of measuring 310 feet X 62 feet was sold along with the portion of
Sy.No.139 measuring 310 feet on the North, 310 feet on the South, 310 feet on the West and
100 +130 feet on the East to the mother of the plaintiffs Mrs. Gladys Lucilda Medina under a
Registered Sale Deed dated 9.11.1972, The suit schedule property was sold to the plaintiffs
mother by one Sri. H.Bhavarlal, S/o Himmatlal and his son Manohar Lal who were the owners of
the said property. The suit schedule property was also known as "Collingwood Estate". The suit
schedule property together with the other Survey Numbers measuring more than 127 acres was
Inamati land sítuated in Jodi-Pattandur formerly known as 'Redwood Estate' and later known as
'Collingwood Estate'. The entire estate including the suit schedule property was purchased by
one Mrs. Marie Gertrude Hussey for a valid consideration under Registered Sale Deed dated
14.3.1944. The said Mrs. Marie Gertrude Hussey has sold the entire estate along with the suit
schedule property for valid consideration to one Mrs. Ada Elizabeth Kurup under a Registered
Sale Deed dated 28.10.1947. A re-survey was introduced and old Sy.No.37 was divided into
various plots and its owner Mrs. Ada Elizabeth Kurup sold several plots in the said Sy.No.37.
Whereas schedule property which was one of the plots in the said old survey Number was sold
by Mrs. Ada Elizabeth Kurup for valid cepsideration to Sri H.Bhavarilal, and one Sri, Mishrilal
under Registered Sale Deed dated 16.6.1967 Whereas Sri.Mishrilal Son of Chaturbhui who had
purchased the schedule property together with H.Bhavarilal on 16.6.1967 had sold. his share
and right, title and interest in the suit schedule property for valid consideration to Sri. Manoharlal
under Registered Sale deed dated 4.5.1970 . Thereafter, the vendors of the schedule property
i.e., Bhavarilal and his Son Manoharlal who had been in absolute possession of the schedule
property had sold the same to the plaintiffs mother Mrs.Gladys Lucilda Medina and she was put
into possession of the schedule property under the Registered Sale Deed dated 9.11.1972.
Subsequently, the old Sy.No.37 was given new numbers as 139 and 142 and the suit schedule
property was given Khata No.50. The name of the plaintiffs' mother was entered in the Mutation
Extraot as an owner and khatedar of the said property. Encumbrance certificate issued by the
Sub-Registrar, Bangalore South Taluk also shows the name of the plaintiffs mother as the
owner of the suit schedule property having purchased the same under a Registered Sale Deed
dated 9.11.972. On 24.2.1995, the plaintiff's mother Mrs.Gladys Lucilda Medina expired at
Bangalore. The plaintiffs are the only heirs of Late Gladys Lucilda Medina and they succeed to
her estate as her heirs. During the life-time of their mother, the plaintiffs were in possession and
enjoyment of the schedule property along with their mother. After the death of their mother, the
plaintifts are in absolute and exclusive possession of the suit schedule property. The defendants
are busy bodies in the villages and have no manner of concern with the suit schedule property.
The defendants are trying to take the advantage of the fact that plaintitts are residing in
Bangalore as they are employed at various places. At present, the bungalow, garage and the
outhouse on the suit property is in a dilapidated condition. There are tamarind, cashew, mango
and other tress in the compound of the bungalow. The defendants are land grabbers and they
have organised themselves in such a manner that when-ever they find vacant plots of land or
unused premises, they try to take forcible possession. The local police are also hand in glove
with the defendants and are helping them to take illegal possession. The defendants who are
very powerful persons in the locality are trying to forcibly dispossess the plaintiffs from the suit
property. The defendants have not only got'political influence, but, they are also monied people.
Though the plaintiffs approached the police on number of occasions,they have refused, to
register complaints against defendants. The plaintiffs are unable to defend themselves against
the defendants. The defendants are trying to dispossess the plaintiffs' from the suit property.