IN THE COURT OF ADDITIONAL CIVIL JUDGE SENIOR

DIVISION, BUDHLADA.

State of Punjab through Sukhwinder Singh, Range Forest Officer,

Mansa, Tehsil and District Mansa.

. ...... Plaintiff

Versus

1. Karam Singh Son opf Chanan Singh Son of Anup Singh

2. Chan~ Singh Son of Anup Singh Spon of Nikka Singh
3. Balcl€v Kaur Wife of Chanan Singh Son of Anup Singh
4. Varinder Kaur Wife of Balwinder Singh Son of Harjit Singh all
residents of Village K.1-mdal Kalan, Tehsil Budhlada, District Mansa

......... Defendant
'•
Suit for permanent injunction restraining the defendants
thefr agents, attorneys or associates from any way or in any
manner interfering and from cutting and removing the t~ees
standing into the part of land measuring 120K-10M
Comprised of Khewat No. 300, Khatoni No. 641, Khasra
Nos.336(20-11), 337(5-7), 339(17-6), 340(60-7) and Khewat
No Khatoni No Khasra Nos 866(9-12), 767(7-7) as entered in
the Jamabandi for the year 2007-08, situated in village
Khudal Kalan, H.B. No. 174, Tehsil Budhlada, District
Mansa.
*********************
Sir,

The plaintiff most respectfully sub111 1·ts l

I
as un c er:-

I
 Forest Officer Forest
That the plaintiff is the Range
Department , at Mansa , Tehsil and Distt Mansa and plaintiff

has been authorized by the Divisional Forest Officer Mansa to

file the present case .

2. That the property in suit belongs to Provincial Government as

d~ly mentioned in the Fard Jamabandi attached. Further the

said property has been given to the canal department and as

per notification of the Government of Punjab, revenue

· department the same is declared as protected forest and is

under the control and management of the Forest department

and the department has planted various trees in the . suit

property. Copy of the notification is attached for the kind

perusal of this learned Court.

3. That the previously defendants have filed civil suit no

341/2017 titled as Karam Singh Vs BDPO Budhlada etc

before the Court of Civil Judge Junior Division _Budhlada

regarding their property bearing Khasr Nos 167 / / 17(2-2),

18/2(2-4), 167//4(8 --
?) ' 5/ l(?-- 8) , 7(9-1), 8/1(2-13),

158/ /23/2(3-0), 24(8-0), 25/ 1(3-8), 167 / / 12 min(S-8), 13(7-

2), 14(7-9) situated at Village Khudal Kal an an d Land bearmg

• .

Khasra Nos 25//7 /2(1-5), 12/2(4-13), 13/2(4-6), 14(7-12),

15(8-0), 17(7-0), 20/lrnin(0-3), 22(6-19) , 23(5 -6) situated

. at
village Kahangarh, Tehsil Budhlada wh.ic h is
. adjoining to the

property of the department and th e learned Court vide

Judgment and Decree dated 12.11 ·20?- 1 partly decreed the

said suit
· with
· the liberty to th .
· e plaintiff to conduct the
demarcation of the land as per 1aw to
separa te th e plaintiffs
 (defendants in pre~ent suit) land and Government land and

plaintiffs (defendants in present suit) have no right to interfere

in the process of demarcation. Copy of judgment and decree

are attached ~or the kind perusal of this learned Court. .

4. That as per the said judgment plaintiff have immediately

applied for demarcation of the land in suit as well as land Qf

the defendants by submitting written request to the Deputy

Commissioner Mansa and other revenue officials. Copy of the

applications area attached for the kind perusal of this learned

Court.

5. That the defendants without waiting for the demarcation and

witq.out intimation to the plaintiffs have started removing and

'. •,

cutting the trees from the suit property by alleging that they

are cutting the trees from their property. Defendants taking

the wrong benefit of the Judgment dated 12.11.2021 have

forcibly and illegally managed to cut and remove 66 trees from

the property in suit and plaintiff has made the comp~aint of

the same to the SSP Mansa. Copy of the same is attached for

the kind perusal of this learned Court.

6. That the defendants are desperate person and having no

regard for law and order and are taking hasty steps to further f

cut and remove the trees standing in the suit land, without I
even waiting for the demarcation of the suit land and their I
.I

adjoining land of which they are having no right to d ·

0 S O.
7. That the defendants are throwing illegal th
reats to fu rth er cut
and remove the trees standing in the sui·t la i· . l
n c1 o w 11 1c 1 t 11ey
are having no right to do so.
 That the plaintiff requested the defendants many a times not

to raise such illegal threats and designs and to wait till the

demarcation of the suit land and their land is conducted c;s

per Judgment arid Decree dated 12.11.2021, but of no use,

hence this suit.

9. That the cause of action arose in favour of the plaintiff and

against the defendants from their illegal threats and designs to

to further cut and remove the trees standing in the suit land

and finally from his final refusal, when they refused to accede

to the request of the plaintiff since yesterday, hence this suit.

l 0. That the property in suit is situated within the jurisdiction of

thi~ learned court, hence this suit is triable by this learned

court.

l l. That the value of the suit for the purpose of court fees and

jurisdiction is Rs. 500 /-, hence a proper court fees has been

affixed on the plaint.

12. That there is no other litigation either pending or decided

regarding the subject matter of the suit in any competent

court of law except the civil suit mentioned above.

13 . That a duplicate plaint is attached herewith.

It is, therefore , prayed that a dee ree 1or

• permanent
injunction restraining the defendants their acrents att
c , orneys or
associates from any way or in any manner inte • · d f
, r1enng an rom
cutting and removing the trees standing into th
e part of land
measuring 12OK-1OM Comprised of Khewat No .
· 300 , Khatorn No.
64 1, Khasra Nos .336(2O-11) 337(5-7) 339(l
' ' 7 - 6 ), 340(60- 7) and
Khewat No Khatoni No Khasra Nos g (
66 9 -12), 767(7-7) as
1/:tered in the Jamabandi- for th~ year 2007-08, situated in

village Khudal Kalan, H.B. No. 174, Tehsil Budhlada, J?istrict

Mansa, may kindly be passed in favour of the plaintiff and

against the defendants, in the interest of justice.

Verification:- Submitted by:

Verified at Budhlada State of Punjab through
on _ _ _ that the
contents of the paras Sukhwinder Singh,
no. l to 13 of the Range Forest Officer,
plaint are true and
correct to .the best of Mans a, Tehsil and
my knowledge and District Mansa.
belief and as per
information derived
from the official
record.
. ....... Plaintiff
... ....:...... Plain tiff

Through Counsel :
 IN THE COURT OF ADDITIONAL CIVIL JUDGE SENIOR ·
DIVISION, BUDHLADA.

State of Punjab Vs Karam Singh etc

( Suit for Permanent Injunction )

Affidavit in support of plaint.
AFFIDAVIT
I, Sukhwinder S~gh aged about u years , Range Forest
Officer, Mansa, Tehsii and District Mansa, do hereby
solemnly affirm and declare as under:-
1. That the· contents of paras no. 1 to 13 of the plaint are
true and correct to the best of my knowledge and belief
and as per information derived from the official record and
the legal advice received through counsel.
2. Th?,t the contents of the plaint as a whole may be read as
part and parcel of this affidavit also.

Deponent

Verification :-
Verified at Budhlada on3MJ&v..½I ~ ;,.,,.n_.I, the above named
deponent do hereby declare o~~olemn affirmation that
the contents of my above affidavit are true and correct to
the best of my lmowledge and belief and nothing has
been concealed therein. ,,I;

Deponent L--

i
 I

IN THE COURT OF ADDITIONAL CML JUDGE SENIOR

DMSION, BUDHLADA.

State of Punjab through Sukhwinder Singh, Range Forest Officer,

Mansa, Tehsil and District Mansa.

. ...... Applicant

Versus

1. Karam Singh Son of Chanan Singh Son of Anup Singh

2. Chanan Singh Son of Anup Singh Spon of Nikka Singh
3. Baldev Kaur Wife of Chanan Singh Son of Anup Singh
4. Vari-nder Ka~r _Wife of Balwinder Singh Son of Harjit Singh all
residents of Village Khudal Kalan, Tehsil Budhlada, District Mansa

.... Respondents

Application U/o 39, Rule 1&2, Read with section 151

C.P.C. for the issuance of ad-interim injunction restraining
the respondents/ defendants their agents, attorneys or
associates from any way or in any manner interfering and
from cutting and removing the trees standing into the
part of land measuring 120K-10M Comprised of Khewat
No. 300, Khatoni No. 641, Khasra Nos.336(20-11), 337(5-
7), 339(17-6), 340(60-7) and Khewat No Khaton.i No Khasra
Nos 866(9-12), 767(7-7) as entered in the Jamabandi for
the year 2007-08, situated in village Khudal Kalan, H.B.
No. 174, Tehsil Budhlada, District Mansa during the
pendency of the present suit.

Sir,
The applicant/plaintiff most respectfully submit as
under:-
1. That the above noted suit is being filed tociay in this

learned ·court and the contents of the plaint on the whole

may kindly be read as part and parcel of this application.
2. That it is clear from the facts stated in the plaint that the
applicant/plaintiff has got a very good prima-facie case in
his favor and the balance of convenience also lies in favor
of the applicant.

I ----
 3. That in case the relief prayed for by the applicant is not
granted, the applicant shall suffer an irreparable loss and
injury which will lead to multiplicity of litigation and t~e
very purpose of initiating the present proceedings will be
defeated .

It is therefore prayed that the present application

may kindly be allowed by issuance of ad-interim
injunction restraining the respondents/ defendants their
agents, attorneys or associates from any way pr in any
manner interfering and from cutting and removing the
trees standing into the part of land measuring 120K-10M
Comprised of Khewat No. 300, Khatoni No. 641, Khasra
Nos.336(20-11), 337(5-7), 339(17-6), 340(60-7) and
Illiewat NoKhatoni No Khasra Nos 866(9-12), 767(7-7) as
entered ih the Jamabandi for the year 2007-08, situated
in village Khudal Kalan, H.B. No. 174, Tehsil Budhlada,

I
District Mansa during the pendency of the present suit,
in the interest of justice.
Verification:- Submitted by:
Verified at Budhlada
on ~-i--- that the State of Punjab through
con t ~ the paras Sukhwinder Singh,
no . 1 to 3 of the
application are true Range Forest Officer,
and correct to the Mansa, Tehsil and
best of my knowledge
and
information
belief and

from the record.

derived
District Mansa.
I
. ...... .. Applicant
........... .. Applicant
......---
Through Counsel :
 IN THE COURT OF ADDITIONAL CIVIL JUDGE SENIOR
DIVISION, BUDHLADA.

State of Punjab Vs Karam Singh etc

( Suit for Permanent Injunction )

Affidavit in support of application U / 0 39, Rule 1&2, Read
with section 151 C.P.C.

I, Sukhwinder Singh aged about~ years, Range

Forest Officer, Mansa, Tehsil and District Mans a, do
hereby solemnly affirm and declare as under:-
!. That the above noted suit is being filed today m this
learned court and the contents of the plaint on the whole
may kindly be read as part and parcel of this affidavit.
2. That it is clear from the facts stated in the plaint that the
cte p~nent has got a very good prima-facie case in his
favour and the balance of convenience also lies in favour
of the deponent.
3. That in case the relief prayed for by the deponent is not
granted, the deponent shall suffer an irreparable loss and
injury which will lead to multiplicity of litigation and the
very purpose of initiating the present proceedings will be
defeated.

Deponent
.,,---
Verification :-
Verified at Budhlada on 3 .J. Jev..u ~ i ~r,--
the above ·
named deponent do hereby declare onliolemn affirmation
that the contents of my above affidavit are true and
correct to the best of my lmowledge and belief an d
n othing has been concealed therein.

Deponent