1823R

IN THE

HON’BLE HIGH COURT OF BANTA

AT BANTA

In the matter of

SAVIOURS OF THE NATION

[PETITIONER]

STATE OF BANTA

[RESPONDENT]

Writ Petition (Civil) No. XXXX/2022

(Under Article 226 of the Constitution of India, 1950)

MEMORIAL ON BEHALF OF THE RESPONDENT

 STATEMENT OF JURISDICTION

The Respondent has approached the High Court of Banta at Banta, to hear and adjudicate

upon the present matter through writ petition (civil) no. XXXX/2022 under Article 226 of the

Constitution of India, 1950.

The parties most humbly submit to the jurisdiction of this Hon’ble High Court

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 STATEMENT OF FACTS

1. The forest of “Wonderland” is a reserve forest [notified under Section 4 of the Indian

Forest Act, 1927] in the State of Banta within the Union of India. Wonderland forest

is the rich ever green forest having 150 species of plants and endangered species of

animals and birds.

2. The State Government of Banta, with permission from the Central Government,

started a project of establishing a biological park “Minerva” in 2020.

3. Pursuant to this, a well-known environmental group called “Saviours of the Nation”

filed a writ petition in the High Court of Banta to prevent the State Government’s

project of establishing this biological park which they believed would oust the

Adivasis who had lived there for centuries and violate their tribal rights over the land.

4. The State contended that the Adivasis would be allowed to use the forest with certain

restrictions and permissions as per the law of the land. Furthermore, the State

elaborated that they were under an obligation under the Wildlife Protection Act, 1972

to protect such species and promote conservation of the said forest.

This has come up for final hearing before the High Court of Banta

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 PRAYER FOR RELIEF
Wherefore, in the light of the facts stated, issues raised, arguments advanced and authorities
cited, it is most humbly prayed before this Hon’ble High Court of Banta that it may be
pleased to hold that:

I. The writ petition is not maintainable

II. The Respondent is justified under its obligation in the wildlife protection Act,
1972
III. The tribal Rights of forest dwellers over the land are not being violated by the
establishment of the Biological Park
and pass any other order that it may deem fit in the ends of justice, equity and good
conscience.

All of which is most humbly and respectfully submitted before this Court.

Date: 12th October, 2022 Counsel No. 1823R

Place: Banta, State of Banta

(Counsel for the Respondent)