Page |4 3. That the statement in Para 3 of the application is made in order to invoke the jurisdiction of this Hon’ble Court. 4.That the statement made in Para 4 of the application is the matter of fact as well as record which require no comment. 5, That the statement made in Para 5 and 6 of the application is false and baseless therefore denied. 6. That with respect to the statement made in Para 7, 8 and 9 of the application it is respectfully submitted that the settled land is inheritable but non-transferable, since the object was to provide land to the landless therefore the sale of the property was void-ab-initio. It is further respectfully submitted that as per settled principle an order passed by a court having no jurisdiction is a nullity, and that its invalidity could be set up whenever and wherever it is sought to be enforced or relied upon, even at the stage of execution and even in collateral proceedings hence the Petitioner is an encroacher over the subject property being a