Appeal Harjeevan Kaur
Appeal Harjeevan Kaur
Appeal Harjeevan Kaur
Powers of Commissioner).
Application No. _______ of 2024
IN
Appeal No.________ of 2024
Index
Dated:
Place:Chandigarh
Through Counsel:
I.P.S. Mangat
P-1493-2011
(Advocate)
1
Dated:
Place: Chandigarh
Through Counsel:
I.P.S. Mangat
P-1493-2011
(Advocate)
3
AFFIDAVIT
Dated: Deponent
VERIFICATION
Dated: Deponent
4
Sir,
1. That the above titled appeal has been filed in this Hon’ble Court
today.
2. That the true facts have been stated in the grounds of appeal
and the same be read as part of this application to avoid further
repetition.
7. It is, therefore, prayed that till the final disposal of the above
titled appeal, the operation, execution and implementation of the
impugned order may kindly be stayed, in the interest of law and
justice.
Dated:
Place:Chandigarh
Through Counsel:
I.P.S. Mangat
P-1493-2011
(Advocate)
6
AFFIDAVIT
Dated: Deponent
VERIFICATION
Dated: Deponent
7
Dated:
Place: Mohali
Through Counsel:
I.P.S. Mangat
P-1493-2011
(Advocate)
9
AFFIDAVIT
Dated: Deponent
VERIFICATION
Dated: Deponent
10
1. Kuldeep Singh Sandhu, Dream City NXT, Near DPS School. G.T,
Road, Village Manawala District Amritsar.
2nd address:
Dream City NXT, 18th Floor, Pent House, Narain Manjil 23,
Barakhamba Road, Connaught Palace, New Delhi-110001
through its Prop. /Authorized Signatory.
---APPELLANTS
Versus
---RESPONDENT
CLAIMS IN APPEAL
GROUNDS OF APPEAL
Sir,
The grounds of appeal are as under: -
asking for eviction of the applicants, a request had been made for an
onsite spot verification to ascertain the actual position and to adjudge
whether any form of encroachment has been done by the applicants or
not.
8. That the applicants also submitted before the Ld. Collector
that prior to the construction of the colonies due approval had been
accorded by the department of Housing and Urban Development and
also NOC had been obtained from the Executive Engineer, Canal and
Drainage Department, Jandiala Guru ABDN, Amritsar.
10. That the order under appeal, which is not speaking one, is
based upon mere surmises and conjectures of the learned officer
below.
11. That the learned officer below has failed to observe that
the appellant is entitled to the relief prayed for and that the petitioner
has not come to the Hon’ble Court with clean hands and has
suppressed the true and material facts from the Hon’ble Court and that
the application deserves dismissal with heavy costs.
12. That the learned officer below has failed to observe that
the there is no unauthorized occupation by the applicants upon the
revenue rasta or even the Khal in question as due permissions have
already been taken from all concerned departments and even proper
NOC has been issued by the department of Canal and Drainage.
13. That the learned officer below has failed to observe that
the land in question is not to be purchased by the applicants rather the
14
same is to be acquired by the State Govt. and payment for the same is
to be made to the Gram Panchayat in light of the notification Annexure
A-2.
16. That the order under appeal is not speaking one and
further, the same is without any foundation or basis.
17. That the learned officer below has wrongly passed the order
under appeal and the same has caused a great loss, grave injustice,
prejudice and irreparable injury to the appellant and in case the order
under appeal is not set-aside, the appellant shall suffer further huge
loss and irreparable injury, not to be compensated in any terms lateron
and there shall be failure and miscarriage of justice as well.
I.P.S. Mangat
P-1493-2011
(Advocate)
16
Dated: Deponent
VERIFICATION
Dated: Deponent