OS 2838/2014

WRITTEN STATEMENT

IN THE COURT OF THE CITY CIVIL JUDGE AT

BANGALORE

0.S.No.2838/2014

Between:
Sri. B. Rangaswamy Plaintiff

And:
Sri. V. Krishna Defendant

MEMORANDUM OF WRITTEN STATEMENT UNDER

ORDER VIII RULE 1 OF THE CODE OF CIVIL
PROCEDURE

The defendant above named most respectfully

submits as follows:-

1. That suit filed by the plaintiff is neither maintainable

under law nor on facts and hence the suit is liable to
be dismissed in limine.

2. There is no cause of action for the purpose of suit

and one claimed, is false and frivolous and hence
suit. lacks cause of action for the purpose of suit and
suit is liable to be dismissed for want of cause of
action.

3. The plaintiff has filed present suit on the basis of

non-existent property and there is no layout forming
which include site in question as alleged. It is
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submitted that as could be seen from the Annual

Report annexed to this written statement, the
concerned authority like BDA has not approved
formation of layout covering the entire extent of land
and in fact the ITI Housing Co-Operative Society
being party to default has failed to convey the land
which are meant for civic amenities and etc., has
failed to do so and hence the Bangalore Development
Authority as rejected the Sanction of Plan which was
submitted for a area covering entire land and earlier
plan sanction did not include present survey
numbers wherein the alleged site is said to be carved
out and hence present suit is filed as against non-
existent property and hence liable to be dismissed for
identity of the property in question.

4. REGARDING PARA NO. 3: The averment that

property bearing Site NO. 687, measuring about East
to West: 40 Feet and North to South: 60 Feet situated
at Nayandahalli Village, Kengeri Hobli, Bangalore
South Taluk and description of property is hereby
specifically denied as false and frivolous. It is
submitted that alleged site is shown to be part of
parcel of Plan Submitted for Approval which covers
an area of where the alleged site is said to have
situated is never approved by the Bangalore
Development Authority and BDA has issued an
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endorsement in this regard and hence very identity of

property being in dispute the question of allotting it
by the society to the Plaintiff and plaintiff possession
are all false pleading and there is no truth in it and
hence the plain lacks particulars which are required
to Identity the property and thus averment made as
to property in question is hereby specifically denied
as false and frivolous. It is further submitted that
plaintiff who claims to have acquired under is a Co-
Operative Society by name ITI Employees Housing
Co-Operative Society Ltd., (Hereinafter referred to as
Society) is a Co-Operative Society registered under
the provisions of Karnataka Co-Operative Societies
Act and rules made there under is under supervision
of Registrar of Co-Operative Societies and its
subordinate Authorities. It is submitted that since
the maladministration of Society is alleged and
brought to the notice of the Registrar leading to
conducting Enquiry Into affairs of Society, which
ended in Reporting for correction methods wherein it
was alleged and proved that Plaintiff herein by
colluding with Plaintiff in O.S. NO. 2836/2014 have
executed alleged Sale to each other wherein they
themselves without permission or authority have
executed Sale Deed in respect of Land for which
extent society never formed layout and consequently
after holding enquiry, the Registrar of Societies was
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pleased to Direct the Society to take steps to cancel

alleged sale deed as it is illegal. However, present
plaintiff who was Officer Bearer holding Post of
President of Society has influenced other office
members not to take steps in this regard and mis-
deeds intelligently pushed under carpet though in
view of Order passed by the Registrar of Co-Operative
Societies has passed suitable order directing
necessary steps for cancellation of alleged deed.
Hence, alleged Schedule Property is not in existence
moreover it was never allotted to the plaintiff as there
was no Plan Sanction accorded by the Bangalore
Development Authority. That in view of above the
question of existence of property, formation of layout
in which schedule property situated, possession
certificate, consequent maintaining of katha in his
name all becomes doubtful and hence suit is on this
count alone liable to be dismissed.

5. REGARDING PARA NO. 4: The averment that, ITI

Employees Housing Co-Operative has acquired the
properties situated at Nayandahalli Village in all
totally Extent of 40 Acres 4.05 Guntas from different
Land Lords and this pleading in absence of
particulars of lands cannot be commented by this
defendant as he is not aware for which property the
plaintiff is referring to is not clearly apparent and
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hence it is hereby specifically denied as false and

frivolous. Further averment that after acquisition the
possession was taken has been taken and layouts
has been formed in the acquired lands situated at
Nayandahalli Village, Kengeri Hobli, Bangalore South
Taluk is also not within the knowledge of this
defendant as particulars of land is not available and
hence it is hereby specifically denied as false. It is
submitted that there is no provision in the Land
Acquisition Act, permitting an Co-Operative Society
to acquire land and such power is vested in the
Government and hence very contention of plaintiff
that society acquired land is clearly false one as there
is no pleading in respect of procedure followed in
respect of acquisition of land and source of power of
Society in this regard, Hence, pleading to this effect is
apparently false pleading and hence plaintiff cannot
get any advantage of such false pleadings which is
perse false and legally unsustainable. Hence, suit of
plaintiff is liable to be dismissed. Further averment
that in respect of the suit schedule property had been
allotted by the Society represented by the President
and executed the absolute registered sale deed on
16-06-2003 in favour of plaintiff is absolutely false in
view of facts stated above and hence very claim of
plaintiff is baseless and once pleading in this regard
is false pleading and hence it is hereby specifically
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denied as false. The document produced is not a

valid document in view of proceedings held by the
Registrar of Co-Operative Society as there was no
consent of the Society in this regard and plaintiff by
misusing the powers and colluding with plaintiff in
O.S.NO. 2836/2014 have got executed alleged
document in their favour by getting it executed by
each other to benefit them without any prior approval
of Society are any authority on behalf of society and
hence it cannot confer any valid title on the title as
very property in question is non-existent property
and hence the document is concocted document to
suit the needs of the plaintiff, under these facts and
circumstances the suit is liable to be dismissed on
this count alone.

6. REGARDING PARA NO. 5: The averment that after

execution of sale deed has been executed by the
society possession certificate has been issued on 07-
08-2003 in respect of suit schedule property is
absolutely false and hence it is hereby specifically
denied as false. It is submitted that since there is no
validity attached to the alleged sale deed which is
sham document which cannot confer any right, title
or interest over the property and hence question of
possession certificate does not arise at all. Hence,
any averment in this regard is hereby specifically
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denied as false. The averment in respect of issuance

of No Objection Certificate on 31-12-2004 in favour of
plaintiff is another inconsequential document as the
particulars for which alleged NOC is issued is not
forth coming, hence this defendant denies the
document by reserving his liberty to dispute the
document once the purpose for which the alleged No
Objection Certificate is made known to be reserved.
The No Objection Certificate is fabricated document
and hence it is hereby specifically denied as false.

7. REGARDING PARA NO. 6: The averment that after

clearance from the society the plaintiff has
approached BBMP to for katha in favour of plaintiff
in respect of suit schedule property is again false
version put forth by the plaintiff and hence it is
hereby specifically denied as false. It is submitted
that according to plaintiff Society has executed a Sale
deed in his favour during 2003 and issued
possession certificate and thereafter no objection was
issued during 2004, if that were to be true then there
nothing for Society to issue clearance certificate and
it is not known that for what reason clearance is
issued. It is submitted had the plan submitted was
approved then BDA itself at that relevant point of
time would have maintained Katha in respect of
alleged schedule property upon fulfilment of terms
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and conditions of Sanction accorded. However, at no

point of time either BDA or Corporation or any other
authority has maintained Revenue Records and
hence it clearly evident that all is not well with
society in its dealing. Hence, the grievances of the
plaintiff if any should be against the Society and not
with the defendant herein as the Society itself could
not prove so called alleged acquisition in its favour
and in absence of it the plaintiff does not have any
locus standi to file present suit against defendant.
That averment that accordingly BBMP on Verification
during 2010 Issued property identification number is
false and it is hereby specifically denied as false. It is
submitted in absence of any proper and valid order
Sanction by the concerned authority the question of
formation of layout, maintaining the revenue record
etc., does not arise at all. It appears that alleged
katha if any is in respect of non-existent property.
Further production of alleged Katha Certificate does
not lead plaintiff anywhere as in absence of identity
of property the question of maintaining the revenue
records becomes immaterial and the document
produced have no bearing on the suit or suit
schedule property.

8. REGARDING PARA NO. 7: The averment that after

the katha have been issued in favour of plaintiff, the
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plaintiff has paid upto date taxes to the suit schedule

property and accordingly the BBMP has collected the
tax and production of alleged Tax Paid Receipt are all
false and it is hereby specifically denied as false. At
the cost of repeating it is stated that when the alleged
Layout itself is not formed as there was no sanction
accorded by the competent authority the question of
maintaining of Katha in respect of alleged property is
of no consequences.

9. REGARDING PARA NO. 8: The averment that since

from the date of execution of sale deed by the society
and thereafter the possession certificate and no
objection certificate have been issued by the Society
in favour of plaintiff and since then the plaintiff had
been in absolute possession and enjoyment of the
property is absolutely false and it is hereby
specifically denied as false. It is submitted in absence
of formation of layout as per law the question of
formation of layout etc., does not have any credence
and hence said contention at the threshold itself is
liable to be rejected and Ignored.

10. REGARDING PARA NO. 9: The averment of plaintiff

that the defendant absolutely has no manner or
right, title and interest in respect of Suit property is
absolutely false and it is hereby specifically denied as
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false. It is submitted the person from whom the

Society has stated to have acquired the property is
head of family of defendant and property which were
owned by the defendant and contention of the
plaintiff that suit schedule property where it is
contended to be formed in layout and in view of
illegal interference as averred by this defendant in his
property in O.S. No. 2416/2014 is property of
Defendant and his Joint family members. It is
submitted that though the notification Under Section
4(1) and 6(1) of Land Acquisition Act were published,
however Award was not passed in terms of law
stipulated there and hence by virtue of provisions
contained in Section 11A of the Land Acquisition Act
have lapsed thereby the notification under Section
4(1) and 6(1) of the Act is by law itself amounts
withdrawal of Proceedings and hence neither society
nor its members can contend otherwise and only
option left for the Society was to seek for fresh
acquisition proceedings and admittedly there is no
acquisition proceedings in this regard and hence by
virtue of Declaration of Law as contained in Section
11 A of the Land Acquisition Act, no benefits have
accrued to Society and when society could not take
benefit of proceedings the question of plaint taking
benefit of said proceedings are all contrary to law. It
is submitted that Section 11 A being Declaratory
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Provision and thus no separate proceedings are

required to prove the effect of non-passing of award
within the time stipulated and hence alleged
acquisition proceedings are all contrary to law cannot
be accepted at all. It is submitted that Society being
non-agricultural Status cannot hold the Agricultural
Land and hence very pleadings made by the plaintiff
are all false pleading and liable to be rejected.
Further averment of plaintiff that defendant is in no
way concerned to the suit schedule property and
further averment that land in different survey
numbers were acquired by the society and layout
have been formed and sale deeds have been executed
in favour of members of society are all false and it is
hereby specifically denied as false. It is submitted
that very question of acquisition is does not arise in
view Section 11 A of Land Acquisition Act, the
question of formation of layout allotment to members
does not arise at all. It is an admitted fact in Annual
Report for the year 2012-13 is published by the
Society which goes to show that alleged land are now
possessed by different persons who are not
concerned with Society and under the circumstance
very contention of plaintiff cannot be accepted at all.
The averment that defendant is total stranger to the
suit schedule property and in order to extract money
from the site holders for one or other reasons he is
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trying to interfere with peaceful possession and

enjoyment of the suit schedule property are all false
and it is hereby specifically denied as false. Further
allegation of the plaintiff that he has been trying to
interfere with peaceful possession and enjoyment of
schedule property by plaintiff and plaintiff has
approached jurisdictional police to give protection
and they have sought time to study the papers are all
false and it is hereby specifically denied as false.
Further contention that defendant is having very
high influence and political background in the
locality and with money and men power attempting
to interfere are all false and it is hereby specifically
denied as false. It is submitted that plaintiff having
obtained alleged sale deed for non-existent property
and with an intention to grab the property as a first
step filed Caveat before this Hon'ble Court and this
defendant has filed a suit in O.S.NO. 2416/2014 in
which proceedings taking advantage of non-granting
of order of Interim Nature and by dragging matter
and simultaneously filed above suit with false
averment and by suppressing actual facts. That this
Hon'ble Court after noticing that defendant in that
suit is unnecessarily dragging matte and on 25-4-
2014 order for maintaining Status-Quo and even at
that point of time plaintiff herein did not disclose
regarding granting T.I. in his favour in above matter
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as the vacation is fast approaching kept quiet and

suffered an order of Status Quo till filing of Written
Statement and objections. This approach of plaintiff
is highly depreciable as he suppressed the fact of
granting of T.I. on 10-04-2014 against this
defendant. However, when the matter posted on 31-
05-2014 plaintiff herein filed written statement
disclosing other things apart from pleading of this
case. Further even on that day plaintiff did not
disclose regarding granting of T.I. In his favour and
on the other hand kept watching without informing
the court regarding passing of order in suit filed
above. Even when the matter was posted on 02-06-
2014 from 31-05-2014 to hear on application for TI
in spite of submission made in this informing that
plaintiff being defendant in that suit as in his written
statement made averment of filing of above suit and
granting of TI in his favour and even on that in spite
of submission made by the counsel in that did not
submit at least orally regarding granting of TI in his
favour on the other hand finding attitude of this
plaintiff, the Hon'ble Court was pleased to extend
order of Status Quo till 15-06-2014. In this regard it
is submitted that approach of plaintiff is not at all
correct and proper and there are not only
suppression of facts and circumstances but also
suppression of passing of order except stating in
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written statement. This conduct on the part of

plaintiff clearly goes to show that plaintiff intending
to mis-use the order so as to take possession of
alleged land did not inform court. Hence, this
conduct coupled with surrounding circumstances
give only Impression that plaintiff is not in
possession of alleged suit schedule property. Hence,
the suit of plaintiff is liable to be dismissed for
suppression of facts and circumstances.

11. REGARDING PARA NO. 10: Further averment that

jurisdictional police have not given protection to the
plaintiff are all false and frivolous and it is hereby
specifically denied as false. It is submitted since
Order of Status Quo was given in O.S.No. 2416/2014
and on finding attempt of plaintiff to take possession
of this defendants property, this defendant has
lodged a complaint on 19-05-2014. However, even
before the jurisdictional police this plaintiff did not
disclose order of TI granted with oblique motive. The
jurisdictional police in view of dispute being Civil in
Nature have advised appropriately in this regard to
the parties. Hence, the conduct of plaintiff herein is
not at all acceptable as plaintiff is in habit of
suppressing real facts and circumstances of the case.
That further averment that plaintiff has given
complaint to Commissioner of Police, and other
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authorities are not within knowledge of this

defendant and hence it is hereby specifically denied
as false and frivolous and plaintiff be put to strict
proof of it. It is submitted that plaintiff instead
approaching the Court and other authorities with
clean hands has suppressed certain facts and
circumstance and hence plaintiff is guilty of
suppression. All other averment in this paragraph is
hereby specifically denied as false.

12. REGARDING PARA No.11: The averment that during

3d Week of March, 2014 when plaintiff started to put
up fencing In the suit schedule property the
defendant has all of sudden came near the suit
schedule property and advised plaintiff not to put up
any compound till the settlement had been made are
all absolutely false and it is hereby specifically denied
as false. This defendant submits that since the
plaintiff made efforts to interfere with and dispossess
this defendant from his property and hence left with
no other option has filed a suit in O.S. No.
2416/2014 and before this plaintiff made such
efforts he has filed a Caveat Petition before this
Hon'ble Court with a sole intention that if this
defendant were to approach Court of law for any
relief he could take advantage of situation as no
order is passed till caveator is heard and it is then
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only the plaintiff made efforts to dig the property of

this defendant which was resisted and since the
plaintiff was in no mood to hear and as such this
defendant has filed a suit in O.S.NO. 2416/2014. The
conduct of plaintiff speak louder than his words and
hence the plaintiff is not entitled for any relief much
less one claimed in this suit and suit is liable to be
dismissed.

13. REGARDING PARA NO. 12: The averment that on

perusal of document goes to show that plaintiff is
absolute owner and in lawful possession and
enjoyment of it are all false and frivolous and it is
hereby specifically denied as false. Further, averment
this defendant has no manner of right, title or
interest and to extract money in one or other way
trying to interfere with plaintiff's peaceful possession
and enjoyment over property are all false and they
are hereby specifically denied as false. That all other
averment in the paragraph are which are not
specifically traversed are hereby specifically denied
as false.

14. REGARDING PARA NO. 13: That there is no cause

of action for the purpose of suit and one claimed is
false and fictitious, imaginary and hence suit is also
liable to be dismissed for want of cause of action.
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15. That the plaintiff is not entitled for any relief much
less one sought for as alleged suit schedule property
is non-existent property of which the plaintiff was
never in possession and with an intention to knock
off this defendant property plaintiff has not only
created document to suit his needs but also made
effort to grab the property. It is submitted that as
already stated in view of proceedings before the
Registrar of Co- Operative Societies wherein a specific
direction was issued to society to cancel the alleged
sale deed as it was not legally allotted, however, the
plaintiff by manipulating the officials of Society as he
was once Holding office of President has silenced
them and now based on illegal documents to take
possession of this defendant's property hence the
plaintiff is not entitled for any relief.

16. That averment which are not specifically traversed

are hereby specifically traversed and specifically
denied as false.

17. This defendant submits that in respect of Land in Sy.

No. 60 which property Originally belongs to joint
family of this defendant is an undisputed fact. In
respect of said property the Society herein has filed a
suit in O.S.NO. 3285/2012 for the relief of
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permanent injunction against this defendant inter

alia contending that land in question was acquired
for formation Residential Sites Layout for its
employees alleging that Society is in possession of
land in Sy.NO. 60 of Nayandahalli Village measuring
about 3 Acres 22 Guntas excluding Phot Karab Land.
In the said matter this defendant has entered his
appearance and while objecting Interim Order which
was to the effect restraining from putting up
construction has stated that he has nothing to do
with construction in question and also contended
that in view of Section 11 A of Land Acquisition Act
the proceedings have lapsed and Society does not
any manner of right title or interest in the property in
question. However, this Hon'ble Court was pleased to
grant TI which was challenged in MFA 4757/2013
before the Hon'ble High Court of Karnataka,
Bangalore however wile hearing the matter in view
certain facts which were not specifically consider and
hence by Reserving liberty to file Review application
MFA 4757/2012 was disposed off. In the mean while
since the matter reached stage of trial after framing
of issued the defendant herein to co-operate with
proceedings did not choose to file application for
review. It is submitted that in the instant case
Society alleges it is in possession of Entire land in
Sy.No. 60, measuring about 3 acres 22 guntas
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excluding phoot karab land and by suppressing facts

society has filed suit as stated above. However,
within a span of some time present plaintiff has filed
suit by contending that Site NO. 687 was allotted to
him and registered deed is executed in his favour. It
is submitted as per the information furnished by the
Bangalore Development Authority it has accorded
Plan Sanction only in respect of 26 plus acres in first
plan submitted. However, since the Society did not
convey public utility land to BDA the plan respect of
55 plus acres (which include 26 acres stated above)
is not accorded and rejected. The intimation
furnished by the Bangalore Development Authority is
herewith produced and marked as ANENXURE 1.
However, by suppressing rejection of approval for
formation of layout on 55 acres of land the Society
appears to have allotted sites which were not at all in
existence as there was no sanction of plan by the
competent authority and in absence of approval of
layout the question of allotment to its members is not
at all acceptable more so on the Face of Section 11 A
of Land Acquisition Act. Further it is submitted that
had the Society is in possession of entire Land as
stated supra claim by the plaintiff that he is in
possession becomes perse false contention, on the
other hand if the possession of plaintiff were to be
accepted then Possession of Society is perse false and
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however surprisingly and clandestinely alleged

Sanction Plan which was submitted for approval from
BDA for land to an extent of Land of more than 55
Acres is not at all produced to arrive at just and
proper conclusion. Hence, the plaintiff as well as
Society is guilty of laches and suppression of facts.
Given the situation that alleged Acquisition
Proceeding has lapsed since no Award is passed
within 2 years from the date of 6(1) Notification
excluding the period consumed in any litigation in
respect of particular land leaves no doubt that there
was no acquisition proceedings which is worth to
consider, hence Society is not properly functioning
and there are misdeeds committed by the Office
bearers in knocking off the property and hence there
is no valid title with Society so that it could transfer
any better title to plaintiff. To crown with mis-deeds
of Society alleged award amount legally payable to
Owners of land and in the instant Award money is
paid to one M/s. Kala Enterprises, which is having
nothing to do with property, hence it is crystal clear
that all is not well with Society and it is not properly
functioning and there are certain misdeeds and
illegal acts which requires probe by appropriate
probing agency.
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18. Further, as already stated it is submitted that there

was an enquiry conducted by the Registrar of Co-
Operative Society regarding misadministration of
Society and it is held that present plaintiff and
plaintiff in O.S NO. 2836/2014 while acting President
of Society have got executed alleged sale deed in
favour by one by one to another and there was no
sanction or approval of society and after holding so,
the Registrar of Societies has directed Society to take
Steps to cancel alleged deed which do not have any
legal sanctity. The Society instead of taking steps in
this regard and pushing such direction under carpet
kept quiet and its office bearers who are aware of this
Direction has maintained godly silence showing their
obedience to the earlier Office Bearers who virtually
ruined the Society and its objectives for which it was
formed. Copies of the Direction issued by the
Registrar of Co-Operative Society is herewith
produced and marked as ANNEXURE - 2 and 3.

19. The defendant herein came to know about these facts

when unfortunately came in possession of Annual
Report for the period for 2012-13 wherein it is
specifically stated in respect of misdeeds done. Copy
of Annual Report is herewith produced and marked
as ANNEXURE- 4.
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20. The Society and its office bearers are hand in glove in
misguiding the authorities to suit their needs and
virtually Society is being misused for personnel gains
of the Office Bearers. Hence, it requires appropriate
probe in this regard by the concerned as to validity of
Society and its functioning. It is further submitted
that there are many land which still in the hands of
owners and possession was never taken from them
and this defendant and other of his family member
being some among them who continued to possess
land in which present suit schedule property is
alleged to be situated. Hence under these
circumstances the plaintiff herein is not entitled for
any relief much less one claimed by him. Hence, suit
of plaintiff is liable to be dismissed.
PRAYER
WHEREFORE, the defendant above named most
respectfully prays that this Hon'ble Court be pleased
to DISMISS the suit of plaintiff by imposing
exemplary costs on plaintiff in favour of this
defendant and further be pleased to pass such other
order or orders and be pleased to grant such other
relief or reliefs as this Hon'ble court deems fit under
the facts and circumstances of the case in the
interest of justice and equity.
Sd/- Sd/-
ADVOCATE FOR DEFENDANT DEFENDANT
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VERIFICATION
I, the defendant above named do hereby state and
declare that whatever stated in above paragraph NO.
1 to 20 are true and correct to the best of my
knowledge, information and belief.

BANGALORE Sd/-
DATED:11-06-2014 DEFENDANT
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IN THE COURT OF THE CITY CIVIL JUDGE AT

BANGALORE

0.S.No.2838/2014

Between:
Sri. B. Rangaswamy Plaintiff

And:
Sri. V. Krishna Defendant

VERIFYING AFFIDAVIT
I, V. Krishna, Son of Late. Venkatanarasimhaiah,
aged about 50 years, Residing at NO. 143/1,
Nayandahalli, Mysore Road, Bangalore 560 039, do
hereby solemnly affirm and state on oath as follows:-

1. I submit that I am the defendant in the above

case and I know the facts and circumstances of the
case and hence I am swearing to this affidavit.

2. I submit that Contents of Para NO. 1 to 20 of

accompanying written statement are true and correct
to the best of my knowledge, information and belief.

3. I submit that Documents furnished along with

written statement are Original and copies of Original.

I, the deponent above named do hereby solemnly

affirm and state on oath that whatever stated above
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are true and correct to the best of my knowledge,

information and belief.

Identified by me
Sd/- Sd/-
ADVOCATE DEPONENT
BANGALORE SWORN TO BEFORE ME
11 JUNE 2014