Points need to be amended in the Regular Civil suit no 825/2012

1. We need to amend the description of the property In order to take the benefit of the permission given by the

high court in order to amend the suit So that exact boundaries of the share of sharad can be

mentioned in the suit property in the suit and the decree and be drawn accordingly for possession.

It is advised that separation of the rest of survey numbers is essential so as to keep the dispute of possession restricted to the survey no 6/4-7 this only issue on which confusion was there in High court in Appeal From order of Kharat court

2. We need to bring on the record encroachment done by the occupants of the hutments and tea stall

We need to take a call on paper that whether the encroachment is done by sharad or occupants of the hutments and tea stall

If , we do not separate other survey no. property then what will be the area description wherein encroachment is done

We need to get the accurate details of the people residing or conducting business in suit properties so that we can make them parties in the suit

We need the sketch so as to locate the existing of hutments survey no. wise.

It is advisable to lodge fresh police complaint wherein we complain of regarding loss of possession by force and muscle power of Sharad kokane so that till the date of high court order to amend it will be considered as we were in possession because till that time we have not admitted loss of possession by us .so that cause of action and limitation for amendment can be shown and also that we have not used till date .

3. In amendment we need to challenge correction deed dated 05/02/2014

We need to make all the executants party to the suit. All the executants of partition deed had not signed this correction

deed. Correction deed only for survey no. 6/4 to 7and not in other

survey no. Correction deed done in order to frustrate the boundaries of the

share acquired by plaintiff. Correction deed done after selling the property without any rights

and interest in property Correction deed done in order to encroach upon the share which

was not owned by defendant and was not affected by acquisition by P.C.M.C.

As per clause 5 of correction deed this document comes into effect from the date of partition deed 2007 which is not feasible because already all the executants of the correction deed have acted upon the partition deed of 2007 many document have been registered now the correction deed after 7 years is bad in law .

4. In amendment we need to challenge correction deed dated 05/02/2014

All the confirming parties have sold the properties and after that in order to get other properties relieved from the clutches of defendant confirming party have executed this documents .

This document is executed to frustrate the boundaries of actual piece of land lying in the share of defendant which was acquired by plaintiff.

The 7/12 extract annexed to the confirmation deed is forged one wherein the cultivation entry of 11/12 is concealed and the signature and stamp of Talathi has been affixed from some other 7/12 extract and photocopy has been obtained which can be witnessed by comparing the two 7 /12 extract of the same month .

5. In the amendment we need to seek the prayer for removal of the hoardings

Hoardings are large in size than what is permitted by the corporation

Hoardings are not placed on the land where it is permitted It is causing loss of the fees and charges payable to the

corporation Need to add the shubhangi advertising as party to the suit.

6. We have already filed police complaint against unknown people attempting encroachment do we need to take all that on record .

7. Finally do we want amendment and then High Court to allow fresh suit in appeal amendment rejected or dismissal & then restoration.

8. We need to lodge Police complaint for loss of original documents urgently if any as told by Amit P.