Memorial Petitioner

IMS UNISON UNIVERSITY 3rd NATIONAL MOOT COURT COMPETITION 2015
TEAM CODE.
BEFORE THE
HONBLE SUPREME COURT OF JUDICATURE
AT
NEW DELHI, INDIA
STATE GOVERNMENT OF MITHILA .PETITIONER
V/S.
SPARTA INDIA PVT. LTD. ...RESPONDENT
MEMORIAL ON BEHALF OF THE PETITIONER
MEMORIAL ON BEHALF OF PETITIONER 1

TABLE OF CONTENTS
List of abbreviations ...III

Index of authorities .IV
1. Case list
2. Books referred
3. Websites
Statement of jurisdiction .V
Statement of facts ...VI
Statement of issues .VIII
Statement of argument IX
Argument advance...(12-26)
1) Issue 112
2) Issue 2 ...13-17
3) Issue 318-19
4) Issue 420-21
5) Issue 522
6) Issue 623
PrayerXXIV
LIST OF ABBREVITIONS
& And
A.I.R. All India Reporters
CONST. The Constitution of India
HONBLE Honorable
ORS. Others

SC Supreme Court
SSC Supreme Court Cases
V./VS. Versus
UOI Union of India
LTD. Limited
ART. Article
PVT. Private
INDEX OF AUTHORITIES
CASE CITED:
1. Abdul rehman v. Pinto1
2. Ashutosh Gupta V. State of Rajasthan
3. Chiranjit lal v. Union of India2
4. Gauri Shankar V. UOI
5. Jagjit singh v. State3
6. Jaila Singh V. State of Rajasthan
7. Janmi Khandsari V. State of U.P.4
1 AIR 1951 Hyd 11
2 AIR 1951 SC 41
3 AIR 1954 Hyd 28

8. Koshila Devi v. Parvati Devison5

9. Monoponier co. v. City of Los Angeles6
10. R.K. Garg v. UOI7
11. M. karunanidhi V. UOI8
BOOKS:
1. Indian constitutional law (lexis Nexis) by M.P. Jain 7th edition 2014.
2. Constitutional law of India (Universal law publishing) by H.M. Seervai vols.1
reprinted 2008.
STATEMENT OF JURISDICTION
The Petitioner s has approached the Honble Supreme Court of India under article 132 of
Constitution of India.
4 AIR 1981 SC 831
5 6 September,1978
6 33 Cal App .675
7 AIR 1981 SC 2138
8 AIR 1979 SC 898

STATEMENT OF FACTS
Mithila is state of the Indian union which is located in eastern part of the union. The state is
among top 3 states in the production of rice and hence its economy is vastly dependent on
agriculture. This state is one of the most politically sensitive states with frequent political clashes
between the different political parties. the Chief Minister emphasized on the fact that the state of
Mithila although quite stable in agricultural sector, needs a boost in the industrial field as was
promised in the election manifesto. He gave an open invitation to the corporate houses to come
and setup industries in the state to boost the economy of the state which was not in a good shape.
The Sparta India Pvt. Ltd which was an industrial giant of India announced that they would soon
launch a new and affordable car called the Sparta Giano which according to them would be
revolutionalize the Indian automobile sector. In joint press conference Mr. Gautamdev Pandit
was chief minister of Mithila and Mr.Sudeep Sparta Chairman of Sparta Group decided to setup
the plant in Bangur, to plant the industry of Sparta Pvt. Ltd. about 950 acres of agriculture land
on behalf Sparta Group. Sparta Group will provide compensation and employment to the
families of the farmers whose land would be acquired.
It was said that the state government would acquire 950 acres of agricultural land on behalf of
Sparta Group and the Sparta Group shall provide compensation and employment to the families
of the farmers whose lands would be acquired. Bangur is located in the district of Srirampur. It is
known to be one of the most fertile areas of the country.

The Federal Party of India was the main opposition party espoused the cause of the farmers who
were against the land acquisition. M.s.Seema Thakur who was leader of opposition organizing
violent protest and dharnas all across the state warned the Government of mass agitation if it
went ahead with its plan of acquisition. But Government being hell bent on land acquiring the
land, using massive police force which resorted to lathi charge, tear gas and water canon
acquiring land in October, 2008 and handed over Sparta Group.
The Sparta Group began the construction work of Giano plant and by August 2009 the plant was
ready to undergo the production. Meanwhile, Ms. Seema Thakur, continued her allegation. The
sit in protest which continued for two long months ultimately forced the Sparta Group to
withdraw the project from the site although they did not part with the possession of the land.
Owing to high anti-incumbency wave, the Federal Party of India was voted to power in the
Assembly Elections of 2013 and Ms. Seema Thakur became the Chief Minister of the state.
Acting promptly on the promise made before Elections, in the first cabinet meeting of the state it
was agreed that law would be made acquire 950 acres of land in Bangur and hand over 400 acres
back to the unwilling farmers and utilize the rest for the other purposes.
The State Government in its first Assembly Session introduced the Bangur Land Rehabilitation
and Development Bill, 2013 and passed it in the same session amidst huge protest from the
opposition party. The Governor of Mithila assented to the bill which came into force from 1st
November 2013. The primary object of the Act was to acquire the land from the Sparta Group
and return 400 acres land to the unwilling farmers from whom earlier the land was acquired and
utilize the rest for some purpose beneficial to the people.
Soon after the Act, the state Government took possession of the 950 acres of land from the Sparta
Group. The Sparta Group immediately challenged the constitutional validity of the Act in the
High Court of Mithila as violative of Article 14 of the Constitution of India on the ground that
the Act failed to answer the test of reasonable classification. Being aggrieved by the judgments
the Sparta Group filed an appeal in the division bench of the High Court of Mithila which
declared the Act to be unconstitutional and void.
The Division Bench held that this Act Land acquisition is a concurrent subject and some of
provisions of the law are in conflict with Central Land Acquisition, Rehabilitation Act, 2013. The

Act was held violative of Article 14 of the Constitution of India as it failed to satisfy the test of
reasonable classification and intelligible differentia. The bench also observed that state
government has not sought the assent of President of India which according to its necessary for
such an Act. Further the High Court of Mithila observed that there was only a mention term
refund in the Act and no clear cut compensation scheme was provided.
Aggrieved by the decision of the High Court of Mithila, the State Government preferred to
appeal to the Supreme Court of India. The Supreme Court of India admitted the appeal and listed
it for final hearing.
STATEMENT OF ISSUES
ISSUE: 1 whether this Appeal is Maintainable?
ISSUE:2 Whether the Bangur Land Rehabilitation and Development Act, 2013 is violative of
Article 14 of the Constitution of India?
ISSUE:3 Whether the consent of the President of India was essential for the Bangur Land
Rehabilitation and Development Bill, 2013?
ISSUE:4 Whether the absence of Social Impact Assessment clause renders the Bangur Land
Rehabilitation and Development Act, 2013 repugnant to the Central Land Acquisition,
Rehabilitation and Resettlement Act, 2013?
ISSUE:45 Whether the acquisition of land under the Bangur Land Rehabilitation and
Development Act, 2013 fulfills the criteria of public purpose as mentioned in the Central Land
Acquisition, Rehabilitation and Resettlement Act, 2013?

ISSUE:6 Whether the refund clause mentioned in the Bangur Land Rehabilitation and
Development Act, 2013 is legally valid?
SUMMARY OF ARGUMENTS
ISSUE :1 Whether this Appeal is Maintainable?
The powers given by Article 132 are in the nature of appellate jurisdiction which is exercisable
outside the purview of the ordinary law relating to appeal, in cases where needs of justice
demand interference by the Supreme Court of the land. In the matter of entertaining and hearing
appeals, by granting of special leave, against any kind of judgment or order made by a court or
tribunal in any cause or matter and the power could be exercised in spite of the specific
provisions for appeal contained in the constitution or other laws. The constitution did not for the
best of reasons choose to fetter or circumscribe the powers exercisable under this article in any
way
ISSUE:2 Whether the Bangur Land Rehabilitation and Development Act, 2013 is violative of
This act not violative of the constitution of India on the ground that the act failed answers the test
of reasonable classification. Because the test of reasonable classification said that while Article
14 forbids class legislation it does not forbids reasonable classification of persons, objects and

transaction by the legislature for the purpose of achieving specific ends. Classification to be
reasonable must fulfill the following two conditions:-
(a) Intelligible differentia which distinguishes persons or things that are
grouped together from other left out of the group.
(b) The differentia must have a rational relation to the object sought to be
achieved by the act.
ISSUE:3 Whether the consent of the President of India was essential for the Bangur Land
Under the const. of India Article 246(2) notwithstanding anything in clause (3), parliament , &,
subject to clause (1), the legislature of any state also, have power to make laws with respect to
any of the matter enumerated in the list III in the seventh schedule (in this const. referred to as
the concurrent list).
ISSUE:4 Whether the absence of Social Impact Assessment clause renders the Bangur Land
There is no absence of the Social Impact Assessment clause in this Act (Bangur Land
Rehabilitation and Development Act, 2013) because the main objective of this act was to acquire

the land from the Sparta Group and return 400 acres land to the unwilling farmers from whom
earlier the land was acquired and utilize the rest for some purpose beneficial to the people.
ISSUE:5 Whether the acquisition of land under the Bangur Land Rehabilitation and
Development Act, 2013 fulfills the criteria of public purpose as mentioned in the Central Land
Yes this act fulfills the criteria of public purpose because the primary element of this
act is too beneficial to the people of Mithila according to centrals land acquisition,
rehabilitation and resettlement act, 2013:
Whereas it is expedient to provide for taking over of the land covered by the lease granted to
Sparta group ltd. For the sole purpose of affordable cars called the Sparta Giano manufacturing
project and letters of allotment issued to the vendor as recommended by Sparta group ltd. In
view of non-commissioning and abandoning affordable cars project and ancillary factories with a
view to returning such portion of land to unwilling owners thereof, who have not accepted
compensation and utilized the balance portion in public interest and for the benefit of the state:

ISSUE:6 Whether the refund clause mentioned in the Bangur Land Rehabilitation and
Yes the refund clause which is mentioned in the Bangur Land Rehabilitation and
Development Act, 2013 is legally valid. Because the amount which is to be refund is complete by
the way of full legal path. The amount of the compensation would be adjudged and determined
by the district judge, mithila on an application being made by Sparta group ltd. In due
compliance with the principal of natural justice and by reasoned ordered.
ARGUMENTS ADVANCED
1. Whether this Appeal is Maintainable?
The powers given by Article 132 are in the nature of appellate jurisdiction which is exercisable
outside the purview of the ordinary law relating to appeal, in cases where needs of justice
demand interference by the Supreme Court of the land. In the matter of entertaining and hearing
appeals, by granting of special leave, against any kind of judgment or order made by a court or
tribunal in any cause or matter and the power could be exercised in spite of the specific
provisions for appeal contained in the constitution or other laws. The constitution did not for the
best of reasons choose to fetter or circumscribe the powers exercisable under this article in any
way

2. Whether the Bangur Land Rehabilitation and Development Act, 2013 is violative of
This act is not violative of the const. of India on the ground of the act failed to answer the test of
reasonable classification. Because the test of reasonable classification said that while article 14
forbids class legislation it does not forbids reasonable classification of persons, objects and
transaction by the legislature for the purpose of achieving specific ends. Classification to be
reasonable must fulfill the following two conditions:-
(A) Intelligible differentia which distinguishes persons or things that are grouped together
from other left out of the group.
(B) The differentia must have a rational relation to the object sought to be achieved by the
act.
Article 14 permits classification but prohibits class legislation: the equal protection of law
guaranteed by article 14 does not mean that all laws must be general in character. It does not
mean that the same laws should be applying to all persons. All persons are not, by nature,
attainment or circumstances in the same position. The varying needs of different classes of
person often require separate treatment. From the very nature of the society there should be
different laws in the different place and the legislature control the policy and enacts laws in the
best interest of the safety and security of the state. In fact, identical treatment in unequal
circumstances would amount to inequality. So, a reasonable classification is only not permitted
but is necessary if society is to progress.

Thus, what article 14 forbids is class legislation but it does not forbids reasonable classification.
The classification, however, must not be arbitrary, artificial or evasive but must be based on
some real and substantial distinction bearing a just and reasonable relation to the object sought to
be achieved by the legislation. Article 14 applies where equals are treated differently without any
reasonable basis. But where equals and unequals are treated differently, article 14 does not apply.
Class legislation is that which makes an improper discrimination by conferring particular
privileges upon a class of persons arbitrarily selected from a large number of persons, all of
whom stand in the same relation to privilege granted that between whom and the persons not so
favored no reasonable distinction or substantial difference can be found justifying the inclusion
of one and the exclusion of the other from such privilege.
At their government treated equal peoples as all are equals but unequals are not to be equal
because they want special treatment. Those farmers who gave their land unwillingly they get
their land return but those people they gave their land willingly they are already get the
compensation of land there is no need to return their land to willingly farmers because the
accepted compensation before but unwilling farmers didnt accepted the amount of
compensation.
According to Bangur Land Rehabilitation and Development Act, 2013:

Whereas it is expedient to provide for taking over of the land covered by the4 lease granted to
In Gauri Shankar V. UOI : the principal of equality of laws thus means not that the same law
should apply to everyone but that a law should deals alike with all in one class, that there should

be an equality of treatment under equal circumstances. It means that equals should not be
treated unlike and unlike should not be treated alike. Likes should be alike.
In Ashutosh Gupta V. State of Rajasthan: where persons or groups of persons are neat situated
equally, to treat those equals would itself result in inequality. As all persons are not equals by
nature or circumstances, the wearing needs of different classes or section of people require
differential treatment. This leads to classification among different groups of persons and
differentiation between such classes. Accordingly, to apply the principal manner, the court has
evolved the principal that if the law is question is based on the rational classification it is not
regarded as discriminatory.
In Chiranjit lal V. Union of India 9 the word any person in article 14 of the constitution denote
that the guarantee of the equal protection of laws is available to any person which includes any
company or association or body of individuals. The protection of article 14 extended to both
citizens and non-citizens and to natural person as well as legal persons. The equality before law
is guaranteed to all without regard to race, color or nationality. Corporations being juristic
persons are also entitled to the benefit of article 14.
In Abdul Rehman V. Pinto10 the very nature of the society there should be different laws in
different places and the legislature control the policy and enact laws in the best interest of the
safety and security of the state. In the fact, identical treatment in unequal circumstances would
amount to inequality.
9 AIR 1951 SC 41
10 AIR 1951 Hyd 11

In jagjit singh V. State11 a reasonable classification is not only permitted but is necessary if
society is to progress.
In R.K. Garg v. UOI12 article 14 forbids is class legislation but it does not forbid reasonable
classification. The classification, however, must not be arbitrary, artificial or evasive but must
be based on some real and substantial distinction bearing a just and reasonable relation to the
object sought to be achieved by the legislation.
In Monoponier co. v. City of Los Angeles 13 Article 14 applies where equals are treated
differently without any reasonable basis. But where equals and unequals are treated differently,
article 14 does not apply. Class legislation is that which makes an improper discrimination by
conferring particular privileges upon a class of persons arbitrarily selected from a large number
of persons, all of whom stand in the same relation to privilege granted that between whom and
the persons not so favored no reasonable distinction or substantial difference can be found
justifying the inclusion of one and the exclusion of the other from such privilege.
In Janmi Khandsari V. State of U.P.14 what is however necessary in that there must be
substantial basis for making the classification and that there should be a means between the
classification and the object of the statute under consideration. In other words, there must be
some rational means between the basis of classification and the object intended to be achieved.
11 AIR 1954 Hyd 28
12 AIR 1981 SC 2138
13 33 Cal App .675
14 AIR 1981 SC 831

In Jaila Singh V. State of Rajasthan therefore, mere differentiation or inequality of treatment

does not per se amount to discrimination within the inhibition of the equal protection clause. To
attract article 14, it is necessary to show that the selection or differentiation is unreasonable or
arbitrary, that is does not rest on rational basis having regard to the object which the legislature
has in view in making the law in question.
In re special courts bill the differentia which is the basis of the classification and the act are
distinct things and what is necessary is that there must be a means between them
Whether a classification adopted by a law is reasonable or not is a matter for the court to decide.
The question of reasonableness of classification has arisen in innumerable cases. The courts
however shows a good deal of deference to legislature intent and do not lightly hold a
classification unreasonable. A study of cases will show that many different classifications have
been upheld as constitutional. There is no closed category of classification, the extant, range and
kind of classification depends on the subject-matters of the legislation, the conditions of the
country, the economics, social and political factors at work a particulars time.

3. Whether the consent of the President of India was essential for the Bangur Land
The concurrent list comprises 52 items. The state is competent to legislate with respect to matter
in this list, subject to the rule of repugnancy contained in article 254.15
The rationale underlying the concurrent list is that there may be certain matters which are neither
of exclusively national interest, nor of purely state or local concern. These matters are such that
both the centre and the state may have common interest therein.
Under the const. of India Article 246(2) notwithstanding anything in clause (3), parliament , &,
subject to clause (1), the legislature of any state also, have power to make laws with respect to
any of the matter enumerated in the list III in the seventh schedule (in this const. referred to as
the concurrent list).
Assent to bill (article 200) of the constitution India:
15 Legislative relation( concurrent list)

When a bill has been passed by the both houses of the state legislature the bill is sent to the
governor for his assent. He may declare either that:
(A) The assent to the bill,
(B) He withholds his assent,
(C) he reserve the bill for the consideration of the president, at least in one case, whereas a
bill is likely to affect the power of the High court of a State, the governor must reserve it
for the consideration of the president,
(D) He may return the bill to the houses for reconsideration, in the last case when a bill,
returned by the governor for the reconsideration of the houses, is passed again by the
houses with or without amendments and presented to the governor for assent, the
governor shall not withhold assent second time.
According to this information the presidents assent is required only in one situation whereas a
bill is likely to affect the power of the High court of a State; the governor must reserve it for the
consideration of the president in the case of state law.
In Koshila Devi v. Parvati Devison16: if the legislature of a state has enacted any law in respect
of the matters enumerated in the concurrent list then, in that case, the law made by the legislature
of state shall prevail in the territory of state.
No there no need of assent of the president because on the subject matter of the concurrent both
union and state have right to make laws. This act (Bangur Land Rehabilitation and Development
Act, 2013) is the subject matter of the concurrent list. Under the constitution of India if a state
legislature made any law then it has to be received assent by the governor of that state.
According to the fact it is already received assent by the governor of that state.
16 6 September,1978

4. Whether the absence of Social Impact Assessment clause renders the Bangur Land
There is no absence of the Social Impact Assessment clause in this Act (Bangur Land
Rehabilitation and Development Act, 2013) because the main objective of this act was to acquire
the land from the Sparta Group and return 400 acres land to the unwilling farmers from whom
earlier the land was acquired and utilize the rest for some purpose beneficial to the people.
This Act is for the public purpose.
According to Bangur Land Rehabilitation and Development Act, 2013:


No there is no repugnancy between the Bangur Land Rehabilitation and Development Act, 2013
and the Central land acquisition, Rehabilitation and Development Act, 2013 because the central
land act is made for the whole India but the Bangur Land Rehabilitation and Development Act,
2013 is made for the state of Mithila which is different from the other states in the basis of the
geographical aspect. The state is among the top 3 states in the production of rice and hence its
economy is vastly dependent on agriculture. The state receives ample amount of rain during the
monsoon season which favors the growth of paddy and moreover the land is highly fertile owing
to the high deposit of silt and alluvium brought down by the river Padma which originates in the
Sindukush Range in the north. The government feels that this Bill is in interest of farmers, in
interest of development and in interest of the poor people. There is no thinking of going back on
Land Rehabilitation, Fair Compensation and Acquisition Act,"
In M. karunanidhi V. UOI17 the Supreme Court held that the state Act was not repugnant to the
centrals acts and therefore it did not repeal the central act which continued to be in operation
even after repeal of the state act and can be invoked for the purpose of prosecuting the
Petitioner . The state act creates distinct and separate offences with different ingredients and
different punishments and does not in any way collide with the centrals act. The state is rather a
complimentary act to the central act. The states act itself permits the central act to come to its aid
after an investigation is completed and a report is submitted. The state act provides that the
public man will have to be prosecuted under the centrals acts.
17 AIR 1979 SC 898

5. Whether the acquisition of land under the Bangur Land Rehabilitation and Development
Act, 2013 fulfills the criteria of public purpose as mentioned in the Central Land
Yes this act fulfills the criteria of public purpose because the primary element of this act is to
beneficial to the people of Mithila according to centrals land acquisition, rehabilitation and
resettlement act, 2013:
Transfer of land to unwilling owners and its utilization:

The state government shall return equivalent quantum of land to unwilling owners, who have not
accepted the compensation from land described in part I and part II to the schedule and the rest

of the land shall be utilized by the government for socio-economic development, employment
generation, and industry and for other public purpose of the state.
6. Whether the refund clause mentioned in the Bangur Land Rehabilitation and
Yes the refund clause which is mentioned in the Bangur Land Rehabilitation and Development
Act, 2013 is legally valid. Because the amount which is to be refund is complete by the way of
full legal path. The amount of the compensation would be adjudged and determined by the
district judge, mithila on an application being made by Sparta group ltd. In due compliance with
the principal of natural justice and by reasoned ordered.
According to the Bangur Land Rehabilitation and Development Act, 2013:

Payment of amount: Section (5)
(a) For the transfer to and vesting in the state government the land
under section 3 and right, title and interest in relation thereto, he
amount of the premium paid respectively by the vendor shall
refunded after deduction the amount of arrears of rent left unpaid by
them upon an application being made by them respectively
mentioning the amount of premium paid and rent in arrears.

(b) For the transfer to the vesting of the land lease to the Sparta group
ltd. The amount of the compensation would be adjudged and
determined by the district judge, mithila on an application being
made by Sparta group ltd. In due compliance with the principal of
natural justice and by reasoned ordered.
(c) The amount so determined in accordance with the provisions hereto,
shall carry simple interest at the rate of six per centum from the
period commencing on the date of application made by claimant and
ending on the date of tender of the amount as may be determined
and payable by the state government.
PRAYER
Wherefore in the light of the facts stated, arguments advanced and authorities cited, the
Petitioner, humbly prays before the Honble Court, to adjudge and declare that:
1. The leave petition filed under Art. 132 of the constitution of India are maintainable.
2. Declare this Act constitutional and valid.
The court may also be pleased to pass any other order, which the court may deem fit in light of
justice equality and good conscience.

All of which is most humbly prayed.

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IMS UNISON UNIVERSITY 3rd NATIONAL MOOT COURT COMPETITION 2015

HONBLE SUPREME COURT OF JUDICATURE

NEW DELHI, INDIA

STATE GOVERNMENT OF MITHILA .PETITIONER

SPARTA INDIA PVT. LTD. ...RESPONDENT

MEMORIAL ON BEHALF OF THE PETITIONER

MEMORIAL ON BEHALF OF PETITIONER 1

List of abbreviations ...III

MEMORIAL ON BEHALF OF PETITIONER 2

1 AIR 1951 Hyd 11

3 AIR 1954 Hyd 28

MEMORIAL ON BEHALF OF PETITIONER 3

8. Koshila Devi v. Parvati Devison5

4 AIR 1981 SC 831

6 33 Cal App .675

7 AIR 1981 SC 2138

8 AIR 1979 SC 898

MEMORIAL ON BEHALF OF PETITIONER 4

MEMORIAL ON BEHALF OF PETITIONER 5

MEMORIAL ON BEHALF OF PETITIONER 6

ISSUE: 1 whether this Appeal is Maintainable?

MEMORIAL ON BEHALF OF PETITIONER 7

ISSUE :1 Whether this Appeal is Maintainable?

MEMORIAL ON BEHALF OF PETITIONER 8

MEMORIAL ON BEHALF OF PETITIONER 9

MEMORIAL ON BEHALF OF PETITIONER 10

1. Whether this Appeal is Maintainable?

MEMORIAL ON BEHALF OF PETITIONER 11

MEMORIAL ON BEHALF OF PETITIONER 12

According to Bangur Land Rehabilitation and Development Act, 2013:

MEMORIAL ON BEHALF OF PETITIONER 13

10 AIR 1951 Hyd 11

MEMORIAL ON BEHALF OF PETITIONER 14

11 AIR 1954 Hyd 28

12 AIR 1981 SC 2138

13 33 Cal App .675

14 AIR 1981 SC 831

MEMORIAL ON BEHALF OF PETITIONER 15

In Jaila Singh V. State of Rajasthan therefore, mere differentiation or inequality of treatment

MEMORIAL ON BEHALF OF PETITIONER 16

Assent to bill (article 200) of the constitution India:

15 Legislative relation( concurrent list)

MEMORIAL ON BEHALF OF PETITIONER 17

MEMORIAL ON BEHALF OF PETITIONER 18

According to Bangur Land Rehabilitation and Development Act, 2013:

MEMORIAL ON BEHALF OF PETITIONER 19

17 AIR 1979 SC 898

MEMORIAL ON BEHALF OF PETITIONER 20

Transfer of land to unwilling owners and its utilization:

MEMORIAL ON BEHALF OF PETITIONER 21

According to the Bangur Land Rehabilitation and Development Act, 2013:

MEMORIAL ON BEHALF OF PETITIONER 22

MEMORIAL ON BEHALF OF PETITIONER 23

All of which is most humbly prayed.

MEMORIAL ON BEHALF OF PETITIONER 24

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