**IN THE COURT OF THE CIVIL JUDGE (J.
D), BARPALI**
**Civil Suit No-01 of 2024**
**Ambika Ganda @ Kumbhar……………………Plaintiff.**
**V.**
**Buchi Kumbhar and 2 others……………………..Defendants.**
**SETTLEMENT OF ISSUES ON BEHALF OF DEFENDANTS**
The Defendants No-1, 2 & 3, through their undersigned counsel, most respectfully submit this Settlement of
Issues for the kind consideration of this Honorable Court and propose the following issues for settlement:
1. **Whether the suit as filed by the Plaintiff is barred by limitation under the provisions of the Limitation Act,
1963?**
2. **Whether the Plaintiff has locus standi to file the present suit in light of the genealogical facts and legal
entitlements as presented by the Defendants?**
3. **Whether the Plaintiff's claim over the suit property, [Link] No-47 of mouza- Gadgaddala, stands
invalidated due to the absence of her name in the relevant revenue records and the presence of the Defendants'
names as per Mutation Case No-562/1992?**
4. **Whether the Plaintiff's assertion of being a successor-in-interest of Late Jethu Ganda is legally sustainable,
considering the documentary evidence and genealogy provided by the Defendants?**
5. **Whether the entry of the Plaintiff's name in the Revenue Misc. Case No-53/2022 in [Link] No-47
Record-of-Right is illegal, improper, and without any legal basis, thereby not conferring any right, title, interest,
or possession over the suit land to the Plaintiff?**
6. **Whether the Defendants are the rightful owners and possessors of the suit land, having perfected their title
over the same since 10/07/1993, and thus the Plaintiff is not entitled to any declaration of her right, title, interest,
or share over the suit land?**
7. **Whether the suit is liable to be dismissed due to non-joinder of necessary parties as per the principles of
civil procedure?**
8. **Whether the Honorable Court lacks pecuniary jurisdiction to try the suit, considering the market value of
the suit land as alleged by the Defendants?**
9. **Whether the Plaintiff has suppressed material facts regarding the pendency of Civil Suit No-22 of 2020,
which directly impacts the maintainability of the present suit?**
10. **Whether the Defendants are entitled to the costs of litigation and any other relief that this Honorable Court
may deem just and proper under the circumstances?**
It is respectfully submitted that the issues framed above are critical for the just and proper adjudication of the
present suit. The Defendants submit that upon careful consideration and determination of these issues, this
Honorable Court may be pleased to dismiss the suit filed by the Plaintiff for being devoid of merit and for the
reasons stated in the written statement filed by the Defendants.
**PRAYER**
It is, therefore, most respectfully prayed that this Honorable Court may be pleased to:
(i) Dismiss the suit filed by the Plaintiff with costs.
(ii) Pass any other order(s) that this Honorable Court may deem fit and proper in the interests of justice, equity,
and good conscience.
**ADVOCATE FOR THE DEFENDANTS**
**DEFENDANTS**
**VERIFICATION**
I, {defendant_name}, aged about {defendant_age} years, {relationship_status}, and {occupation}, resident of
{defendant_address}, the Defendant No-1, do hereby declare that the contents of this Settlement of Issues from
paragraphs one to ten are true and correct to the best of my knowledge and belief. No part of it is false and
nothing material has been concealed therein. Verified today, the {verification_date}.
**ADVOCATE FOR THE DEFENDANTS**
**DEFENDANT NO-1**
**AFFIDAVIT**
I, {defendant_name}, aged about {defendant_age} years, {relationship_status}, and {occupation}, resident of
{defendant_address}, the Defendant No-1 in the suit, do hereby solemnly affirm and state as follows:
1. That, I am the contesting Defendant No-1 in the suit.
2. That, the contents of this Settlement of Issues and verification are true to the best of my knowledge and belief.
This affidavit is made to affirm the truthfulness of the statements made in the Settlement of Issues submitted to
this Honorable Court.
**ADVOCATE FOR THE DEFENDANTS**
**DEFENDANT NO-1**