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1932:                      The Dominion Government of India conducted a survey. According to it properties comprised in C. S. Khatian No. 530 comprised in C. S. Plot No. 307 and 308 was measuring 0.60 Acre and properties comprised in C. S. Khatian No. 534 C. S. Plot No. 309, 310, 311 and 311/995 was measuring 0.50 Acre, totaling 1.10 Acre total equivalent to 66 Cottahs more or less. The aforesaid properties was lying and situated within Mouza Sahapur, Police Station Behala, District: South 24-Parganas, within ward No. 119 of Kolkata Municipal Corporation.


16/09/1948           One Nalini Mohan Dey husband of my vendors purchased aforesaid properties measuring 0.60 Acre equivalent to 36 Cottas comprised in the said C. S. Khatian No. 530 as aforesaid from it's the then Owners. 


23/12/1947           One Balaram Paul was claiming himself as owner of the aforesaid Properties measuring 0.50 Acre equivalent to 30 Cottahs comprised in the aforesaid C.S. Khatian No. 534, under some false representations or otherwise, executed one alleged deed in favour of Chittaranjan Ganguly, subsequently, which was seized by Police in or about May 1948 from the Advocate of said executor Balaram Paul.


08/05/1954           Said Balaram Paul executed another alleged deed relating to aforesaid self same properties measuring 0.50 Acre equivalent to 30 Cottas, comprised in C.S. Khatian No. 534 as aforesaid, in favour of said Nalini Mohan Dey, and delivered physical possession of the properties except one part, which according to him was tenanted to one Abdul Latiff Mistry.

However by Judgment dated 28/09/1977 in Title Suit No. 301 of 1963 4th Court of Munsif, Alipore held interalia that “C.S.Khatian 534 (ext.3 (a) reveals that Tincouri Sheikh and another were accorded therein as raiyat and Gopal was in possession of the Suit plot No.311 as a licensee.Ext.3 is the R.S.Khatian 534 showing Sheikh Ghulam Mohammed and other as raiyats and R.S.Plot 219 hasbben shown to be in forcible possession of defendant Ext.15, Information slip prove as that R.S.Plot No.219 is old C.S.Plot 311 of Suit. From their records of right I find that neither Balaram nor Gopal nor Abdul Latif was even shown as Raiyat in respect of suit Khatian or for that matter the suit land, Gopal’s possession was therefore his possession of a licensee as per the record of rights, the entries in the record of rights have presumption of their correctness. There is no satisfactory documentary evidence to prove that Gopal was even a raiyat in respect of Suit Khatian, except some registered deeds wherein admission by the vendors themselves which cannot prove raiyati right of Gopal, in that event, Plff’s case of Abdul Latif staking settlement of tenancy from Gopal Ch.Pal  has no leg to stand.”


On the basis of the aforesaid Judgment (1) Nalini Mohan Dey in 1954; and (2) adjudged Chitta Ranjan ganguly  has no legs to stand for claim of the ownership, since father of aforesaid Balaram Paul, namely Gopal Chandra Paul has no legs to stand.


However, Court hold “The possession of the defdt. (Legal heirs of Rabindra Lal Chakraborty ) in the Suit Land has been recorded as forcible one in for R. S. Records of rights against owners Sk.Golam Md.and other and it has not been challenged by the defdts. Nor even by the plff. The entries therefore remain as correct. In that view of the matter the possession of the the suit land is held to be that of a trespasser.”. Similarly in the selfsame document “C.S.Khatian 534 (ext.3 (a) reveals that Tincouri Sheikh and another were accorded therein as raiyat and Gopal was in possession of the Suit Khatian as a licensee. Ext.3 is the R.S.Khatian 534 in respect of the properties comprised in R. S. Plot No. 205, 206 and 207 showing Sheikh Ghulam Mohammed and other as raiyats and name of Nalini Mohan Dey the predecessor-in-interests of Vendors were recorded as forcible one in the following manner:-

In the year of 1956 Government of West Bengal made Revenue Survey, in which aforesaid properties were recoreded with the corresponding R.S.Plot Nos. in the following manner:-

C.S./R.S.Khatian No.530  R.S.Plot No.194      0.367 Acre  against owner Nalini Mohan Dey, since 1948.

C.S./R.S.Khatian No.530R.S.Plot No.195          0.187  ,,             ,,       ,,               ,,                                   ,,

C.S./R.S.Khatian No.534 R.S.Plot No.205   0.168    ,, recorded against owner that it in forcible occupation of Nalini Mohan Dey since 1954.

C.S./R.S.Khatian No.534 R.S.Plot No. 206   0.187   ,, recorded against owner that it in forcible occupation of Nalini Mohan Dey since 1954.

C.S./R.S.Khatian No.534 R.S.Plot No, 207      0.031   recorded against owner that it in forcible occupation of Nalini Mohan Dey since 1954.

C.S./R.S.Khatian No.534 R.S.Plot No.219             0.158   ,, recorded name owner: as forcible occupation of Rabindra Chakraborty                                    1.098 Acre                        .                

Therefore Ownership of my Vendors established in respect of 1.098 Acre minus 0.158 recorded name owner: as forcible occupation of Rabindra Chakraborty = 0.94 Acre = 56 Cottahs of Land


From the records of Rights as well as from the aforesaid Deeds total area of the properties arises more or less 66 Cottahs, including properties comprised in R. S. Plot No. 219.


1980-1981            My Vendors: Ava Rani Dey and Dipika Rani Bhattacharjee, through their Lawyer Mr. Swapan Kumar Chakraborty made false claims in writing through their Lawyer that they are owners of 70 Cottas of the land, out of which one litigation is pending in respect of the properties more or less measuring 3 Cottas. My Lawyer Alok Nath Ghosh, in connivance with their Lawyer Cheated me and not verified authenticity of such false statement.


09-12-1981 / 05-02-1982 I entered in agreement with my Vendors, to purchase their alleged 70

cottas of landed properties comprised in C. S. Khatian No. 530 and 534 as aforesaid, relying their false claim as correct.


02/02/1982           My Lawyer of Ld. Mr. Aloke Nath Ghosh, Advocate sent a Letter to Lawyer of my Vendors, Ld. Mr. Swapan Kumar Chakraborty with reference to such agreement and made requisite subsequent correspondent.


00/03/1982                 I also entered in Agreements to sale 31 Flats.


31/05/1982 / 28/06/1982 My Vendors, executed 14 Sale Deeds in respect of 35 Cottas of Landed

Properties comprised in entire R. S. Plot No. 194, 205 and 207 in favour of my nominees, including my mother, father, Brother-in-laws, and friends. My Vendors failed to execute Sale Deeds in respect of R. S. Plot No. 195 and 206 (Measuring 21 Cottahs more or less) for their failure to comply some legal formalities, though I made full payment to them and they delivered Physical Possession to me. With regards to rest R.S. Plot No. 219 (Measuring 10 Cottahs more or less) they lost their claim of Title in 1977 in the aforesaid Suit against their total false claim which they made in 1982 in writing through their Lawyer claiming that a Litigation is pending for about 3 Cottahs. 


As per Records of Rights and as per aforesaid Deeds total area of the entire properties comprised in 6 C. S. under 2 C. S. Khatian corresponding with 6 R. S. Plots comprised in 2 R. S. Khatians arrived  =                 66 Cottahs

Out of 66 Cottahs they admitted in the plaint and Injunction

Application that they have sold to me:                                                                                         35 Cottahs

So, Rest land arrives:                                                                                                                   31 Cottahs

Out of 31 Cottahs of Land they suppressed material facts from the Court relates

to aforesaid Judgment dated 28/09/1977 in Title Suit No. 301 of 1963 which was

filed by their predecessor-in-interest, and dismissed by 4th Court of Munsif, Alipore

as they failed to prove ownership right over the properties comprised in R. S.

Plot No. 219, as per Records of Rights                                                                                    9 Cottahs

In 1982 for the rest properties measuring 22 Cottahs of Land more or less they Executed Registered Sale Deeds and granted Power of Attorney in my favour and delivered physical possession of the same by taking full payment. I have documentary evidences to prove that my Vendors failed to Execute Sale Deeds for want of some legal compliance.  


19th September 1984 After Order in Title Suit No. 108 of 1983 passed by Ld. 7th Assistant District Judge, Alipore, I constructed boundary wall surrounding entire properties comprised under R. S. Plot No. 194 and 195 under R.S. Khatian No. 530 and R. S. Plot No. 205, 206 and 207  under R. S. Khatian No. 534 as aforesaid.


21/03/1986           Kolkata Municipal Corpoartion sanctioned two Plans each for two multistoried buildings in favour of me (R.S.Plot No. 206), and my Cooperative Society (R.S.Plot No. 205). I started construction of the Buildings on the basis of Two Sanction of Plans one for R. S. Plot No. 205 and another for R. S. Plot No. 206.


Between 1982 and May 1988 Ava Rani Dey and her daughter Dipika Rani Bhattacharjee had no dispute against me, when I make construction of boundary walls in 1984 surrounding entire properties and further in 1986 when construction of Buildings was started by me. But in or around May 1988 when they also joined the Boat of the Blackmailers, dispute was got caused and filed Suit against me. In the suit they adopted criminal manipulation with criminal objects by mixing up the 6 C. S. Plots described in Records of Rights published in 1932 by the Dominion Government in India with the corresponding 6 R. S. Plots described in the Records of Rights published by the Government of West Bengal in 1956 and referred them as total 12 Plots in the Plaint of the Suit without describing them as C. S. or R. S. Plots. 


Total property as per Records of Rights relates to aforesaid 6 C. S. Plots corresponding to aforesaid  6 R. S. Plots was referred as 66 Cottahs.


But under manipulation and after wrongfully mixing up the aforesaid 6 = 6 as 12 Plots they referred Total property in the Suit as 94 Cottahs. Out of which they admitted that sale of the properties about 35 Cottahs of land to me. According to them after deduction of already sold 35 Cottahs land they were still owners of the 59 Cotthas of the land. On the basis of their false statement they filed Injunction Suit against me under connivance with ChuniLal Mukherjee, to favour blackmailing objectives of the Mafia Leader Sanjay Kumar Jhunjhunwala.


They suppressed such material fact considering that in view of the aforesaid Judgment dated 28/09/1977 in Title Suit No. 301 of 1963 they not entitled to file any Suit in respect of R. S. Plot No. 219 as it was debarred by Law of the Resjudicata. But they included it in the Suit Property.


October 1988       I filed Title Suit No. 138 and 139 of 1988 of Ld. 7th Court of Assistant District Judge, Alipore against my Vendors for specific performance by execution of Sale Deeds in respect of Properties comprised in R. S. Plot No. 195 and 206.


As per Supreme Court guidelines, for granting Injunction Order Mr. Moulick, the then Presiding Officer of the 5th Court of Munsif, Alipore should not have pass any Injunction order against me, in respect of any part of the aforesaid property. But, he was engaged himself to pass Injunction Order under extra Judicial powers thus passed Injunction Order against 59 Cottahs of Land out of Total 66 Cottahs. As such I filed Appeal, which was heard by Ld. Mr. A. K. Chowdhury, Additional District Judge, 5th Court of Alipore (Kolkata) and after hearing hte matter he commented in open Court that in consideration of the serious manipulation he is going to reject the plaint at limini, and would pass the order to that effects. But he was embraced by some one against me thus withheld the order for few days and when passed he upheld the order passed by Mr. J. C. Moulick.   


I filed Revision Application before Kolkata High Court against aforesaid Injunction Order passed against me. When my Counsel Ld. Mr. Shakti Nath Mukherjee, Bar-at-law moved my Petition before Justice Amulya Kumar Nandi, of Kolkata High Court, after hearing the matter Court was ready to set-aside the Injunction Order passed against me and to revert back to the lower court for further hearing of the Injunction Petition. At this stage Ld. Mr. Shakti Nath Mukherjee, argued before the Hon’ble Court that in consideration of serious manipulations in the Suit Property he will satisfy to Court to pass a Ruling to reject the Suit at limini even during hearing of the Revision Petition. Court agreed and fixed for final hearing of the matter. 


Such development causes serious obstruction for their object to blackmail me. Mr. Kishan Lal Bagaria, Solicitors of Sanjay persuaded my Solicitors Mr. Gouri Shankar Gupta thus he advised me for sitting in negotiation table, which I refused. Thereafter, Gouri Shankar Gupta misguided me that Mr. Shakti Nath Mukherjee, is very busy lawyer, so we should also appoint an additional senior Lawyer, and under his advise I appointed his choice: Ld. Mr. Bidyut Banerjee, Advocate. I was failed to understand that this was a game plan of Gouri Shankar Gupta in connivance with Mr. Kishan Lal Bagaria, Solicitors of Mafia Leader Sanjay Kumar Jhunjhunwala.


29/03/1990           When matter was called and Mr. Shakti Nath Mukherjee sent message to Shri Gouri Shankar Gupta for pass over of the matter for few minutes, since he was coming from other Court. Hon'ble Judge was ready to Passover. But at this stage, even ignoring  my loudly objection Gouri Shankar Gupta advised and Bidyut Banerjee pleaded in the matter, and the same order was passed, which was Hon'ble Court was ready to pass on the first day of the moving of the Revision Petition.


26/03/1991           Since the earlier order of Injunction was passed under criminal misconduct by Mr. J. C. Moulick as such again he passed Injunction Order against me, ignoring 16 different Rulings of the different High Courts, and Guidelines of the Supreme Court, which I pleaded in my written arguments. More dangerous impact of the same was that my Vendors promised before High Court to amend the schedule of the property but at the lower Court they not amended the Suit Property in compliance of their admission and legal duty to come before Court with clean hands. In Revision Petition High Court directed for disposal of the matter within 15 days, while matter was disposed off only after a conspiracy was hatched to commit attempt to murder my son which was committed on 22nd  February 1991 and within one month 4 days from the severe Attempt to murder my son order was passed. Since Injunction Order was passed under connivance and under open conspiracy by misusing the Judicial Office, as such Mr. J. C. Moulick even ignored the documents upon which said plaintiffs relied upon for praying the Injunction Order against me. I made written Argument that though court may not rely upon the documents referred by me, but Court cannot ignore the documents referred and relying upon by the plaintiffs of the said Suit  i. e. my Vendors, who are seeking Injunction Order against me.         


Part of Correspondentce Between
Advocates From Both Sides

ALOKNATH GHOSH & Records of Rights and Legal Opinion.


Correspondence between my the then Lawyer Aloke Nath Ghosh and Lawyer of my Vendors: Swapan Kumar Chakraborty, it is quite clear that Ava Rani Dey and her daughter from beginning made false statement relating to (1) area of the properties; (2) already disposed of Suit was claimed as Pending; and (3) in consideration of serious implications hidden the facts relates to Judgment pronounced by 4th Court of Munsif Alipore in Title Suit 301 of 1963, otherwise I may have not entered in agreement to purchase the property.    


Aloke Nath Ghosh, Advocate also cheated me by not verifying the correct picture of the Suit, since Swapan Kumar Chakraborty, Advocate noted down his false reply on the several page requisition forwarded by Aloke Nath Ghosh that a dispute is pending against Chittaranjan Ganguly for 3 cottahs of land comprised in C.S. Plot No. 311. Besides such false reply impact of the said Judgment was that even the father of Balaram Paul namely Gopal Chandra Paul was not the owner of the property, rather just was a licensee. By the said Judgment Records of Rights was hold as the basis for ownership rights by adverse possession. According to said Judgment ownership rights of the Nalini Mohan Dey in respect of Properties comprised in R. S. Plot No. 205, 206 and 207 were ascertained as forcible occupier, not on the basis of the alleged Deed executed by Balaram Paul. Therefore it is clear to me that there were some connivance between my then Lawyer Aloke Nath Ghosh, Lawyer of my Vendors: Swapan Kumar Chakraborty, and my Vendors, to cheat me, through such false statement. In this Page of the Website such correspondence is referred while respective Records of Rights which admittedly filed by the both side parties to Suit and Legal Opinion relating to Judgment dated 28/09/1977 in Title Suit No. 301 of 1963 4th Court of Munsif, Alipore are referred in the page of Chittaranjan Ganguly.


I have referred in detail that total area of the properties were arises as 56 Cottahs more or less for which ownership of Nalini Mohan Dey was established. But thye falsely claimed that they were owners of the 70 Cottahs. However, during 1982 they delivered the physical possession of the aforesaid 56/57 Cotthas of land more or less after receipt of the entire payments and executed the Deeds as follows:

Registered Sale Deeds in respect of 35 Cottahs

Registered Sale Agreements for rest 21/22 Cottahs more or less and Registered Power of Attorney were delivered since my Vendors failed to comply some mandatory provisions, as per documents I have in position to prove this fact.


In 1984 I made construction surrounding aforesaid entire 56/57 Cottahs of Land. In 1986 I started construction of the Buildings at the aforesaid properties. Between 1982 and 1988 my Vendors no way were in the picture. But once Chuni Lal Mukherjee, the main agent of Mafia Leader Sanjay Kumar Jhunjhunwala instigate, abetted and inserted greediness in the mind of my Vendors to blackmail me to earn and exploit more money, they started to blackmail me with the help of Mr. J. C. Moulick, besides others including few Advocates and submitted total false claim with regards to total area of the property as 94 Cottahs and admitted sale of the 35 Cottahs properties to me and ask Injunction Order for 59 Cottahs against their total Properties not more than 56/57 Cottahs of land, before sale to me. Role of Chuni Lal Mukherjee, appears from the letter from non other than grand daughter of My Vendors Ratna Bhattachryya, photocopy of which is posted here.


From the aforesaid Letter from Ms. Ratna hattacharyya, grand daughter of my Vendor Ava Rani Dey confirm that Chuni Lal Mukherjee, (the main agent of Mafia Leader Sanjay Kumar Jhunjhunwala) was regular visitor at their residence.