statement of claim

affected land to be earth-filled through the use of bulldozers, excavators,shovels, trucks and lorries.25. The 1 st Defendant, its contractors, subcontractors, employees, servantsand/or workers also felled the trees and clear vegetations and therebydestroying and damaging the communal forests of the Plaintiffs.26. Inspite of the numerous and continued objections and protests by thePlaintiffs, the 2 nd and/or the 3 rd Defendant had given assurance to resolvethe dispute and stop the trespass but had not acted on their assurance,thereby permitting the 1 st Defendant’s trespass to continue on thePlaintiffs' said Tana Pengurip or ancestral or NCR Land.27. With the said timber licence issued by the 2 nd Defendant, the 1 st Defendanthave entered through their contractors, subcontractors, employees,servants and/or workers wrongfully claiming that they have the right toenter, clear, use and occupy the Plaintiffs' said Tana Pengurip or ancestralor NCR Land.Damages28. By reason of the matters aforesaid, the Plaintiffs' sources of and, any rightto their, livelihood is seriously threatened and they have suffered loss anddamage.28.1 The farmland, rivers and the communal forests are damaged anddestroyed by the 1 st Defendant, its contractors, subcontractors,employees, servants and/or workers.Particulars Of Damage(a)(b)(c)Irreparable damage to vegetations, food, water, valuablemedicines, wildlife and other forest produce which thePlaintiffs need and are dependent upon with the destructionof the communal forests and thereby seriously impairing thePlaintiffs' sources of livelihood.Extensive damages to the Plaintiffs' said Tana Pengurip orancestral or NCR Land.Destruction of fruit trees and other essential trees such as“Tajem” (poison trees) and “Kayeu Keleput” (blowpipe trees),and crops.11