12.07.2015 Views

statement of claim

statement of claim

statement of claim

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vi.vii.viii.ix.A declaration that in issuing and granting the said timber licence asaforesaid, the Defendants are in breach <strong>of</strong> their fiduciary duty to thePlaintiffs and therefore the said Timber Licences was null and void;A Declaration that the issuance and granting <strong>of</strong> the said timber licencewas in breach <strong>of</strong> the statutory provisions <strong>of</strong> the Forests Ordinance(Cap.126);A Declaration that the issuance and granting <strong>of</strong> the said timber licence isunlawful, improper, unconstitutional and therefore null and void;A Declaration order that the area so included in the said timber licence as<strong>claim</strong>ed by the Plaintiffs as part <strong>of</strong> their Tana Pengurip or ancestral orNCR Land, the same be excised out <strong>of</strong> the area <strong>of</strong> land under the saidtimber licence;x. A prohibitory injunction restraining the 1 st Defendant, its contractors,subcontractors, employees, servants and/or workers from trespassing,clearing, using or occupying the Plaintiffs said Tana Pengurip or ancestralor NCR Land;xi.xii.xiii.xiv.xv.xvi.xvii.A mandatory injunction against the 1 st Defendant, its contractors,subcontractors, employees, servants and/or workers to cease operationand remove all structures, equipment and/or machineries from thePlaintiffs said Tana Pengurip or ancestral or NCR Land forthwith;DamagesExemplary damages, alternatively, aggravated damages;Alternatively, an order that the damages be assessed accordingly;Interests;Cost; andSuch further and/or other relief this Honourable Court deems fit and just.Dated thisday <strong>of</strong>16

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