filed a civil suit bearing Civil Suit No. A/211/2019 for declaration of his title and possession over the suit land and has also sought relief of possession of some portion of suit land, which has been mortgaged mentioned in Schedule A annexed with the plaint. He further submits that earlier Laxmin Bai had filed civil suit bearing No. 4-A/1988 against Balaram (father of petitioner) and Chetram for declaration of her title over the suit land of instant Civil Suit No. A/211/2019. In aforesaid civil suit, Balaram filed counter claim. Civil Suit No. 4-A/1988 was dismissed by the trial Court, counter claim filed by Balaram was allowed and decree was passed in his favour. Thereafter, in execution proceeding, possession over the suit land was granted to Balaram by the Court. Subsequently, Municipal Corporation, Bilaspur obtained gift deed from Laxmin Bai in respect of that disputed land and constructed community hall on some portion of disputed land. It is further submitted that, area of disputed land is 24 Hath x 11 Hath as per sale deed, but some of the portion has been encroached by the Municipal Corporation, Bilaspur, therefore, the petitioner/plaintiff (son of late Balaram Verma) has filed civil suit bearing No. A/211/2019 against Municipal Corporation, Bilaspur, which is pending consideration before the Court of 10th Civil Judge, Junior Division, Bilaspur, Distt. Bilaspur. It is further submitted that in aforesaid civil suit (No. A/211/2019), the petitioner plaintiff filed an application under Section 65 of the Evidence Act for permission to adduce secondary evidence in form of photocopy of order sheet, Fard Talika, possession warrant, receipt of taking possession etc. of Execution Case of Civil Suit No. 4A/2008, as aforesaid execution case is not available in the record room, therefore, certified copy
