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It is pleaded that in or about the year 1905­10, the Improvement Trust of Delhi, while developing the area of Beadonpura, in Karol Bagh, New Delhi, earmarked and left a plot of approximately 100 Sq. Yards between Gali No. 31 and 32, Beadonpura, Karol Bagh, New Delhi, for common and welfare use of the all the residents of the locality. According to the plaintiffs, in the beginning a well was dug by the Improvement Trust in the year 1905/10 for providing water to the residents where all the residents of the area used to take water from the said well and the said plot was also used as community centre for other activities like holding of panchayats and other social gatherings of the local residents of the area. In or about the year 1940, the Municipal Committee provided water facilities and a water tap was installed for common use of the locality and not only that but a water tank was also constructed there by the Authorities for collection of water for use in emergency/storage of the water, as the second world war was going in that period and the well was filled and covered thereafter. Further, in or about the year 1970, on request of the residents of the area, the Delhi Administration constructed a Barat Ghar/Community Centre on the said plot for the common use of the residents of the said area. Since then the said premises have been continuously in use for social purposes like Marriages, functions and holding other social gatherings etc. According to the plaintiff, in the year 1972, the defendant nos. 1 & 2 alongwith their mother and family members illegally occupied the said Barat Ghar/Community Centre. The local residents objected to their illegal occupation, but, due to terror spread by them, the plaintiffs could not resist and prevent them from illegally occupying the said premises, as the defendant no.1 is himself a hard core criminal who had been convicted in a murder case. Thereafter the local residents and various office bearers of the plaintiff no.1 from time to time have been approaching the Govt. authorities including the then Chief Executive Councillor, Police Authorities and the present Chief Minister requesting them to get the said Barat Ghar/Community Centre vacated and the Delhi Administration wrote many times to the Local Police authorities to get the said premises vacated but till date no constructive action has been taken by the concerned authorities and despite various efforts the Government has not got the said premises vacated from the illegal occupation by the defendants 1 & 2. The plaintiff apprehend that the defendants may handover and sell the said premises to other persons because they have threatened to do so on account of the fact that the said property is under litigation in another suit filed by Shri Kuldip Singh where their ownership rights are under challenged.

The case of the Adarsh Beadonpura Residents Welfare Association is that in or about the year 1905­10 the Improvement Trust of Delhi while developing the area of Beadonpura, Karol Bagh, New Delhi had earmarked and left a plot of approximately 100 sq. yards between Gali no. 31 and 32, Beadonpura, Karol Bagh, New Delhi for common and welfare use of all the residents of the locality and in the beginning a well was dug by the Improvement Trust in the year 1905/10 for providing water to the residents, from where all the residents of the area used to take water, which plot was also used as community center for other activities like holding of Panchayats and other social gathering etc. In or about the year 1940 the Municipal Committee provided water facilities and a water tap was installed for common use of the locality and a water tank was also constructed for collection of water for use in emergency/ storage of water on account of second world war during the period. Thereafter, the well was filled and covered. In or about 1970 on request of the residents of the area the Harijan Welfare Board through the Municipal Corporation/ Delhi Development Authority (Slums) (Delhi Administration) had constructed a Barat Ghar/ Community Center on the plot for common use of the residents of the area and ever since the premises were being used for social purposes like marriages, functions and holding other social gatherings etc. In the year 1972 Mohan Lal Kuredia and his other family members illegally occupied the said Barat Ghat/ Community Center and the local residents also objected to their illegal occupation but due their terror the plaintiff association could not resist and prevent them from illegally occupying the premises as Purushottam himself was a hardcore criminal who had been convicted in a murder case. The local residents and various office bearers of the plaintiff Association had been approaching the government authorities from time to time including the Chief Executive Councillor, Police Authorities and the present Chief Minister requesting them to get the said Barat Ghar/ Community Center vacated and the Delhi Administration wrote to the Local Police authorities on many occasions to get the said premises vacated but no constructive action was taken.