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7. That the contents of para 7 of the Additional Affidavit are wrong and denied. The UPPCB was impleaded as party in the matter and when they came to know that the violation have been done, only thereafter, the penalty was imposed as stated by respondent no.11 in their additional affidavit dated 30.04.2025 (at page 478 to 486). The additional affidavit of the respondent no.11 may kindly be read as part and parcel of the present para.

8. That the contents of para 8 of the Additional Affidavit. are wrong and denied. The averments mentioned in para are misleading and the respondent no.8 is trying to mislead by alleging the applicant. The disputes in between the applicant and the respondent no. 8 to 10 are inter-se disputes and nothing to do with the present case.

12. That the contents of para 12 of the Additional Affidavit are wrong and denied for want of knowledge.

13. That the contents of para 13 of the Additional Affidavit are wrong and denied for want of knowledge, Even though it is clear that the misleading facts mentioned in Annexure-RB.

14. That the contents of para 14 of the Additional Affidavit are wrong and denied. It is therefore, most respectfully prayed that the prayer made in the additional affidavit in para 14 may kindly be dismiss with heavy and exemplary cost in the interest of justice."

6. That the contents of para 6 of the parawise reply of the additional affidavit are wrong and denied by placing certain forged documents, the Respondent cannot fall within the shoes of environmentalist.

7. That the contents of para 7 of the parawise reply of the additional affidavit are wrong and denied. Illegally cutting trees by the Respondent cannot be called a nature loving person. Thus, proper and strict action should be taken in the penal form as well as environment compensation should be recovered from the Respondent No. 8, as per the Additional Affidavit filed by Respondent No. 11 dated 30.04.2025. As per the formula per tree the environmental compensation was Rs.4,57,483.90/- and the total trees were 180. Thus, the total penalty comes 180 X Rs.4,57,483.90/ and the totaling of environmental compensation is Rs.8,23,47,102/- to be recovered from the Respondent Nos. 8 to 10 jointly and severally.

9. That the contents of para 9 of the parawise reply of the additional affidavit are wrong and hence the same are denied.

10. That the contents of para 10 of the parawise reply of the additional affidavit are wrong and hence the same are denied. The admitted position is that the trees were cut illegally, therefore, no family issue or dispute can protect the Respondent O.A. No. 272/2024 Deepank Kumar Sharma & Ors.

(I.A. No. 120/2024) Vs. MOEF & CC & Ors.