Complaint No. ________ of 20____ (to be allotted by the office of the Commission)
To,
The Chairperson and Members,
Punjab State Commission for Non-Resident Indians,
Block A, Room No. 6, Punjab Civil Secretariat-2,
Sector 9, Chandigarh.
Complainant: Sukhwinder Singh Sandhu, and Jasbir Kaur Sandhu, presently of Canada.
Respondents: as named in clause 3 of this complaint.
Subject: Complaint in respect of the occupation of the complainant's property by a relative of the complainant who refuses to deliver possession, concerning agricultural land in a revenue estate situated at Bhullarai, Tehsil Phillaur, District Jalandhar, Punjab.
Respected Sir / Madam,
1.1 Who I am. I, Sukhwinder Singh Sandhu, son of Late S. Gurdial Singh Sandhu, aged about 58 years, am a non-resident Indian, being a citizen of India ordinarily residing outside India. I ordinarily reside at X, in Canada, and I hold passport bearing No. Z4821975, a copy of the first and last pages whereof is annexed to this complaint.
1.2 Where to write to me. My email address is s.sandhu@example.com, and I respectfully request that every notice, every date of hearing, every direction and the final recommendation of this Commission be sent to it, because post to an overseas address is slow and a hearing date that reaches me after the hearing has passed is of no use to me. My address for service in India is X. My telephone number in the country of my residence is +1 604 555 0142. The mobile number at which I or my family may be reached in India is +91 XXXXX XXXXX. I hold Overseas Citizen of India card No. A1234567, a copy whereof is annexed.
A joint complainant. This complaint is made jointly with Jasbir Kaur Sandhu, wife of Shri Sukhwinder Singh Sandhu, who is a non-resident Indian, being a citizen of India ordinarily residing outside India, who ordinarily resides at X, in United Kingdom, and who holds passport bearing No. P1234567, a copy of the first and last pages whereof is annexed. The email address of the joint complainant is j.kaur@example.com, and I pray that every notice be sent to that address as well as to mine. The joint complainant is interested in the same property and is aggrieved by the same acts, has read this complaint, adopts every statement made in it, verifies it at the foot in his or her own place and on his or her own date, and swears a separate affidavit in support of it at Annexure B.
My representative in Punjab. I am represented in Punjab by Harpreet Singh Sandhu, of X, who is authorised to present this complaint, to receive notices on my behalf, to appear before this Commission and before any authority to whom this Commission may be pleased to refer the matter, and to obtain copies of the record. Notice to my representative may be treated as notice to me, but I pray that it be sent to my email address as well.
The instrument of authority. The authority of my representative is contained in a special power of attorney dated 14 March 2026, executed by me at Surrey and authenticated by a Notary Public of the Province of British Columbia, and attested at the Consulate General of India, Vancouver on 18 March 2026, authorising the said attorney to present, prosecute and withdraw this complaint and to receive notices, and conferring no power to sell, mortgage or otherwise deal with the said property. The original is produced for inspection and a copy is annexed. I say expressly that this authority does not empower my representative to sell, mortgage, gift or otherwise deal with the property described in clause 4, and that no other person holds any authority from me to do so.
When I was last in Punjab. I was last physically present in Punjab on 4 April 2026. My absence from Punjab since that date is the reason the acts complained of below could happen and could continue unchecked, and it is the reason I come before this Commission instead of attending in person at each counter in the district.
2.1 The Commission's remit, and my standing before it. This Commission is constituted under the Punjab State Commission for Non-resident Indians Act, 2011 (Punjab Act No. 33 of 2011), notified in the Punjab Gazette on 29 November 2011, to protect and safeguard the interests of non-resident Indians in the State of Punjab and to recommend remedial measures for their welfare. I am a non-resident Indian, being a citizen of India ordinarily residing outside India, and I say that I fall within the class of persons for whose protection this Commission is constituted. If the Commission requires me to establish that standing by reference to the definition clause of the Act, I crave leave to place further material on record and to be heard upon it. Both the property and the grievance to which this complaint relates lie wholly within the State of Punjab, and no part of this complaint concerns property outside Punjab.
2.2 The powers I invoke. I am aware, and I record it here so that there is no misunderstanding later, that this Commission has all the powers of a civil court trying a suit in respect of summoning and enforcing the attendance of any person and examining him on oath, requiring the discovery and production of documents, receiving evidence on affidavit, requisitioning any public record from any court or office, and issuing commissions for the examination of witnesses. It is on that footing, and on no wider footing, that I ask in clause 9 for the respondents to be summoned and for the revenue, estate and police record to be requisitioned.
2.3 The limits I accept. I am equally aware that what this Commission makes at the conclusion of an inquiry is a recommendation and not a decree. It is not executable. It does not bind the State Government or the police. By itself it restores no possession, cancels no instrument and corrects no entry. I therefore do not ask this Commission to declare my title, to cancel any deed, to set aside any mutation, to pass a decree for possession or mesne profits, or to award damages or costs, because none of that lies within its powers. Relief of that kind lies in a suit — for cancellation of a void or voidable instrument under sections 31 to 34 of the Specific Relief Act, 1963, or for possession upon title — and I understand that the periods of limitation prescribed by the Limitation Act, 1963, including three years from the date of knowledge to set aside an instrument and twelve years for possession based on title, continue to run while this complaint is pending and are neither suspended nor extended by it. What I ask of this Commission is set out in clause 9 and nothing beyond it.
3.1 Who is complained against. The persons complained against, with their addresses for service of summons, are —
- Shri Balwinder Singh, son of Late S. Gurdial Singh Sandhu, resident of House No. 42, Village Bhullarai, Tehsil Phillaur, District Jalandhar, Punjab — the person in occupation.
- Smt. Rajinder Kaur, wife of Shri Balwinder Singh, resident of the same address.
- The Station House Officer, Police Station Phillaur, District Jalandhar, Punjab — before whom the complaint dated 9 January 2026 is stated to be pending.
How the principal respondent stands to me. The principal respondent is a relative of the complainant. I state this because it explains both how the respondent came to be in a position to do what is complained of, and why the matter was not brought to a head earlier.
3.2 Service and production. I pray that summons be issued to each of the respondents named above at the address given against his name, that each be required to appear, and that each be required to produce the originals of every document he sets up in answer to this complaint, as prayed in clause 9.
4.1 Description. The property to which this complaint relates is agricultural land in a revenue estate, and its particulars are as follows —
| Particular | Detail |
|---|---|
| Revenue estate / town | Bhullarai |
| Tehsil / Sub-Tehsil | Phillaur |
| District | Jalandhar, Punjab |
| Hadbast No. | 214 |
| Khewat / Khatauni | Khewat No. 118, Khatauni No. 231 |
| Khasra / Killa No(s). | Killa Nos. 22//7, 22//8/1 and 23//11 |
| Area | 6 kanal 12 marla |
| Jamabandi year relied upon | 2021-22 |
| Postal address and boundaries | X |
| Approximate present value | ₹85,00,000 (Rupees Eighty Five Lakh only) |
The revenue record. The record of rights of the said revenue estate is maintained under section 31 of the Punjab Land Revenue Act, 1887, and the periodical record — the jamabandi upon which I rely — under section 32 of that Act. The Halqa Patwari makes the entry, the Field Kanungo checks it and the Circle Revenue Officer, being a Tehsildar or Naib Tehsildar notified as an Assistant Collector of the second grade, sanctions or rejects a mutation upon it. The record is viewable at https://jamabandi.punjab.gov.in/ and a certified copy of the fard is obtainable at the tehsil, the State having decided in April 2025 to move Fard Kendra work to the Sewa Kendras. The nakal jamabandi for the year 2021-22 upon which I rely is annexed, and the entries material to this complaint are marked upon it.