H.P.D.S. Gunawardena (Deceased) v. G.D. Upali Dharmasena – CA PHC 92/2015-2021

In the case between H.P.D.S. Gunawardena (succeeded by A.M. Nita Chandrawatha) and G.D. Upali Dharmasena (together with Perakum Farmer Organisation and the Commissioner General of Agrarian Development, among others), the court addressed the issues of locus standi of a registered farmer organization under Section 90 of the Agrarian Development Act No. 46 of 2000, proper exhaustion of remedies, and the identification of necessary parties in agrarian proceedings. It was held that the Perakum Farmer Organisation, as a registered body corporate, possesses the legal capacity to initiate complaints and should have been named as a necessary party in the proceedings. Procedurally, the requirement to exhaust all available remedies before approaching the appellate court was emphasized, with failure t