Sandya Rajapakse, Janatha Estate Development Board vs Ramya Nirmali Illeperuma and another – SC APPEAL 76/2016-2024

In the case between Ramya Nirmali Illeperuma, Ajith Bhathiya Illeperuma (through their attorney Opheila Eileen Illeperuma) and Sandya Rajapakse, Chairman, Janatha Estate Development Board, and others, the court addressed the issue of whether a District Court engaged in a summary investigation under Sections 241–245 of the Civil Procedure Code is required to conduct a full inquiry into the ownership of a seized property, especially when no evidence is led by a defendant claiming State ownership. It was held that a summary inquiry is confined to determining possession at the time of seizure and does not require the court to establish actual ownership, particularly when evidence supporting State ownership is lacking. The principle was reaffirmed that, in such proceedings, a claimant must demo