[1] In brief, the plaintiff's claim against the defendant is for trespass on the plaintiff's lands, and damages arising from the trespass.

[2] By this writ action the plaintiff seeks judgment against the defendant for a total sum of RM221,472,061.00. In the statement of claim, the plaintiff applied for the following reliefs:

(a) A declaration that the defendant is a trespasser on the lands and is a nuisance to the plaintiff;

(b) Special damages amounting to RM23,077,116.00 being the total rental value of the lands based on its current prevailing market value rates calculated with effect from 22 March 2011 and continuing until cessation of the telecommunication services and the date of removal of the defendant's offending infrastructure from the lands as per Annexure A and/or alternatively for the same to be assessed;

(c) Special damages amounting to RM198,110,908.00 being loss of opportunity and/or loss of profit by reason of the continued wrongful occupation of the squatters which was caused, encouraged and or facilitated by the defendant resulting in the plaintiff being prevented from developing the lands to its full potential as per Annexure B and/or alternatively, for the same to b