Format of SUIT FOR PERMANENT INJUNCTION

SUIT FOR PERMANENT INJUNCTION

In the Court of……………………….

Suit No. l……………………. of 200

In the Matter of: –

AB…………………………………………………………… Plaintiff

versus

CD……………………………………………………….. Defendant

SUIT FOR PERMANENT INJUNCTION

Respectfully Showeth:

1. That the plaintiff has been residing at House No……………………….. ………………………. as a tenant for the last about nine years with his mother, wife and children.

2. That upto the year………………………. the plaintiff had been living in a Tinshed constructed by him in the premises of House No………………………..

3. That the plaintiff in………………………. constructed thereon pucca room and kitchen at his own cost. Some of the receipts available pertaining to the material purchased by the plaintiff for construction of a room and kitchen are annexed hereto and collectively marked as Annexure-A-1.

4. That the plaintiff is a poor person and bread earner for three minor children apart from his wife and mother and for earning his livelihood is running a small Dhabba outside the said house.

5. That the plaintiff had been paying Rs……………………….. per month as rent regularly to Defendant No. 1 in cash. However, no receipt is being issued by defendant No. 1 towards payment of the said rent.

6. That defendant Nos. 2 and 3 the sons of defendant No. 1 have been giving threats to the plaintiff either to vacate the premises or face dire consequences.

7. That on………………………. Defendant No. 1 alongwith his associates entered the room of plaintiff using filthy and abusive language and started beating the plaintiff.

8. That the plaintiff reported the matter to the Incharge Police Station, ………………………. and lodged FIR on……………………….. However no protection was afforded to the plaintiff by the police.

9. That the plaintiff is a law abiding citizen and has rehabilitated himself in the petty business at his own, whereas the defendant Nos. 2 and 3 are influential people who believe in taking the law in their own hands and also believe on using muscle power.

10. That defendants are bent upon grabbing the room and kitchen by forcible eviction of the plaintiff and his family through use of their might and money.

11. That the acts of the defendants are unlawful, arbitrary, unwarranted and against all cannons of justice and they are liable to be restrained by passing a decree of permanent injunction under Section 30 of the Specific Relief Act which remedy is only efficacious in the circumstances of the case.

12. That the cause of action first accrued to the plaintiff against the defendants in the……………………………………………….. entered the room of the plaintiff using abusive language and started beating him. The cause of action again arose on ………………………. in favour of the plaintiff when the defendants 2 and 3 with their muscelmen locked the plaintiffs residence from outside. The cause of action for filing the present suit is still subsisting and will continue to subsist in favour of the plaintiff till the defendants are ‘restrained by a decree of this Hon’ble Court as prayed.

13. That the parties reside in Delhi and the suit property is also situated in Delhi, this Hon’ble Court therefore has jurisdiction to entertain and try the suit.

14. That the value of the suit for purposes of jurisdiction and court fee is assessed at Rs. 130/- for which the requisite court fee for the relief of permanent injunction has been affixed/paid on the plaint.

PRAYER

It is, therefore most respectfully prayed that this Hon’ble Court may be pleased to grant a decree of permanent injunction in favour of plaintiff and against the defendants permanently restraining the defendant Nos. 1 to 3, their agents, servants, relatives etc. interfering with the peaceful possession, occupation, enjoyment and use of the premises House No………………………………………………… by the plaintiff without following the process of law.

(3) Such other relief which this Hon’ble Court may in the circumstances of the case, be pleased to grant may also be granted.

Plaintiff

Through Advocate

VERIFICATION

Verified at………………………. on this the………………………. day of ………………………. that the contents of paras No……………………….. of the plaint are true to my knowledge and belief, whereas, those of paras No……………………….. are believed to be true on legal advice received through the counsel. Last para is prayer to this Hon’ble Court.

Plaintiff.

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