Injunction Prohibitory
IN THE COURT OF LEARNED CIVIL JUDGE (SENIOR DIVISION) …………………
In Civil Suit No.: ______ of 20……
…………………………………………………………………Plaintiff
Versus
……………………………………………………………Defendants
Civil suit for permanent prohibitory injunction for restraining the defendants
from interfering in any manner whatsoever particularly ______ situated over
Khata No. ______ Khasara No. _______ more particularly depicted in rough plan
of the sight and photograph excepting in accordance with Law.
Respectfully Sheweth:
1.That the plaintiff is resident of _____________________
2. That the plaintiff is presently working as ______________________ with
the department.
3. That in the month of ________ the state of _______________________
has orally granted the suit land in favour of the plaintiff
and allowed the plaintiff to raise construction for
his residential house over the same. The plaintiff has spent
major portion of his hard earned money for the construction of
the said shed house situated over Khata. Khatauni Khasara No. after
getting the house constructed over the suit land by the plaintiff the state
government/ department has also recognized the legal possessory status of the
plaintiff over the suit land. The plaintiff has also been given electricity
connection from electricity department and he has also got his ration card on
the same address. The name of the plaintiff and other persons of his
family members are also figuring in the voters list of the
said ward.
4. That till _________________ nobody has objected to and raised any
objection regarding the raising of construction of the house of the plaintiff
over the said and the plaintiff lived there peacefully, openly and to the very
constant of the owner of the property. The possession of the plaintiff is
long standing a one and the same has not been disputed/ disturbed by any
one till date.
5. That no show cause notice of any proceedings for the eviction of
the plaintiff from the land and from the house raised by the plaintiff over the
same has ever been initiated.
6. That on _________________ some of the officials from ________________
department came on the spot and threatened to dispossess the plaintiff from the
suit land and also threatened to dismantle the house/shed of the plaintiff
without any legal orders that too illegally and wrongly. As no order of
eviction has been passed against the plaintiff till date by any competent
authority/Court as such plaintiff has got prima facie a very good case in his
favour since he is in possession of land for the last more than _____ years.
The balance of convenience is also in favour of the plaintiff and against the
dependent and in case the suit of the plaintiff is not decreed the plaintiff
will suffer irreparable loss and injury which can't be compensated in terms of
money, rather it will lead to multiplicity of litigation between the parties
and the plaintiff will come on roads as he has no other residential house
except the present one.
7. That there are as many as __________________________ residential house
constructed by some other people over the adjoining land of the present
plaintiff which is also owned by _______ government/department. That till date
no show cause notice has been issued to them nor any proceedings for eviction
has been started/initiated against them in the competent Court of law. The
wrongful all illegal dispossession/dismantling the house of the plaintiff is
arbitrary, malafide, illegal and even discriminatory.
8. Jurisdiction.
9. Cause of action.
10. Limitation.
11. Valuation.
………………………………….. Plaintiff
______ Through, Advocate
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