SUIT FOR INJUNCTION TO
RESTRAIN A PUBLIC NUISANCE[CD1]
IN THE COURT OF THE ........
Suit No. ................... of 20........
C.D..................................... Plaintiff
versus
C.F.....................................
Defendant
The
abovenamed plaintiff most respectfully submits as under:
1.
The
defendant has wrongfully heaped up earth and stones on a public road known as
.................... Street at .................... so as to obstruct the
passage of the public along the same and threatens and intends, unless
restrained from so doing, to continue and repeat the said wrongful act.
2.
The
plaintiff has obtained the leave of the Court for institution of the suit.
3.
Cause
of action arose on .................... 20 .................. When the
defendant obstructed the road by wrongfully heaping up earth and stones on the
public road mentioned above, and this Court has jurisdiction to try the suit.
4.
The
suit is valued at Rs. ................... and court fee is paid thereon.
The
Plaintiff claims:
(i)
A
declaration that the defendant is not entitled to obstruct the passage of the
public along the said public road;
(ii)
an
injunction restraining the defendant from obstructing the passage of the public
along the said public road and directing the defendant to remove the earth and
stones wrongfully heaped up as aforesaid.
Plaintiff
Through
Advocate
I,
abovenamed plaintiff, do hereby verify that the contents of paras
................... to ................... of the plaint are true to my
personal knowledge and the of paras ...................and ...................
thereof are based on legal advice which I believe to be true.
Verified
on this ................ day of ................... 20 .................. at
......
Plaintiff
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