7.
SUIT FOR
PROHIBITORY INJUNCTION, BREACH OF CONTRACT BY THE DEFENDANT[CD1]
IN THE COURT OF THE ........................
Suit No. .................... of
19...............
C.D....................................................................Plaintiff
versus
C.F.
........................................................... Defendant
The
above named plaintiff most respectfully submits as under :
1.
That
the plaintiff let out his Plot, situate at .................. Road, of
................ square-yards in area, the boundaries of which are given below,
to the defendant for .................... years through a registered lease-deed
executed on .................... 19 .. .................., for storing timber
for sales and supplies in the city or out-station, at an yearly rent of Rs.
.............
Boundaries of the Plot are as follows:
In the East. ………………..
In the West .... ……………
In the North……………….
In the South ……………......
2.
That in the deed of aforesaid it was expressly agreed that the defendant will
not make or raise any permanent construction. He was allowed to have temporary
constructions of wood. But, however, in breach of the agreement defendant has
begun to raise pakka constructions over the plot, and has raise room which is
not yet roofed. The measurements and details of which are & the foot of the
plaint with a site plan.
3.
That the plaintiff checked the defendant from not so doing, not heed to the
warning of the plaintiff and is continuing to raise and construction aforesaid.
4.
That the defendant has threatened on .................. plaintiff to raise
constructions over the whole of the plot leased. -
5.
That cause of action arose on ................. 19………………. plaintiff began to
raise pakka constructions over the plot and secondly on 19………………….when he
threatened the plaintiff to make this court has jurisdiction to decide the
matter.
6.
The suit is valued at ................... rupees, the purpose of jurisdiction and
Rs. fee. And Court Fee is paid according to the reliefs claimed.
RELIEFS CLAIMED :
The
Plaintiff claims :
(1) a mandatory injunction to be issued to the
defendant and remove the pakka construction already raised by him above-mentioned;
and
(2) to issue a prohibitory injunction
restraining the defendant from raising any pakka or permanent construction in
future on the to of land.
Plaintiff Through Advocate
I, above named plaintiff, do hereby verify
that the contents of paras....... to .................... of the plaint are
true to my personal knowledge and those of paras .................... and
.................... thereof are based on legal advice which I believe to be
true.
Verified on this ................ day
of ................ 19 ................. at.
Plaintiff
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