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

 

VERIFICATION[CD2] 

 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

 

 [CD1]SUIT FOR PROHIBITORY INJUNCTION, BREACH OF CONTRACT BY THE DEFENDANT

 [CD2]VERIFICATION