IN THE COURT OF CITY CIIVL JUDGE, JAIPUR

Civil Original Suit no – XXX/ 2020

Amol Palekar s/o Ajit Palekar, r/o 255, C-Scheme, Jaipur - Plaintiff

Versus

Chirag Shah s/o Satish Shah, r/o 898, Mansarovar Park, Jaipur - Defendant

SUIT FOR PERMANENT INJUNCTION

May it please this Learned Court,

The plaintiff, above mentioned, most respectfully, submits as under –
1. That the Plaintiff is the owner of a plot bearing the address 799, Shastri Nagar, Jaipur
(hereinafter referred to as the disputed plot).
2. That the adjoining the suit plot, 800, Shastri Nagar, Jaipur is an open air restaurant
‘Happy Hours’ operated by the defendant.
3. That the Plaintiff last visited the plot, on January 31, 2020 he noticed that the
defendant had increased the operational area of his plot by breaking down the
dividing wall and placing chairs and tables on the vacant plot.
4. That the Plaintiff sent a legal notice to the defendant on 1 February, 2020 to vacate
the plot and start the reconstruction of the wall within 15 days.
5. That the non-compliance of the defendant to legal notice resulted in cause of action to
have arisen on 15 February, 2020.
6. That the disputed plot is situated in Shastri Nagar, Jaipur and therefore this Learned
Court has jurisdiction to hear and adjudicate the suit.
7. That the suit is not barred by limitation.
8. That the valuation of the suit for the purposes of court fees and pecuniary jurisdiction
is Rs. 25,000 out of which Rs. 2,000 Court fess has been paid.
It is therefore most humbly prayed that the Learned Court may be pleased to pass a decree
with costs in favor of the Plaintiff and against the defendant –
Ordering the defendant to vacate the suit plot, reconstruct the dividing wall, and handover
the vacant possession to the plaintiff.
Ordering the defendant to pay the cost of the suit and grant such other relief, which the
Learned Court feels just and proper in the interest of justice. The affidavit in support of
the plaint is enclosed.
Jaipur
Dated 18 February 2020 Plaintiff

VERIFICATION

I, Amol Palekar, above mentioned Plaintiff, verify an oath that the contents of para 1 to
para 7 of the plaint are true to the best of my knowledge and belief, and the last para is
with regard to the relief.

Jaipur
Dated 18 February 2020 Plaintiff
 AFFIDAVIT IN SUPPORT OF THE PLAINT
IN THE COURT OF CITY CIVIL JUDGE, JAIPUR

Civil Original Suit No. – XXX/2020

Amol Palekar s/o Ajit Palekar, r/o 255, C-Scheme, Jaipur - Plaintiff

Versus

Chirag Shah s/o Satish Shah, r/o 898, Mansarovar Park, Jaipur - Defendant

SUIT FOR PERMANENT INJUNCTION

I, Amol Palekar s/o Ajit Palekar, r/o 255, C-Scheme, Jaipur, Plaintiff in this case swear in the
name of god and state as under –

1. That I am plaintiff in this case and conversant with the facts of this case.
2. That the contents of the plaint may be treated as part of this affidavit.
3. That the contents of the plaint are true to the best of my knowledge and belief.

Place: Jaipur Sd/Amol Palekar

Date: 18 February, 2020

VERIFICATION

I, Amol Palekar s/o Ajit Palekar, r/o 255, C-Scheme, Jaipur, Plaintiff in this case swear in the
name of god and verify an oath that the contents of this affidavit are true to the best of my
knowledge and belief, so help me god.

Place: Jaipur Sd/Amol Palekar

Date: 18 February, 2020
 IN THE COURT OF CITY CIVIL JUDGE, JODHPUR

Civil Original Suit No. – XXX/ 2020

Mr. Shyam Prasad Mukherjee s/o Gopal Prasad Mukherjee, aged 50 years, r/o 7459, Sundar
Nagar, Jodhpur - Plaintiff

Versus

Mr. Dheeraj Shah s/o Mr. Vipin Shah, aged 30 years, r/o 2599, Ganga Apartments, Jodhpur
- Defendant

SUIT FOR PERMANENT INJUNCTION

May it please this Hon’ble Court,
The Plaintiff, above mentioned, most respectfully, submits as under –
1. That the plaintiff owns shop no 24, Pacific Mall, Jodhpur since 2012. The plaintiff is
in the business of selling grocery, vegetables, and has a godown for storage purposes.
2. That the defendant owns shop no 25, Pacific Mall. Jodhpur since 2016. He is in the
business of selling mobile phones and accessories. He also has an attached godown to
his shop.
3. Since 2012,