IN THE COURT OF SH. ………………. SENIOR CIVIL JUDGE , ………….

, DELHI

CIVIL SUIT (OS) NO. ……… OF 20…….

IN THE MATTER OF :

SMT. ……………. W/O ……………..

RESIDENT OF ………………………. ……………PLAINTIFF

VERSUS

MR. …………….. S/O ………………

RESIDENT OF ………………………. …………DEFENDANT

SUIT FOR PERMANENT INJUNCTION

MOST RESPECTFULLY SHOWETH :

1. The plaintiff is the owner and the permanent resident of H.no. ………… , ……. , New Delhi.
She has been living for the past ……. Years with her husband and her son Mr. …………… with
his wife and minor son as licensee.

2. The plaintiff is the owner of the property consisting of 2 floors where ground floor is in
occupation of the plaintiff and second in the occupation of son.

3. The right were granted to the Mr. …………. vide registered license deed no ………… on
….. /…… /……

4. The license granted was for a duration of ……. Years , from …… /….. /….. to ……/……/……..

5. The license came to an end on ……/……./…….. . Since then the plaintiff has sent registered
legal notice on …….. , ……… and ……… .

6. The plaintiff has refused to vacate the said premises . On requesting to leave MR. ………….
threatened to face serious consequences and has made attempts to cause annoyance to the
plaintiff.

7. The plaintiff has no other efficacious remedy except to approach this Hon’ble court for
seeking relief of injunction against defendant for vacating the premises and interfering in
peaceful possession of the H.no …………….. ,……………, New Delhi .

8. The cause of action arose on …./……/……. when the license granted ceased to exist and the
right given to licensee thereby ceased .

9. That the parties to the suit for the purpose (s) of court fee and jurisdiction is Rs. ……./- on
which the requisite court fee has affixed.

10. The suit is within the period of limitation .

11. This Hon’ble Court has jurisdiction to entertain this suit because the part of the cause of
action arose at Delhi and the suit property is situated within the territorial jurisdiction of this
Hon’ble Court.

PRAYER :

It is, therefore most respectfully prayed that this Hon’ble Court may be pleased to :-

1. Pass decree for permanent injunction in favour of the plaintiff and against the defendant for
vacating the premises and also from interfering in peaceful possession of H.no …………,
………, new Delhi.

2. Award cost in favour of the plaintiff and against the defendant.

3. Pass such other and further orders as may be deemed fit and proper on the facts and in the
circumstances of this case.

Place : Plaintiff

Date : through

Advocate for the plaintiff

 VERIFICATION:

Verified at Delhi on ……/……/……. The contents of para …… to ……… are true to my knowledge
derived from the record , the para ….. to ……..are true on information received and believed to be
true last para is the humble prayer in to this hon’ble court.

Plaintiff

[note* - plaint to be supported by affidavit ]

 IN THE COURT OF SH. ……………….. SENIOR CIVIL JUDGE , ………. , NEW DELHI

IA. OF …… OF 20……..

IN

CIVIL SUIT (OS) …….. OF 20……

IN MATTER OF :

SMT …………….. W/O …………

RESIDENT ………………………. ………..PLAINTIFF

VERSUS

MR. ……………. S/O ……………

RESIDENT ……………………….. …..…DEFENDANT

APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER XXXIX, RULE 1 & 2 READ
WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908

MOST RESPECTFULLY SHOWETH :

1. That the plaintiff has filed a suit for permanent injunction which is pending for disposal before
this Hon’ble Court.

2. That the contents of the accompanying suit for permanent injunction may kindly be read as a
part and parcel of this application which are not repeated here for the sake of brevity.

3. That the plaintiff/applicant has got a prima-facie case in his favour and there is likelihood of
success in the present case.

4. That In the case defendant are not restrained by means of ad-interim injunction for staying in
the premises and from interfering the physical peaceful possession , the plaintiff shall face
irreparable loss and loss and suit shall become infructuos and would lead to multiplicity of
case

5. The balance of convenience lies in favour of plaintiff and against the defendant .

PRAYER:

IT is therefore most respectfully prayed that this court may be pleased to pass :-

1. Ex-parte ad interim induction restraining the defendant to cause annoyance or any attempt to
threaten the plaintiff or any action of same kind .

2. pass such other and further order(s) as may be deemed fit and proper on the facts and in the
circumstances of this case

Place: plaintiff

Through

Time:

Counsel for plaintiff

[Note*- application to be supported by an affidavit]