BEFORE THE SENIOR CIVIL JUDGE OR DISTRICT JUDGE AT

_________

CIVIL SUIT NO. __________ OF 20__

 

IN THE MATTER OF:

Mr.
_________                                                            PLAINTIFF
 

VERSUS

Mr. ____________                                                    DEFENDANT

SUIT FOR INJUNCTION AGAINST NUISANCE

MOST RESPECTFULLY SHOWETH:

1. That the plaintiff is a business man residing at

_________________________.

2. That the Plaintiff is the absolute owner and in possession of Flat

No. ________ at _____ .

3. That the Defendant is the owner and in possession of Flat No

________ at _____ adjoining Plot No. ______________.

3. That on ______ the Defendant has erected upon his aforesaid

plot a cloth washing and colouring unit, which is illegal as per the
notification passed by the Municipal Council and and per
Environment law. In the said colouring unit the Defendant is
engaged in washing clothes using machines, colouring it with the
help of machines and use huge quantity of water in the residential
area. As a result huge quantity of waste water is being flowing
through the front side of the house of Plaintiff. 
4. The Defendant is using the Flat for commercial purpose without
seeking permission from any authority.

5. That the Plaintiff has sent several complaints to the public

authorities to stop this nuisance and illegal activity, but in vain.
Copies of Complaints are annexed herewith as Annexure P1. 

6. That on account of the use of Flat by the Defendant for

commercial purpose, Plaintiff has been unable to peacefully reside in
the house.

7. That cause of action has arose on _________ and continues to

exist even at present with use of the Flat for the aforesaid unlawful
purpose.

8. That the Valuation of the Suit for the purpose of Court fee and
Jurisdiction is Rs. ______________ and Court fee of Rs.
___________ and Court fee of Rs. ______ has been affixed.

9. That the suit property is situated within the Jurisdiction of this

Hon'ble Court. Having regard to the cause of action, narrated above,
this Hon'ble Court has the Jurisdiction to entertain any try this Suit.

10. The Plaintiff accordingly claims that the Defendant be restrained

by way of decree of injunction from using the suit Flat as a
Commercial Property thereby committing or permitting, any further
nuisance.

10. In the facts and circumstances of case mentioned herein above

this Hon'ble Court may graciously be pleased to:
 

PRAYER

That the Plaintiff, therefore, pray that this Hon'ble Court may pass -

a) A decree restraining the Defendant Permanently from operating

his Cloth Washing and Coloring unit from Flat No.______ ;

b) Any other relief, which the Hon'ble court deems fit, may please
be granted to the plaintiff in the interest of justice.

PLAINTIFF
 THROUGH

______________., Advocate

Place :

Date :

VERIFICATION

I, ____________, the above named Plaintiff states on solemn

affirmation that contents of Para 1 to __ of the Plaint are true and
correct to the best of my knowledge and belief and those of legal
averments are true and correct on the basis of legal advice received
and believed to be true by me.

Verified at ____ on this ______ day of _____ 20__

PLAINTIFF