PETITION UNDER SECTION 9 OF THE ARBITRATION AND

CONCILIATION ACT, 1996 FILED BEFORE HON’BLE HIGH

COURT SEEKING URGENT INTERIM ORDERS ON ACCOUNT
OF A DISPUTE ARISING OUT OF A COLLABORATION
AGREEMENT EXECUTED WITH A BUILDER FOR
CONSTRUCTION OF A HIGHWAY RESORT PROJECT ON THE
LAND BELONGING TO THE PETITIONER.

IN THE HIGH COURT OF ______ AT ______

O.M.P. NO OF ______
IN THE MATTER OF
M/S ____________________
… PETITIONER
VERSUS
M/S ____________________
… RESPONDENT
INDEX
SNo. Particular Pages

01 Court Fee Sheet

02 Urgent Application
03 Memo of Parties
04 Application under Section 11 of the
Arbitration and Conciliation Act 1996
05 Affidavit in support
06 List of documents alongwith documents
07 Exemption Application with Affidavit in
support
08 Vakalatnama

PETITIONER
THROUGH

( )
ADVOCATE
ENROLLMENT NO………
ADDRESS:………………
EMAIL:…………………
MOB. NO………………

Place :_____
Signed on: ___________
Filed on :
Note – That the petitioner has already filed a Petition under Section 9
of the Arbitration & Conciliation Act 1996 and the same is
pending adjudication before Hon’ble Mr. Justice ______ and
is listed for ______.
 IN THE HIGH COURT OF ______ AT ______

O.M.P. NO OF ______

IN THE MATTER OF

M/S ____________________
… PETITIONER
VERSUS
M/S ____________________
… RESPONDENT

To

The Deputy Registrar,

________________.

URGENT APPLICATION

Sir,

Will you kindly treat the accompanying petition as urgent one in

accordance with the High Court Rules and Orders.

The ground of urgency are :-

“ Interim Orders have been prayed for ”

PETITIONER

THROUGH

( )
ADVOCATE
ENROLLMENT NO………
ADDRESS:………………
EMAIL:…………………
MOB. NO………………

Place :_____
Signed on: ___________
Filed on :
 IN THE HIGH COURT OF ______ AT ______

O.M.P. NO OF ______
IN THE MATTER OF
M/S ____________________
… PETITIONER
VERSUS
M/S ____________________
… RESPONDENT

MEMO OF PARTIES
M/s. _______,
having its Registered office: _______
_______ duly represented through
its Director, _______,
S/o _______, R/o _______
_______ _______ ….Petitioner
Versus
M/s. _______,
having its registered office at : _______
_____________________, through its Director
Mr. _______

Also at
_______
_______,
___________

And also at
M/s. _______,
C/o _______,
_______
_______
…. Respondent

PETITIONER

THROUGH

( )
ADVOCATE
ENROLLMENT NO………
ADDRESS:………………
EMAIL:…………………
MOB. NO………………

Place :_____
Signed on: ___________
Filed on :
 IN THE HIGH COURT OF ______ AT ______

O.M.P. NO OF ______

IN THE MATTER OF

M/S ____________________

… PETITIONER
VERSUS

M/S ____________________

… RESPONDENT

APPLICATION FOR EXEMPTION UNDER SECTION 151

C.P.C

Most Respectfully Sheweth :

1. That the petitioner has filed the accompanying petition in this

Hon’ble Court. The contents of the same are not being reproduced here for

the sake of brevity but those may kindly be read as part and parcel of this

application.

2. That the petitioner has filed true/photo copies of documents

alongwith the petition. The certified copies of the same are being applied

and those shall be filed in this Hon’ble Court as soon as they are received

from the Branch.

 PRAYER

It is therefore most respectfully prayed that the present petition may

kindly be heard on the strength of true/ photo copies of the documents and

the filing of certified copies may not be insisted upon at this stage, in the

given facts and circumstances of the case in the interest of justice.

Prayed accordingly.

Affidavit is filed in support.

PETITIONER
THROUGH

( )
ADVOCATE
ENROLLMENT NO………
ADDRESS:………………
EMAIL:…………………
MOB. NO………………

Place :_____
Signed on: ___________
Filed on :
 IN THE HIGH COURT OF ______ AT ______

O.M.P. NO OF ______

IN THE MATTER OF

M/S ____________________ & OTHERS

… PETITIONER
VERSUS

M/S ____________________
… RESPONDENTS

1. Provision under which the Application under Section 9 of the

application is filed Arbitration and Conciliation Act

1996.

2. Name of the applicant with 1. ____________________. duly

address represented through its

Managing Director

__________, having its

Registered Office at

__________, __________

__________

2. Shri __________ S/o Shri

__________ R/O __________,

__________ (__________)

duly represented through his

General Power of Attorney

Holder _______.

(a) Smt. __________ W/O

Shri __________ R/O

__________, __________
 (__________) duly

represented through her

General Power of Attorney

Holder __________.

3. Name of the other parties to 1. ____________________,

the Arbitration Agreement __________, __________,

with complete Address __________

2. __________ (Formerly known

as __________)

____________________________

_______________

4. Name and address of Name of Hon’ble Mr. Justice

Arbitrator __________ (Former Judge of

Hon’ble Supreme Court of India)

has been proposed in Legal

Notice dated _____ to be

appointed as Sole Arbitrator in

terms of clause __ of the

Agreement dated _____

05. Name and address of Person Sole Arbitrator to be appointed for

or Institution if any, to adjudication of disputes and the

whom any Function has venue of Arbitration shall be at

been entrusted by the parties __________. (Clause __ of the

to the Arbitration Agreement)

Agreement under

appointment procedure
 agreed upon by them.

6. Qualification required if any Dispute are to be referred for

of the Arbitration by the Arbitration by Sole Arbitrator and

agreement of Parties the Arbitration shall be held in

accordance with the Arbitration

and Conciliation Act 1996 and the

venue of Arbitration shall be at

__________, ( Clause __ of the

Agreement ).

7. BRIEF WRITTEN STATEMENT DESCRIBING THE

GENERAL NATURE OF THE DISPUTES AND THE POINTS
AT ISSUES IS GIVEN HEREUNDER

7(1) That the petitioner No 1 is duly represented through its

Managing Director ______. The petitioner No.1 company is primarily

engaged in the business of real estate and has enviable goodwill in the

market.

7(ii) That in the months of _____ Petitioners No.2 and 3

who are husband and wife met _____, Managing Director of the Petitioner

No.1. Petitioner No. 2 represented to _____ that he was the owner of land

admeasuring __ canals __ Marla equivalent to _____ Acres i.e. to say

_____ sq.yds. approx. falling in Khasra No.

_____,_____,_____,______,_____,____ and _____ bearing Khatoni

No._____,_____,_____,______, of the revenue estate of Village ______ in

Controlled Area – 1, __________ which was purchased by him vide Sale

Deed No. ______ dated ______, Sale Deeds No. ______ dated ______,

Sale Deed No. ______ dated ______ and Sale Deed No. ______ dated
______ registered in the office of Sub Registrar, __________

(__________).The Petitioner No. 3 ___ __________ represented that she

was the owner of land admeasuring ______ app. ______ Acre i.e. ______

sq.yds. forming part of Khasra No.______ bearing Khatoni No.______ of

the Revenue Estate of Village ______ in Controlled Area-__, __________,

which was purchased by the Vendor vide Sale Deed No.______ dated

______ registered with the Sub-Registrar, __________. The total land of

petitioners No. 2 and 3 put together was thus ______ sq yds.

7(iii) That the petitioners No. 2 and 3 negotiated with the

petitioner No. 1 company for sale of part of the said land. That in

furtherance thereof, the Petitioner No. 2, out of his total land of ______ sq

yds entered into an Agreement to Sell dated ______ in respect of land

admeasuring ______ i.e. ______ sq yds with the petitioner No. 1, M/s

____________________. The petitioner No. 3 also entered into an

Agreement to Sell dated ______ with petitioner No. 1 company in respect

of the entire land owned by her measuring ______ sq.yds.

7(iv) That the petitioner no 2 further represented to the

petitioner no 1 that from the remaining portion of the land , an area of

______ sq yards could be utilized for the construction of a ______ but he

also at the same time stated that since the permission for change of land use

for construction of a ______ on the said land admeasuring ______ Sq. Yds.

had been granted by the Director Town and Country Planning ______

( __________ ) in his personal name, it was becoming difficult for him to

arrange finances from the bank/ Financial Institutions for the construction

of the ______ as the banks/Financial Institutions generally do not provide

finances to the projects of such large magnitude unless and until the same
was not in the names of Companies / Corporate . The petitioner no 2

represented to the petitioner no 1 that he had already approached the

concerned authorities for changing the name from “ __________ ______ ”

to the name of the company known as “ M/s __________ ______ ” . The

parties further negotiated amongst them and thereafter the petitioner No.2

entered into a collaboration agreement dated ______ with petitioner No. 1

for construction of a ______ on the land measuring ______ Sq.Yds. and it

was agreed that the petitioner No. 1 would provide a built up area of

______ sq.ft. in the proposed ______ to the petitioner No. 2 in

consideration thereof.

7(v) That after the petitioner no 1 and petitioner no 2 had

entered into a Collaboration Agreement dated ______, the petitioner no 2

Shri __________ requested the petitioner No.1 that he was willing to sell

his entitlement of an area of ______ sq.ft. to be provided under the

Collaboration Agreement to the petitioner No.1 for a sum of Rs ______ .

The petitioner no 1 then agreed to buy this area of ______ sq. ft. also, and

accordingly on ______, the petitioner No. 2 entered into an Agreement to

Sell with petitioner No. 2 and the petitioner No.1 bought the area of

______ sq,ft. which was entitlement of petitioner No. 2 under the

Collaboration Agreement dated ______ for a sum of Rs. ______/-.

7(vi) That though the parties had entered into the

Collaboration Agreement dated ______ for the construction of ______ but

the parties felt that since it was a time bound project therefore it would be

appropriate that if they could rope in a company having sound financial

credibility and good reputation in construction projects . It was felt that a

company having sound financials and track record in Highway

Construction Project would be able to complete the construction in a much

faster and efficient manner. Keeping these parameters in mind the

petitioner No. 1 and 2 entered into a Collaboration agreement dated ______

with the respondent company for the construction of ______ and the

petitioner No.3 signed the said Collaboration Agreement as a Confirming

Party. In the said Collaboration Agreement dated ______ the details of all

the transactions iner se between the petitioners i.e. petitioner No.1,

petitioner No.2 and petitioner No.3 were also mentioned for keeping the

record straight and also for clarity. On ______ the petitioners no 2 and 3

also gave respective possessions letters of the land to the petitioner No. 1

company and the petitioner No. 1 company in turn paid the entire

outstanding purchase consideration arising out of all the three Agreements

to Sell dated ______, dated ______ and ______. In other words the

accounts between the petitioners i.e. petitioner No.1, petitioner No.2 &

petitioner No.3 stood settled on ______ in all respects and Receipts for full

and final payments and the possession letters of the lands were duly handed

over by the petitioner No.2 & petitioner No.3 to the petitioner No. 1

company and as such the possession of the land was delivered to the

petitioner No.1 company. Thus the petitioners and more particularly

petitioner No.1 company had got possession of the lands.

It may be pertinent to mention that out of his total lands of ______ sq. yds.,

the petitioner No. 2 __________ retained an area of ___ sq yds for setting

up a Petrol Pump.

BRIEFLY THE SALIENT FEATURES OF THE COLLABORATION

AGREEMENT DATED ______ ARE AS UNDER:-
a. Shri __________ Party of the First Part

b. _____________ Party of the Second Part

c. ____________________ Respondent herein

(Party of the Third Part)

d. Smt. __________ Confirming Party

e. As per Collaboration Agreement dated ______ total land

admeasuring ______ sq yds was to be utilised for construction of a

______. The said land is on the main _______________ Highway

and is situated at the out skirts of __________ City.

f. The party of the first part was entitled to ______ sq.ft. of built up

area in the proposed ______ and the petitioner No. 1 was entitled to

remaining built up and unbuilt up area.

g. Project land as per the Collaboration Agreement included an area of

______ sq.yds (+) ______ sq yds and ______ sq.yds. totaling to

______ sq.yds. which has been provided in the agreement as

“PROJECT LAND”.

h. The respondent who is a Third Party in the said collaboration

agreement was to develop, construct a ______ on the project land.

The respondent was also liable for applying for requisite

license/permission/ sanction from the competent authorities and

obtain necessary sanctions, permissions and approvals.

i. That it was provided in the Collaboration Agreement that the

building plans for construction of ______ were approved by the

Director, Town and Country Planning vide Memo dated ______ and
 were valid upto ______ and it was further provided that extension of

time was sought from the Director, Down and Country

Planning,______ (__________) and upon his refusal to provide

further extension, the first party in the Collaboration Agreement

(petitioner No. 2 herein) had approached the Hon’ble High Court of

______ and __________ at ______ and the Hon’ble High Court vide

its order dated ______ had granted the extension for construction of

the ______ project by three years and in pursuance thereof, the

Director Town and Country Planning, __________ vide his Memo

dated ______ had extended the permission for change of land use

for a further period of three years from the date of issue of the said

memo. Thus for all purposes extension granted by the Hon’ble High

Court of ______ & __________ is upto ______ i.e. before ______.

j. Third party i.e. the respondent was to start the development and

construction works within the period of ___ days from the said

collaboration agreement dated ______ at its own costs and expenses

and the ______ was to be completed in a time bound manner i.e.

within the time period stipulated by the statutory authorities.

k. The parties had also agreed that the built up and unbuilt up

areas/space would be sold to prospective customers and all moneys

collected from the bookings/sale/leasing of built up/unbuilt up area

was to be deposited in an Escrow account which was to be opened in

the name of “__________”, The parties had following sharing

arrangement of the amount rendered from every sale/lease of

unbuilt/built-up area/space of the Resort :-

 Petitioner No. 1 __% of the amount so rendered

from every sale/lease of

unbuilt/built-up space of the

Resort.

Respondent __% of the amount so rendered

from every sale/lease of

unbuilt/built-up space of the

Resort.

Balance __% of the amount so rendered

from every sale/lease of

unbuilt/built-up space of the

Resort was to be paid by third

party (Respondent) to Mahindru

Charitable Trust and the money

was to be utilised for

charitable/social causes.

7(vii) That as mentioned above the construction of the _____ was to

start within __ days of the execution of the collaboration agreement and it

was surely a time bound project. Timing assumed greater significance

particularly when the plans were valid for only a period of ___ years from

the date of sanction and the construction had to be completed by the

respondent No. 2 on or before ______, The Hon’ble High Court of

______ and ______ at ______ vide it’s order dated ______ had extended

the permission for change of land use by three years only i.e. upto _____.

In this regard it is very pertinent to mention here that the said order dated

______ passed by Hon’ble High Court of ______ & ______ at ______

had given an extension only for a period of three years and therefore the

very purpose of the parties to get into the Collaboration Agreement dated

______ was to get the work executed in a time bound manner, as it was

clear to everyone that if the project is not completed within the stipulated

time period, then the extension of the permissions for change of land use

granted by the Hon’ble High Court would expire on ______ leaving the

petitioners to suffer irreparable and heavy financial losses and also

rendering the said land of no value because after the expiry of the said

period no construction activity can be carried out on the said land and the

land use of the said land would restore back to its original land use i.e. for

agricultural purposes.

7(viii) That after the execution of the Collaboration

Agreement dated _____ the petitioners legitimately expected that the

respondent company would start the development and construction work

within stipulated time period of ___days. The respondent company

however kept on making promises that they were going to commence the

development and construction work at site very shortly, but despite their

promises and assurances no construction actively actually ever started at the

said land. The petitioners reminded them the urgency involved in timely

commencement of construction work but the respondent despite being fully

aware of the repercussions of delays in commencement of construction

activity, did not start the work. Soon it became clear that the respondent

company neither had any intentions nor was in a position to muster

resources to carry out the construction activities within the stipulated time

period.
7(ix) That the petitioners were clearly disappointed

and naturally very agitated because the respondent company had failed to

carry out its contractual obligations. The petitioners also got to know from

various sources that the respondent company perhaps never had adequate

financial and manpower resources to execute the work and the respondent

company had basically entered into a Collaboration Agreement with the

petitioners by misrepresenting the facts.

7(x) That the crucial time was fast running out for

the petitioners to get the construction completed in all respects by ______

and thus serious differences/disputes arose between the parties on account

non-performance of contractual obligations by the respondent company.

Left with no other option, the petitioner No.1 vide legal notice dated

______ terminated the said collaboration agreement and cancelled the same

in all respects and also gave separate Notice for appointment of Arbitrator.

7(xi) That the petitioner No. 2 and also petitioner No. 3 gave their

separate legal notices on similar lines. The Petitioners also gave separate

legal notices to the respondent calling upon the respondent company and its

directors to return the general power of attorneys executed in favour of the

respondent company and also to not to act upon them in any manner.

7(xii) That the petitioners after termination of the said collaboration

agreement did not have any other option but to somehow start and complete

the construction activities either on their own or through any other third

party and that too in a time bound manner so that the entire construction

can take place on or before ______ i.e the said dead line given by the

Hon’ble High Court of Punjab & Haryana at Chandigarh in Civil Writ

Petition No. ______. In furtherance thereof the petitioner company and

other petitioners are making all possible effort to get the construction done

at the site, either on their own or any other third party under a fresh

collaboration agreement as the construction of a Highway Resort is not a

small project and requires huge financial resources and manpower

planning.

Very unfortunately however at this crucial juncture, the respondent

company and some officials claiming to be acting on the instructions of the

directors of the respondent company are threatening to disrupt the

construction activity which the petitioners are proposing to carry out either

through themselves or through any other third party under a fresh

Collaboration Agreement, on the project land. The petitioners are peace

loving and law abiding citizens and they want to complete the construction

on or before ______ so that their interest is not put to jeopardy.

Unfortunately the respondent have malafide intentions and designs and

they want to black mail the petitioners by coercing them to shell out heavy

amounts to them and that is the reason the respondent company and its

Directors and officials are deliberately threatening to disrupt the proposed

construction activity . The respondent perhaps know fully well that if they

succeed in delaying the construction activities then perhaps it would be fate

accompli for the petitioners who then shall suffer irreparable loss and

damages.

7(xiii) That it is respectfully submitted that the petitioners

herein have been wronged by the respondent and they have already suffered

huge financial losses besides loss of goodwill. It may be relevant to

mention here that the petitioners have been left high and dry by the

respondent on account of its failure to carry out its contractual obligations.

It may be noted that if the respondent would have carried out the

construction work and had completed the entire project on time, then the

entire sale proceeds of the Project would have been almost to the tune of

Rs. ___ Crores calculated at the minimum rate of sale price of Rs. _____/-

per sq.ft. multiplied by the total area to be constructed which was ____

sq.ft. app. The petitioner, M/s ______( Petitioner No1 ) who is entitled to

___% of the sale proceeds under the Collaboration Agreement , would then

have received a sum of Rs. ________/- (Rupees ____________ only). The

petitioner No. 1 therefore on account of non-performance of the contractual

obligations by the respondent, clearly stands to lose this amount as per

present calculations, besides a sum of Rs. _____ Crores towards the loss of

goodwill which the petitioner have suffered. Therefore the petitioner No. 1,

even as per present calculations would have a claim of Rs. ______/-

(Rupees thirty-_________ only) against the respondent company and

without prejudice to all other claims that may accrue in favour of petitioner

No. 1 in future, it is submitted that the petitioner No. 1 would have a claim

of minimum of Rs. ______/- (Rupees __________ only) and therefore the

petitioner reserves its right to file a detailed statement of claims before the

learned Arbitrator at an appropriate stage.

7(iv) That as stated hereinabove the petitioner have rightly

terminated the Collaboration Agreement. However disputes and claims if

any, can be referred to the arbitration by a sole arbitrator but respondent

cannot take away the favourable possession of the said land or disrupt the

construction activities scheduled to be carried out by the petitioners.

7(xv) That admittedly there is an arbitration clause in the

Collaboration Agreement and the disputes have to be adjudicate by a sole

arbitrator. The petitioners have already sent their legal notices through

their advocate for appointment of arbitrator and have proposed the name of

Hon’ble Mr. Justice ______ (Former Judge Supreme Court of India) to be

appointed as sole arbitrator for adjudication of the disputes which have

arisen between the parties. The said notices have been duly served on the

respondent. However the respondent company has not replied as yet to the

legal notices tom the petitioners.

7(xvi) That the petitioners have been put in such a situation

where they have hardly any choice but to get the construction done and

make the Highway Project. The petitioners are therefore contemplating to

raise the construction either through their own or through some third party

with whom they can enter into a collaboration agreement. The respondent

on the other hand is nursing malafide intentions to delay the matter and

thus cause wrongful loss to the petitioners. The petitioners respectfully

submit that today the real intention of the respondent company is to some

how make wrongful gains out of their own wrongs. The Respondent

company and its directors namely Shri ______and Shri ______ know very

well that further delay in construction could result in grave financial loss to

the petitioners. Therefore the respondent company and its directors are

now trying to threaten to disrupt the proposed construction by the

petitioners themselves or through any other third party on the said land and

in this process they are trying to coerce the petitioners to cough up huge

sums of money to the respondent who are hell bent of making loss out of

their own wrong/doings. It may be pertinent to mention that the directors of

the respondent company have clearly and very openly threatened the

petitioners that they shall take forcible possession of the land which is

presently with the petitioners and they shall also not allow any one else to

start construction if they are not given Crores of rupees by the petitioners.

The petitioners respectfully submit that it is clear cut case of not only

cheating, fraud but also of black mailing and taking unfair advantage of the

situation by the respondent. The petitioners have genuine apprehension that

the respondent company and its officials will either try to take forceable

possession of the Project Land from the petitioners or else they would

disrupt the proposed/intended construction by the petitioners themselves or

through a third party under a fresh collaboration agreement and therefore

the petitioners have no other efficacious remedy but to approach this

Hon’ble Court for urgent interim orders/protection to protect their legal

rights.

7(xvii)That it is thus a fit case where an urgent interim orders may be

passed in favour of the petitioners and the right of the petitioners be

protected.

7(xviiij) That it is settled preposition of law that in commencement of

any arbitral proceedings is not precondition for exercise of powers by the

Hon’ble High Court under Section 9 of the Act.

8. This Hon’ble Court has the powers to grant interim

relief to protect the interest of the parties.

It has also been held in catena of judgments of the Hon’ble Supreme Court

that Section 9 of the Arbitration and Conciliation Act 1996 only deals with

interim measures by the court and in a fit case where interest of parties

sought to be protected, such interim orders may be passed under section 9

of the Act. It has further been held that a party or a person is entitled to

interim protection if other party is either in the breach of terms of the

agreement or militates against equity, fair play and natural justice. It is

therefore, respectfully submitted that in view of the settled preposition of

law, the Hon’ble Court may be graciously pleased to pass interim Order.

9. That the cause of action to file the present petition

arose on ____ when parties entered into a collaboration agreement

and it arose on all such dates when the respondent company

breached the terms of the collaboration agreement and failed to carry

out their contractual obligations and it further a rose on non-

commencement of construction activities by the respondent

company within the stipulated time period. The cause of action

further arose on ______ when the petitioner No. 1 gave a legal

notice to the respondent and it further arose when the officials/agents

of the respondent threatened the petitioner no. 1 company, its

directors and petitioners 2 and 3 that they would not allow any

construction activity at the site which is in possession of the

petitioners.

CLAIM

10. That the petitioners respectfully submit that on

the present valuation, the petitioner No. 1, M/s ______ would at least have

claim of Rs. ______/- (Rupees ______ only) against the respondent

company and the said claim may also go up in future and therefore without

prejudice to its rights accruing in future, the petitioner would be filing

appropriate statement of claim before the learned Sole Arbitrator who shall

be deciding the disputes between the parties.

ARBITRATION CLAUSE

11. That clause ___ of the Collaboration Agreement

clearly sets out the arbitration clause in respect of Collaboration

Agreement.

COURT FEES

12. The petitioners are paying requisite court fees on this

application.

NON FILING PARA

13. That the petitioners have not filed any other or similar

petitions before this Hon’ble Court or in the Hon’ble Supreme Court of

India.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court may kindly

be pleased to:-

(a) Restrain the respondent company, its directors namely Shri

______and Shri ______ or their agents/employees or any one acting

for and on their behalf from taking forcible possession of the project

land ( admeasuring ______ sq yards comprising of ______ sq yards

(+) ___sq. yds. and ____ sq. yds. of the petitioners falling in Khasra

No. _____,_____,____,____ bearing Khatoni No.____, ____, _____

and ____ of the revenue estate of Village ____________________,

and further restrain the respondent, its directors/agents/servants or

any one acting for and on behalf of the respondent company from
 creating any hindrance or disrupting, disturbing, threatening to

obstruct construction activities by the petitioners themselves or

through a third party under a fresh collaboration agreement to be

carried on the project land comprising _________ sq.yds. situated in

Revenue Estate of Village _________, which is in possession of the

petitioners.

(b) Pass any other or further order(s) as this Hon’ble Court may deem fit

and proper in the given facts and circumstances of the case in the

interest of justice.

Prayed accordingly.

Affidavit is filed in support.

PETITIONER

THROUGH

( )
ADVOCATE
ENROLLMENT NO………
ADDRESS:………………
EMAIL:…………………
MOB. NO………………

Place :_____
Signed on: ___________
Filed on :