IN THE HON’BLE COURT OF LD.

VACATION JUDGE,
SAKET DISTRICT COURT, DELHI.
CIVIL SUIT NO. Of 2018

IN THE MATTER OF:-

XXXXXXXXXXXXXXXXXX PVT. LTD. …..PLAINTIFF

VERSUS

XXXXXXXXX & ORS. …..DEFENDANTS

APPLICATION UNDER ORDER 39 RULE 1 & 2 R/W SECTION 94

AND SECTION 151 CPC ON BEHALF OF PLAINTIFF FOR EX
PARTE AD INTERIM STAY ON THE DEFENDANTS THEREBY
RESTRAINING THEM TO ROAM AROUND AND ENTER INTO THE
SUIT PROPERTY BEYOND 500 METRES DURING THE
PENDENCY OF THIS SUIT.

MOST RESPECTFULLY SHOWETH:-

1. The Applicant/Plaintiff has filed the accompanying suit

seeking, inter alia, restraining the Defendants from
entering into the suit property and sitting on dharna,
sleeping, cooking food, playing cards, consuming liquor
and damaging the property. The contents of the plaint
may be read as the part and parcel of the present
application for better clarity upon the subject matter.

2. That the Plaintiff for the sake of brevity seeks to rely on

the facts and circumstances of the suit challenging the
apprehended illegal activities of the Defendants.

3. That the Defendants herein are planning to illegally

trespass into the suit premises and damaging the life &
 property besides blocking the entry of the Plaintiff and
their officials into the suit premises.

4. That as stated in detail in the plaint the defendants are

in the process and preparation of the illegal activities in
all types of coercive manner including the threatening to
workmen of the plaintiff, thereby which may disrupt the
entire functioning of the plaintiff.

5. It is, therefore, prayed that this Ld. Court may kindly be

pleased to stay the entry of the Defendants in and
around the suit property during the pendency of this suit,
as otherwise the suit would be rendered infructuous and
would cause grave irreparable loss and injury to the
Plaintiff.

6. The instant application is made bonafide and in the

interest of justice. No prejudice would be caused to the
Defendants if the instant application is allowed. The
Applicant/Plaintiff has a prima facie case, the balance of
convenience heavily lies in favour of the
Applicant/Plaintiff and non-grant of the reliefs prayed for
in the application would cause irreparable loss and injury
to the Applicant/Plaintiff. The Applicant has no other
equally efficacious or alternate remedy available to it.

PRAYER

In view of the above it is prayed in the interest of justice that

this Hon’ble Court may kindly be pleased to:

a) grant ex parte ad interim stay thereby restraining the

defendants & their associates/aides to roam and enter
 into the suit property restraining them/their
accomplices to trespass the suit properties situated at:

i. Plot No. 43, Block AXXXXXXXXXXXXXXXX.

ii. XXXXXXXXXXXXXXXXX 44.

iii. XXXXXXXXXXXXXXX, New Delhi -110044.

iv. XXXXXXXXXXXXXXXXXXXXXXXX Delhi, 110044.

b) restraining Defendants & their associates, agents or

accomplices to enter into the suit property, hold
dharna, sitting there, squatting, consuming liquor,
creating obstruction in entry/exit, nuisance,
disturbance, etc. therein, not to roam around or near
the entry/exit of the suit property and within 500
metres of the suit property;

Any other and further order that may deem fit and proper in
this context may also kindly be passed in favour of Plaintiff.
[PLAINTIFF]

THROUGH
ADVOCATE

Place: NEW DELHI

Dated: XXXXXXXXXXX