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CIVIL PLEADING

IN THE COURT OF SENIOR CIVIL JUDGE


(Place……, District….., State……… (Delhi)

I.A. No………….Year…… 20…….


In
Suit No …………… Year …… 20…..

(APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER -


39, RULE- I & II OF THE CODE OF CIVIL PROCEDURE, 1908)
IN THE MATTER OF:

 Name ............ (Plantiff/Applicant), S/o,D/o,W/O ..........., Age ....... Year, R/o. .........
Village/ Mohalla .......... , Tehsil ..........., District ........

…….. (Plaintiff/Applicant)

Versus

 1. Name ............ (Defendant/Respondent), S/o,D/o,W/O ..........., Age ....... Year,


R/o. ......... Village/ Mohalla .......... , Tehsil ..........., District ........
 2. Name ............ (Defendant/Respondent), S/o,D/o,W/O ..........., Age ....... Year,
R/o. ......... Village/ Mohalla .......... , Tehsil ..........., District ........

…….. (Defendants/Respondents)
(APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER -
39, RULE- I & II 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 case the defendants are not restrained by
means of ad-interim injunction for dispossessing the
plaintiff from the above said premises no. ……….. Village/
Mohalla .......... , Tehsil ..........., District ........ and from
interfering in physical peaceful possession of the above
said premises, the plaintiff shall suffer irreparable loss and
injury and the suit shall become anfractuous and would
lead to multiplicity of the cases.
 (5.) That the balance of convenience lies in favour
of the plaintiff and against the defendants.
PRAYER/RELIEF:

 It is, therefore most respectfully prayed that this Hon’ble


Court may be pleased to :-
 (i) Pass ex-parte ad interim injunction restraining the
defendants, their associates, servants, agents and their
representatives from interfering into the peaceful physical
possession of the applicant/plaintiff in the above said
premises and from dispossessing the applicant/plaintiff
from the same.
 (ii) award cost of the suit in favour of the Plaintiff and against
the Defendants;

 (iii) pass such other and further order(s) as may be deemed


fit and proper on the facts and in the circumstances of this
case.
 Signature … (Applicant/Plaintiff)
 Place……. (Through)
 Date……..
 Signature … (Advocate)
VERIFICATION:

 Verified at ………. (place)… on this ……. (day)……….(month) ………


(year) 20… that the contents of paras 1 to .. of the suit are true to
my personal knowledge derived from the records of the Plaintiff
maintained in the ordinary course of its business, there is nothing
lies and last para is the humble prayer to this Hon’ble Court.

Signature … (Plaintiff/Applicant)

 Note*** (An affidavit, duly attested by oath commissioner, in support


of this application is to attached with to this application.)
Thank You

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