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Application for Temporary Injunction

IN THE MATTER OF:

[[Name of the Plaintiff]] S/O or D/O or W/o [[Name of the Father/Husband/Guardian]],

aged about . . . . years,

R/O [[Complete address of the Plaintiff]].

Mobile: [[Mobile No. of the Plaintiff]].

. . . Plaintiff

Versus

  1. [[Name of the Defendant/Respondent]] S/O or D/O or W/o [[Name of the Father/Husband/Guardian]],

aged about . . . . years,

R/O [[Complete address of the Defendant/Respondent]].

Mobile: [[Mobile No. of the Defendant/Respondent]].

2. [[Name of the Defendant/Respondent]] S/O or D/O or W/o [[Name of the Father/Husband/Guardian]],

aged about . . . . years,

R/O [[Complete address of the Defendant/Respondent]].

Mobile: [[Mobile No. of the Defendant/Respondent]].

. . . Defendants

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 case the defendants are not restrained by means of ad-interim injunction for dispossessing the plaintiff from the above said premises no. _________ Uttam Nagar, New Delhi and from interfering in physical peaceful possession of the above said premises, the plaintiff shall suffer irrepairable 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:

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

  1. 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 plaintiff in the above said premises and from dispossessing the applicant/plaintiff from the same.
  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.

Date: [[mention the date of filing]]

Place: [[Name of the Place]]

[Signature of the Plaintiff]

[Name of the Plaintiff]

Through

[[Signature of the Advocate]]

[[Name of the Advocate]]

[[Name of the Law Firm: LawDocs Associates]]

[[Address, e-mail & mobile no. of the Advocate]]

 

VERIFICATION

Verified at [[Place]] on this [[Date:1st day of January 20…]] that the contents of paras 1 to … of the plaint are true to my knowledge derived from the records of the Plaintiff maintained in the ordinary course of its business, those of paras …. to …. are true on information received and believed to be true and last para is the humble prayer to this Hon’ble Court.

[[Signature of the Plaintiff]]

[[Name of the Plaintiff]]

[NOTE : This Application has to be supported by an affidavit].

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