Suit for Permanent Injunction (1)

In the Court of............................
Suit No. l......................... of 200

In the Matter of: -
AB............................................................................................................................ Plaintiff
versus
CD............................................................................................................................ Defendant
SUIT FOR PERMANENT INJUNCTION
Respectfully Showeth:
1. That the plaintiff has been residing at House No............................. ............................ as a
tenant for the last about nine years with his mother, wife and children.
2. That upto the year............................ the plaintiff had been living in a Tinshed constructed
by him in the premises of House No.............................
3. That the plaintiff in............................ constructed thereon pucca room and kitchen at his
own cost. Some of the receipts available pertaining to the material purchased by the plaintiff
for construction of a room and kitchen are annexed hereto and collectively marked as
Annexure-A-1.
4. That the plaintiff is a poor person and bread earner for three minor children apart from his
wife and mother and for earning his livelihood is running a small Dhabba outside the said
house.
5. That the plaintiff had been paying Rs............................. per month as rent
regularly to Defendant No. 1 in cash. However, no receipt is being issued by defendant No. 1
towards payment of the said rent.
6. That defendant Nos. 2 and 3 the sons of defendant No. 1 have been giving threats to the
plaintiff either to vacate the premises or face dire consequences.
7. That on............................ Defendant No. 1 alongwith his associates entered the room of
plaintiff using filthy and abusive language and started beating the plaintiff.
8. That the plaintiff reported the matter to the Incharge Police Station, ............................ and
lodged FIR on............................. However no protection was afforded to the plaintiff by the
police.
9. That the plaintiff is a law abiding citizen and has rehabilitated himself in the petty business
at his own, whereas the defendant Nos. 2 and 3 are influential people who believe in taking
the law in their own hands and also believe on using muscle power.
10. That defendants are bent upon grabbing the room and kitchen by forcible eviction of the
plaintiff and his family through use of their might and money.
11. That the acts of the defendants are unlawful, arbitrary, unwarranted and against all
cannons of justice and they are liable to be restrained by passing a decree of permanent
injunction under Section 30 of the Specific Relief Act which remedy is only efficacious in the
circumstances of the case.
12. That the cause of action first accrued to the plaintiff against the defendants in
the........................................................ entered the room of the plaintiff using abusive
language and started beating him. The cause of action again arose on ............................ in
favour of the plaintiff when the defendants 2 and 3 with their muscelmen locked the plaintiffs
residence from outside. The cause of action for filing the present suit is still subsisting and
will continue to subsist in favour of the plaintiff till the defendants are ‘restrained by a decree
of this Hon’ble Court as prayed.
13. That the parties reside in Delhi and the suit property is also situated in Delhi, this Hon’ble
Court therefore has jurisdiction to entertain and try the suit.
14. That the value of the suit for purposes of jurisdiction and court fee is assessed at Rs. 130/-
for which the requisite court fee for the relief of permanent injunction has been affixed/paid
on the plaint.
PRAYER
It is, therefore most respectfully prayed that this Hon’ble Court may be pleased to grant a
decree of permanent injunction in favour of plaintiff and against the defendants permanently
restraining the defendant Nos. 1 to 3, their agents, servants, relatives etc. interfering with the
peaceful possession, occupation, enjoyment and use of the premises House
No......................................................... by the plaintiff without following the process of law.
(3) Such other relief which this Hon’ble Court may in the circumstances of the case, be
pleased to grant may also be granted.
Plaintiff
Through Advocate
VERIFICATION
Verified at............................ on this the............................ day of ............................ that the
contents of paras No............................. of the plaint are true to my knowledge and belief,
whereas, those of paras No............................. are believed to be true on legal advice received
through the counsel. Last para is prayer to this Hon’ble Court.
Plaintiff.

Suit for Permanent Injunction (1)

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In the Court of............................

Suit No. l......................... of 200

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