SUIT FOR PERMANENT INJUNCTION

                                                                        IN THE COURT OF SENIOR CIVIL JUDGE (DISTRICT _____), DELHI

                                                                                                      SUIT NO. ____ OF 20..

IN THE MATTER OF:

Sh. Om Veer Singh

S/o. _____-,

R/o. Sainik Nagar, New Delhi .… PLAINTIFF

VERSUS

1. Dr. U. Basu

S/o____,

R/o Pragati Vihar Society, Delhi - 92

2. Tapan Kumar,

S/o __

R/o Pragati Vihar Society, Delhi – 92 ….. DEFENDANTS

SUIT FOR PERMANENT INJUNCTION

MOST RESPECTFULLY SHOWETH:

1. That the plaintiff is the permanent resident of the above mentioned address in

property bearing no. ____ Uttam Nagar, New Delhi for the last many year and is living

with wife and minor children, as a tenant.

2. That the plaintiff is a tenant in respect of the above said property bearing

no_______Uttam Nagar, New Delhi consisting two rooms, latrine and kitchen in the

above said premises of Rent Rs. …….per month excluding electricity and water charges

under the tenancy of late Sh____ who died on ……..(date) and late Sh. __ used to

collect the rent from the plaintiff but late Sh. ___did not issued any rent receipt to the

plaintiff even after several demands made by the plaintiff but he always used to postpone the

issue of rent receipt.

3. That the plaintiff spent a huge amount on the construction of these two rooms in the

above said premises at the request of Late Sh. __and Sh. ____assured the plaintiff to

adjust the said rent (the plaintiff is having the necessary documents/proofs of material for

construction of rooms in the above said property). It is also pertinent to mention here that the

plaintiff looked after late Sh. __ many a times, whenever he fell ill.

4. That at present the plaintiff is having the peaceful possassion of premises no.

______Uttam Nagar, New Delhi and is having the whole necessary documents/record

regarding possession (photocopy of Ration Card, School Card is enclosed herewith) but the

above said defendants are internded to disturbe the peaceful physical possession of the

plaintiff of the above said premises.

5. That the plaintiff is having the whole necessary household goods which are

lying/kept in the above said premises and is living peacefully.

15

6. That the plaintiff has paid the agreed rent @ Rs. …… per month to late Sh.

___upto …... It is also pertinent to mention hare that the legal heirs of late Sh. ___are

not in the knowledge of the plaintiff and at present also the plaintiff is ready to tender the rent

before the legal heirs of late Sh. ___.

7. That on ……..(date) the above said defendant came to the above said premises of the

plaintiff and threatened the plaintiff to vacate the tenanted premises immediately otherwise

the plaintiff would have to face dire consequences, when the plaintiff asked about their

identity then they did not disclose the same, instead started throwing household goods

forcibly and illegally and started to quarrel with the plaintiff when the local

residents/neighbourers intervened in the matter then the defendants left the spot after

threatening for dire consequences and to dispossess the plaintiff forcibly and illegally in the

near future with the help of local goondas. The defendants openly stated that the staff of

police post ………dances at their tune and it is very easy job for them to dispossess any

person or to grab the property of any one with the help of the police staff.

8. That immediately on the same date the plaintiff rushed to the police post …….to

lodge his report against the defendants regarding such incident but duty officer did not lodge

the report of the plaintiff. The plaintiff was surprised to see that both the defendants were

already present at the Police Post …….

9. That on ………(date) , the plaintiff sent a notice to the defendant no. 1 and copy to

Chowki Incharge Police Post ……. by Regd. A.D. (copy of the same is enclosed herewith)

but Police Post ……… staff has not taken any action against the defendants for reasons best

known to them.

10. That on …….. (date), the defendants along with two unknown persons/ whom the

plaintiff can recognise by face, came to the above said premises bearing no. ___ Uttam

Nagar, and knocked at the door at odd hours and threatened the plaintiff to come out of the

room. The plaintiff saw their faces from gaps of the door and the plaintiff got nervous, and

therefore did not come out of two-room apartment. The said persons threatened the plaintiff

to vacate the premises immediately. However, then the neighbourers gathered there and they

restrained the defendants from dispossessing the plaintiff from the above said premises

forcibly and illegally. When the neighbourers threatened them, they left the spot with a threat

to come after one or two days with heavy force to dispossess the plaintiff from the above said

premises forcibly and illegally.

11. That on ……(date), the plaintiff again went to the police post ……. to lodge the report

against the defendants but no Police Officer of police post ……. is ready to listen against the

defendants and they advised the plaintiff to approach to the competent court of law to seek

his remedy and to get injunction order against the defendants and the police post ……..

12. That the plaintiff has no other efficatious remedy except to approach to this Hon'ble court

for seeking relief of injunction against the defendants from interfering in the peaceful

possession of the premises no. ____Uttam Nagar, New Delhi.

13. That the cause of action arose on different date when the defendants threatened the

plaintiff to vacate the premises no. ____Uttam Nagar, New Delhi and threatened the

plaintiff of dire consequences and further to dispossess him from the above premises bearing

no.____Uttam Nagar, New Delhi forcibly and illegally. The cause of action lastly

arose on ……. when the defendants again threatened and tried to dispossess the plaintiff from

16

the premises no. __ Uttam Nagar, New Delhi forcibly and illegally with the connivance

of the Local Police. The cause of action still subsists as the threat of the defendants to

dispossess the plaintiff and to create disturbance in the peaceful possession of the premises

no.___ Uttam Nagar, New Delhi continues.

14. The value of this suit for the purposes of court fee and jurisdiction is Rs. --------- on

which court fee of Rs. _____is paid.

15. This Hon’ble Court has jurisdiction to entertain this suit because the part of the cause of

action arose at Delhi and the suit property is situated within the territorial jurisdiction of this

Hon’ble Court.

PRAYER:

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

(a) pass the decree for Permanent Injunction in favour of the plaintiff and against the

defendants thereby restraining the defendants, their representatives, employees, agents etc.

from dispossessing the plaintiff forcibly and illegally from the tenanted premises bearing no.

___ Uttam Nagar, New Delhi and also from interfering in the peaceful possession of the

above said premises.

 (b) award cost of the suit in favour of the Plaintiff and against the Defendants;

 (c) pass such other and further order(s) as may be deemed fit and proper on the

 facts and in the circumstances of this case.

Plaintiff

Place: Through

Date: Advocate

VERIFICATION:

Verified at Delhi on this …..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.

 Plaintiff