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SUIT FOR PERMANENT INJUNCTION
IN THE COURT OF SENIOR CIVIL JUDGE (DISTRICT ___________),
SUIT NO. ____________ OF 20..
IN THE MATTER OF:
Sh. Om Veer Singh S/o. ___________-, R/o. Sainik Nagar, New Delhi
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
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. 150/- (Rs. 150/-) p.m. excluding electricity and water charges under the tenancy of late Sh_________ who died on 17.10.2013 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.
6. That the plaintiff has paid the agreed rent @ Rs. 150/- p.m. to late Sh. ______upto Oct. 2013. It is also pertinent to mention hare that the legal hairs 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 dt. 30.1.2015 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 disclosethe 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 defendents 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 Matiala 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 Matiala 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 Matiala.
9. That on 10.2.2015, the plaintiff sent a Registered Notice to the defendant no. 1 and copy to Chowki Incharge Police Post Matiala by Regd. A.D. (copy of the same is enclosed herewith) but P.P. Matiala staff has not taken any action against the defendants for reasons best known to them.
10. That on 11.2.2015, 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 de. 12.2.2015, the plaintiff again went to the police post Matiala to lodge the report against the defendants but no Police Officer of P. Post Matiala 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 P.S. Matiala.
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 dt. 11.2.2015 when the defendants again threatened and tried to dispossess the plaintiff from 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. That the parties to the suit for the purpose (s) of court fee and jurisdiction is Rs. 130/- on which the requisite court fee has affixed.
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 :-
pass the decree for Permanent Injunctin in favor 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. award cost of the suit in favour of the Plaintiff and against the Defendants; 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
Through
Advocate
(b)
(c)
Place:
Date:
VERIFICATION:
Verified at Delhi on this 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.
Plaintiff
[NOTE : This plaint has to be supported by an affidavit]
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