Table of Contents
APPLICATION UNDER ORDER 39, RULES 1 AND 2 AND SECTION 151 C. P. C.
APPLICATION UNDER ORDER 39, RULES 1 AND 2 AND SECTION 151 C. P. C.
Draft
APPLICATION UNDER ORDER 39, RULES 1 AND 2 AND SECTION 151 C. P. C.
IN THE COURT OF………………..
……………….. Suit No………………… of 19………………..
C. D…………………………………………………………. Plaintiff
versus
C. F……………………………………………………….. Defendant
Sir,
The plaintiff respectfully submits as follows: —
1. That the plaintiff has filed the above noted suit for possession against the defendant. The contents of the plaint may be read as part of this application.
2. That the defendant had allowed some persons to inspect the premises in dispute on………………. and on enquiry from these persons who did not disclose their identity to the plaintiff it transpired that the defendant was adamant to let out the premises on higher rent.
3. That the plaintiff is the tenant in the disputed premises and the possession of the defendant in the disputed premises is illegal and unauthorised and as such the defendant has no right to let out the same to any other person or part with possession of the disputed premises.
4. That the plaintiff has a good prima facie case and the plaintiff is sure to succeed.
5. That the balance of convenience is in favour of the plaintiff that the status quo may be ordered to be maintained during the pendency of the suit.
6. That the plaintiff will suffer irreparable loss and injury in case the defendant succeeds in her illegal design.
7. That under these circumstances, it is, therefore, prayed that an ex pane ad-interim injunction may be granted in favour of the plaintiff restraining the defendant from letting or parting with possession of the disputed premises shown in blue colour in the annexed plan with the plaint forming part of property No. ……………….. till the disposal of the suit. Any other relief that this Hon’ble Court deems fit may also be granted to the plaintiff.
Plaintiff
