In the court of Hon’ble Civil Judge, Senior Division, ____.
_________ Versus __________
Suit for Declaration with a Consequential Relief Permanent Injunction
APPLICATION UNDER ORDER __ RULE __ C.P.C. READ WITH SECTION ___ CPC PRAYING FOR GRANT OF EXPARTE AD-INTERIM INJUCTIVE ORDER.
Respectfully showeth:
1- That the applicant/plaintiff has this day instituted the above captioned case before this Hon’ble court, the contents of which may kindly be read as part and parcel of this application for the sake of brevity and avoidance of repetition.
2- That succinctly stated that the applicant has very good prim-facie case to succeed, balance of convenience heavily tilts in his favour, and plaintiff will suffer irreparable loss and incalculable injury if the stay sought for is not granted.
3- That on the basis of the false, illegal, and unlawful the judgement and decree dated ____ defendant/respondent wants to dispossess the applicant/plaintiff from the suit land which is mentioned in Para No.1 of the plaint illegally, forcibly and wants to take the possession of the suit land from the applicant/plaintiff illegally, forcibly and unlawfully for which the defendant has no right title and interest to do so. In case respondents/defendant will succeed in her illegal motives in that event the applicant/plaintiff shall only suffer an irreparable loss and incalculable injuries
PRAYER:
It is, therefore, prayed that an ex-parte ad interim injunction order restraining the defendant/respondent from dispossessing the applicant/plaintiff from the suit land and from interfering into the peaceful possession of the applicant/plaintiff over the suit and also from taking the forcible possession of the suit land from the plaintiff which is mentioned in Para No.1 of the plain, forcibly illegally and in any coercive manner whatsoever may kindly be passed in favour of the applicant/plaintiff and against the respondent/defendant till the final decision of the suit.
Dated Applicant/Plaintiff
Through counsel
_____ Advocate, ____.
