📝 Suit for Permanent Injunction
(Under Section 38 of the Specific Relief Act, 1963)
IN THE COURT OF THE CIVIL JUDGE / SENIOR CIVIL JUDGE
At: ____________
SUIT FOR PERMANENT INJUNCTION
IN THE MATTER OF:
Plaintiff: [Full Name]
S/o or D/o or W/o: ____________
R/o: [Full Residential Address]
VERSUS
Defendant: [Full Name]
S/o or D/o or W/o: ____________
R/o: [Full Residential Address]
MOST RESPECTFULLY SHOWETH:
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That the plaintiff is the absolute and lawful owner and in peaceful possession of property bearing no. ____________, situated at ____________ (hereinafter referred to as “the suit property”).
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That the defendant, without any right, title or interest, is attempting to forcibly enter/trespass into the said property and disturb the peaceful possession of the plaintiff.
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That the defendant has no legal authority or justification to interfere in the plaintiff’s possession.
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That the plaintiff apprehends that the defendant may cause irreparable harm and injury to the property and peaceful possession of the plaintiff.
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That the cause of action arose on ___ when the defendant tried to encroach upon the property, and it still continues.
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That the jurisdiction of this Hon’ble Court is proper, and the present suit is within limitation.
PRAYER:
In view of the above, it is most respectfully prayed that this Hon’ble Court may kindly be pleased to:
a) Pass a decree of permanent injunction in favour of the plaintiff and against the defendant, restraining the defendant, his agents, employees, representatives, etc. from interfering in any manner with the peaceful possession of the plaintiff over the suit property;
b) Award cost of the suit;
c) Pass such other and further reliefs as deemed just and proper in the facts and circumstances of the case.
Plaintiff
(Through Counsel)
[Advocate’s Name]
[Enrollment No.]
[Office Address]
[Contact No. & Email]
📌 Annexures:
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Title Deed / Ownership Proof
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Site Plan (if available)
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Photos (if needed)
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Complaint/Police Report (if filed)
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