Suit For Permanent Injuction
IN THE COURT OF SH._____________.
_________ Versus _____________
SUIT FOR PERMANENT INJUCTION
I, __________ son of Sh. ___________, R/o _______________, do hereby solemnly affirm and declare as under:
1 That the deponent along with his ___________ son of Sh. ____________ purchased a site consisting of a house and a shop situated at _____________ formerly ________, forming part of __________- measuring ___ Sq. yards admeasuring __ x __ show in ___ colour in the site attached with the plaint from ___________ S/o Sh. __________________ vide registered sale deed dated _________. The Photo Copy the sale Deed is EX-P-1. The said shop is bounded as under :-
North - ____________
South - ____________
East - ____________
West - ____________
2- That the afore-said _____________ had purchased the above mentioned site from ____________ of _____________ vide registered sale Deed dated _______________ in which ____ room _____ and _____ were existing. Water and electricity connections were also therein the site. The photocopy of sale Deed dated ______ is EXP-2.
3- That at the time of purchase of the said site by the deponent and his ______ from _________ aforesaid , _____ room ______ ,______ and ______ were there at the site and the electric and water connections were also there. The property in question is subject to house tax by the defendants and the same is being paid by the deponent from time to time.
4- That the construction mentioned in Para No.2 above is existing at the site for the last more than __ years as is evident from the Photocopy of the conveyance Deed attached with the plaint. The photocopy of the House Tax receipt is EXP-3 and the copy of the site plan is EXP-4.
5- That the defendants illegally and unlawfully issued show cause notice dated __________ under Section ___ of the _____________ Act and order of demolition dated ___________ in the name off Shri ____ father of the deponent on receipt of which the deponent visited the office of the defendants and apprised them that the construction regarding which notices has been issued by the defendants was an old one having been raised in the premises in question for the last more than __ years and documents in the support there of were also shown to them. On seeing the same they were satisfied and told that the deponent that no action thereon shall be taken by the defendants.
6- That the defendants through their employees now on __________ came to the suit premises and tried to demolish the construction rose thereon illegally and unlawfully. However, their attempt to do so was failed with the help of the respectables of the area. They left the spot but held out threats to demolish the same. The deponent apprehends that in case they succeed in their illegal designs, in that event he would suffer irreparable loss and injury. This is the final date of cause of action and hence this suit.
Verified that the contents of my above affidavit are true to best of my knowledge and belief and nothing concealed therein.
Verified at __________ on _________