Suit for a permanent injunction. How to restrain a wrongdoer from his illegal acts through civil court by obtaining an injunctive order. The sample is given below, do the necessary changing as per the facts of the case.

Suit for a permanent injunction

 Purpose: To seek remedy against wrongdoers through the civil court in order to restrain the defendant/wrongdoer from his illegal acts that prejudice the civil rights of the plaintiff.

IN THE COURT OF SENIOR CIVIL JUDGE, GUJRANWALA

In the matter of:

(Name, parentage, and address of the plaintiff/s)        …..Plaintiff

Versus

(Name, parentage, and address of the defendant/s)   …. Defendants

SUIT FOR PERMANENT INJUNCTION

Respectfully Sheweth:-

That the plaintiff is an old age lady who along with her other family members is an owner in possession of land measuring 4K-4M bearing Khewat No. 00, Khasra No. 000 situated in the Revenue Estate of Matha, Tehsil & District Gujranwala. (Hereinafter referred as to suit property)        

That the suit property is inherited property of the plaintiff and the plaintiff is enjoying the peaceful possession of the suit land for long without any interference from any corner or side.   

That the suit property is a valuable property which is located on the main road of an industrial area and its price is increasing day by day. The defendants have no concern with the suit property in any manner whatsoever with the suit property and possession of the plaintiff because the plaintiff is an exclusive owner in possession of the suit property through the inheritance of her deceased parents but the defendants are greedy persons with malafide intention and ulterior motives started interference into the peaceful and lawful possession of the plaintiff over the suit property without any title or interest illegally, unlawfully and without any cogent reason and justification just in order to grab the valuable property of the plaintiff.

That the act of the defendants is totally illegal, unlawful, and against the genuine rights of the plaintiff, and if the defendants are not restrained from their illegal acts and designs, then the plaintiff shall suffer an irreparable loss.  

That the plaintiff time and again asked the defendants to refrain from their illegal designs and acts but the defendants flatly refused to accede to the genuine request of the plaintiffs, hence this suit.

That the cause of action accrued to the plaintiff before a week ago when the defendants started interference into the peaceful possession of the plaintiff over the suit property illegally and forcibly and lastly yesterday when the defendants refused to accede to the genuine request of the plaintiffs and the same is continuing day by day.

That the cause of action accrued to the plaintiff within the territorial limits of this Hon’ble Court, hence this Hon’ble court has jurisdiction to try and adjudicate upon the matter.

That the value of the suit for the purposes of court fee and jurisdiction is fixed Rs.00,000/- which is exempted from the levy of court fee.

PRAYER:

 In view of the above circumstances, it is, most respectfully prayed that a decree for permanent injunction restraining the defendants from interfering in the peaceful possession of the plaintiff over the suit property or encroaching, dispossessing the plaintiff, and raising any sort of construction upon the suit property and also from any kind of hindrance into the peaceful possession of the plaintiff over the suit property forcibly, illegally, unlawfully in any manner whatsoever may kindly be passed in favor of the plaintiff and against the defendants with costs.

Any other relief which this Hon’ble court deems just and proper may also be awarded.

Plaintiff                  Through                 Counsel

 

Verification:-

Verified on Oath at the {name of city} on 00.10.00 that the contents of para No. 1 to 6 are true and correct to the best of my knowledge and belief and whereas para No. 7 to 9 are believed to be true.

…. Plaintiff

Note:

1.       To attach an application U/o 39 Rule 1 & 2 CPC along with an affidavit

2.       To attach the title documents.