suit for permanent injunction
IN THE COURT OF SENIOR CIVIL JUDGE
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PLAINTIFF.
VERSUS
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DISTRICT-------------------------------------------------------------------------------------------------------------
DEFENDANT
SUIT FOR PERMANENT INJUNCTION:
It is respectfully submitted as under:.
1. That the plaintiff is an owner -in-possession of a house situated at---------------------------------------
The copy of the ownership document is attached with this suit.
2. That the plaintiff is entitled to a right of way from and to the said house for himself, his family members, relatives and servants etc and similar is the right of plaintiff for his vehicle at all times of the year on the field belonging to the Defendant which is adjacent to the house of the plaintiff .
3 . On 13th day of October,2006 the defendant wrongfully obstructed(block up) the said way by building wire-enclosure thereon and refused to permit the plaintiff to proceed to his house by passing over the said field.
4. That the plaintiff has been continuously enjoying the said right for more than 20 years past without any obstruction from the past without any obstruction from the defendant, therefore, the plaintiff has acquired a full right of easement of passing over the field.
5. That the said act of the defendant is wrongful, without any lawful authority and illegal .
6. That the case of action arose against the defendant on 13th October 2006, when the defendant flatly refused to let the plaintiff passing over the disputed field.
7. That since the plaintiff and defendant reside at ---------------------and violation of easement right of the plaintiff has occurred in------------------------and disputed field is situated in Lahore, therefore civil Courts of --------------------have the jurisdiction to try this suit
8. That the valuation of the suit for the purposes of court fee and jurisdiction is Rs. 4000/- therefore no Court fee has to be affixed on plaint
In view of the above it is respectfully prayed as under:.
Prayers
a) A decree may kindly be passed in favour of the plaintiff and against the defendant restraining the defendant from obstructing the plaintiff, his family members etc and also his vehicles from passing over the said field of and from the plaintiff's house and all times of the year.
b) The plaintiff may also be ordered through this decree to remove the wire from the disputed fields.
c) Heavy costs may also be awarded to the plaintiff.
d) Any other relief deemed possible by this Hon'ble Court may also be granted to plaintiff.
PLAINTIFF...
Through Counsel,
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VERIFICATION:
Verified on Oath at--------------------------------on this 20th day of October 2006 that the paras 1 to 5 are correct and remaining paras 6 to 8 are true according to my belief and knowledge.
plaintiff
COMMENTS