Note: This Legal Draft is merely illustrative and not exhaustive; it shall only be used in consultation with a lawyer and with due edits to meet the ends of the user.

IN THE COURT OF SENIOR CIVIL JUDGE (DISTRICT ________), DELHI
IA No. _________ of 20__ in
Suit No. _________ of 20__

IN THE MATTER OF:
Sh. Aman Kumar, S/o Sh. _________,
R/o House No. _____, Sector ____, Dwarka, New Delhi.

…PLAINTIFF/APPLICANT

VERSUS

1. Dr. Ravi Sharma, S/o Sh. _________,
   R/o House No. _____, Janakpuri, New Delhi.
2. Sh. Neeraj Gupta, S/o Sh. _________,
   R/o House No. _____, Tilak Nagar, New Delhi.  

…DEFENDANTS/RESPONDENTS

APPLICATION UNDER ORDER XXXIX, RULES 1 & 2 READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908, SEEKING TEMPORARY INJUNCTION

MOST RESPECTFULLY SHOWETH:

1. That the plaintiff has instituted a suit for permanent injunction against the defendants, which is presently pending adjudication before this Hon’ble Court.

2. That the contents of the accompanying plaint in the suit for permanent injunction are reiterated herein and may kindly be read as part and parcel of this application for the sake of brevity.

3. That the plaintiff is in lawful and peaceful possession of the premises bearing No. _____________, Sector ____, Dwarka, New Delhi (hereinafter referred to as “the suit property”). The plaintiff has been residing/operating in the suit property without any interference until recently when the defendants, in connivance with certain individuals, have attempted to illegally dispossess the plaintiff and interfere in his peaceful possession.

4. That the plaintiff has a prima facie case in his favor, as evidenced by documentary and circumstantial evidence, including but not limited to ownership/tenancy agreements, utility bills, and witnesses to his continuous occupation of the suit property.

5. That if the defendants are not restrained by way of an ad-interim injunction, there is a grave and imminent threat that the plaintiff will be dispossessed unlawfully from the suit property. Such dispossession would cause irreparable harm and injury to the plaintiff, which cannot be adequately compensated in monetary terms, and would render the main suit infructuous.

6. That the balance of convenience is heavily tilted in favor of the plaintiff, as the defendants stand to suffer no harm by being restrained from engaging in unlawful activities, while the plaintiff’s right to peaceful possession and enjoyment of the suit property is at stake.

7. That this application is made bona fide and in the interest of justice to prevent irreparable harm and to protect the plaintiff’s rights in the suit property.

PRAYER:

In light of the aforementioned facts and circumstances, it is most respectfully prayed that this Hon’ble Court may graciously be pleased to:

a) Pass an ex-parte ad-interim injunction restraining the defendants, their agents, servants, employees, associates, or any other persons acting on their behalf, from interfering in the peaceful possession of the plaintiff over the suit property bearing No. _____________, Sector ____, Dwarka, New Delhi, and from dispossessing the plaintiff therefrom during the pendency of the suit;

b) Pass such other and further orders as may be deemed fit and proper in the facts and circumstances of this case in the interest of justice and equity.

Place: New Delhi
Date: _______

PLAINTIFF/APPLICANT

Through
__________, Advocate
(Address of Advocate)

[NOTE: This application must be accompanied by a duly sworn affidavit in support of the facts stated above.]