Injunction restraining nuisance

IN THE COURT…………

………………………..                                                …Plaintiff

Vs.

………………………                                                  … Defendant

MAY IT PLEASE YOUR HONOUR

Mr………………………….., the above-named plaintiff, states as follows :

1. The Plaintiff is, and at all the times hereinafter mentioned was, the absolute owner of [the House No. Street, Mumbai].

2. The defendant is, and at all the said times was, the absolute owner of [a plot of ground in the same street……………..].

3. On the ……………………. day of ………… 20…….. the defendant created upon his said plot a slaughter-house, and still maintains the same; and form that day until the present time has continually caused cattle to be brought and killed there [and has caused the blood and offal to be thrown into the street opposite the said house of the plaintiff].

4. In consequence the plaintiff has been compelled to abandon the said house, and has been unable to rent the same].

5. [Facts regarding cause of action arose and that Court has jurisdiction.]

6. The value of the subject-matter of the suit for the purpose of jurisdiction is

     ……………… rupees and for the purpose and the plaintiff as  paid  Rs………. as   

     court fees.

7. The plaintiff claims that the defendant be restrained by injunction from

     committing or permitting and further nuisance.