APPLICATION UNDER ORDER 39 RULES 1 AND 2 READ WITH SECTION 151 CIVIL PROCEDURE CODE.

MOST RESPECTFULLY SHEWETH:

1.            That the applicant/plaintiff has today filed the above noted Suit for Possession Damages and Mesne Profits and Permanent Injunction against the defendant and the same is pending adjudication before this Hon’ble court.

2.            That the plaintiff craves leave of this Hon’ble court to read and treat the contents of the plaint as part hereof, as the same are not being reproduced herein for the sake of brevity.

3.            That the plaintiff has got a very strong prima facie case in it’s favour and it’s suit most likely to be decreed.

4.            That the balance of convenience also lies on the side of the plaintiff and against the defendant.

5.            That in case, during pendency of the suit, the defendant is not restrained from transferring, alienating, parting with possession and creating third party interest in the suit property then the plaintiff shall suffer irreparable loss and injury, not measurable in terms of money.

P R A Y E R:

It is, therefore, respectfully prayed that this Hon’ble court may kindly be pleased to pass an exparte ad-interim injunction in favour of the plaintiff and against the defendant thereby restraining the defendant, his associates, attorneys, relatives etc. from transferring, alienating, parting with possession and creating third party interest in the suit property more specifically shown red in the site plan situated on First Floor at M/s Sss Club …, Delhi consisting of one room, during the pendency of the present suit.

Any other or further relief, which this Hon’ble court deems fit and proper, be granted in favour of the plaintiff and against the defendant.

Delhi

Dated:

PLAINTIFF

THROUGH

ADVOCATE

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IN THE COURT OF THE DISTRICT JUDGE: DELHI

M/s Sss Club …, Delhi                                            ……             PLAINTIFF

VERSUS

SHRI BBB                 ……         DEFENDANT

AFFIDAVIT

I, Mr.aaa, Secretary M/s Sss Club …, Delhi, do hereby solemnly affirm and declare as under:-

1.            That the deponent is the plaintiff in the above noted case and is well conversant with the fact of the same and competent to depose this affidavit.

2.            That the contents of the accompanying application Under Order 39 Rules 1&2 read with section 151 CPC has been drafted by the counsel under my instructions and same has been explained to me and I admit them as true and correct.  The contents of the same be read as part and parcel of this affidavit which are not repeated herein for the sake of brevity.

DEPONENT

VERIFICATION:

Verified at Delhi on this … day of ………2007 that the contents of above affidavit are true and correct to my knowledge and no part of it is false and nothing has been concealed therefrom.

DEPONENT

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Specimen of Suit Against Electricity Board against wrong Bills:

IN THE COURT OF SENIOR CIVIL JUDGE: TIS HAZARI: DELHI

CIVIL SUIT NO. ……….. OF 2010

IN THE MATTER OF:

SHRI AAA

R/o …. Delhi-55.                                                                  ……        PLAINTIFF

VERSUS

1.         B.S.E.S. YAMUNA POWER LIMITED.

            Through its BUSINESS MANAGER,

            Div. Paharganj, Gandhi Market,

New Delhi-110055.

2.         B.S.E.S. YAMUNA POWER LIMITED

Through its C.E.O.

Shakti Kiran Building,

Karkardooma, Delhi-110032.                                 ……DEFENDANTS