IN THE HIGH COURT OF THE………………..
C. M. No………………… of 19………………..
in
C. W. No………………. of 19……………….
A. B………………………………………………………. Petitioner
versus
C. F…………………………………………………… Respondent.
Respectfully Showeth:
1. That the applicant/petitioner has today filed the accompanying writ petition against the respondent action of forcible dispossession of the petitioner’s from his land (built up land) in………………. No………………… the detailed averments and allegations of which may not be repeated herein for the sake of brevity craving leave of this Hon’ble Court to refer to the same for decision of this application.
2. That the Collector did not take possession of the said land from the petitioner and did not pass on the same to the respondent authority and the petitioner is in the continue possession yet the respondent insists on taking forcible possession and to demolish the petitioner structure.
3. The balance of convenience is in favour of the petitioner, he being in possession of the land in question. Ever since his father built it up.
4. That the respondent — Authority having lost even the prosecution proceedings in a criminal Court is bent on taking the law in its own hand and of justice demand that ad-interim stay even without hearing the respondent authority merits to be granted in favour of the petitioner to protect his possession or else he will suffer irreparable loss at the hands of the respondent authority which is not likely to be made good in terms of money.
It is submitted that the respondent is not in any way prejudiced by the grant of stay prayed for because the petitioner in his possession.
It is therefore, most respectfully prayed that this Hon’ble Court be pleased to grant an ad-interim stay against dispossession and demolition till the decision of the writ petition.
Petitioner
Through Advocate.