IN THE COURT OF DISTRICT JUDGE………………..
Suit No………………… of 19………………………………….
C. F…………………………………………………………. Plaintiff
versus
C. D……………………………………………………… Defendant
Respectfully showeth:
1. That the defendant No. 1 is the father and defendants No. 2 to 4 are his sons, who purportedly
constitutes H. U. F.
2. That the defendant No…….. is the owner of house No…… as per Sale Deed dated……… who rented a
shop therein to the plaintiff in…………. on a monthly rent of Rs……… The specification of the shop are
described in the plan attached hereto.
3. That the…………….. being situated adjoining to……………….. on………………has become an important
market for sale and storage of oils and lubricants.
4. That the plaintiff is ever since carrying his business of lubricants and Petroleum products in the said
shop and is a registered dealer.
5. That the plaintiff has been paying regularly the stipulated rent to defendant No…………….. normally by
cheques, the latest being No………………. for Rs……………………….. and No…………………… for
Rs………………………..
6. That the said defendant/landlord issued last receipt to the plaintiff in respect of rent
from………………………. and did not issue any for cash paid to him in lieu of cheque No……………………….
for Rs………………………..
7. that the accommodation in the oil market of…….. has become scarce, giving rise to rent and ‘Pagri’.
The defendant No……… has also not been able to resist this temptation and has become greedy. That is
why he is on a look out to oust the plaintiff from the said shop and as the plaintiff learnt, he has also not
presented the aforesaid cheques No……….. to the plaintiff’s banker for encashment. If he does so by
following the process prescribed by law, the plaintiff will be willing to face the consequences.
8. That the defendant No……………………….. appears to have decided to take the law in his own hand with
the assistance of defendant No……………………….. and to take possession of the premises forcibly from
the plaintiff.
9. That in the afternoon of……………………….. when the plaintiff had gone to a nearby shop, the
defendants with the help of a few labourers got the outer boundary wall and the entrance of the shop
demolished from its height of 6 feet, when the plaintiff rushed back on information and agitated they
proclaimed and threatened to have the shop vacated forcibly. The plaintiff lodged a report with the Police
Squad and with the arrival and intervention of the police forcibly eviction of the plaintiff was averted and
the defendants assured to restore and re-built the boundary wall and the gate to the same height of 6
feet, and width to ensure safety of the plaintiffs goods inside the open frontage. The local Police then
called the plaintiff to the Police Station and got his signautre on a writing allegedly a compromise.
Thereafter on……………………….. the plaintiff came to his shop in the evening and found that the
construction of the boundary had been raised only to 3-1/2 feet and the width of the gate reduced by 2
feet to prevent entry of light vehicles.

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10. That the plaintiff contacted the defendants to redeem their assurance, their tone was found to be
aggressive and hostile, which cause apprehension in the mind of the plaintiff that he is likely to be
deprived of his lawful possession of the premises any moment. The plaintiff approached the Local Police
for restoration of his boundary wall in the original height as his goods are not safe with the defendants
again promised to raise its height in due course, when they get a Mistri,
11. That on………………………. when the plaintiff went to handover the cheque No……………………….. for
Rs……………………….. for clearance of up-to-date rent, the defendants refused to take it and again
threatened to forcible eviction of the plaintiff from the shop.
12. That the plaintiff is a lawful occupant and tenant of the shop and is a law abiding citizen, whereas the
defendants are wealthy landlords, who believe in taking the law into their own hands by use of force and
muscle power and hence this suit.
13. That the cause of action has accrued to the plaintiff from the bundle of facts, acts and conduct of the
defendants mentioned in the para………………………. above.
14. That the tenanted premises is situated in……………………….. where the parties also reside and work
for gain. This Hon’ble Court has therefore, jurisdiction to entertain and try the suit.
15. That the value of the suit property is assessed at Rs……………………….. for which a court fees of
Rs……………………….. for the relief of permanent injunction and another Rs……………………….. for the relief
of mandatory injunction are affixed on the plaint.
PRAYER

It is, therefore, respectfully prayed that this Hon’ble Court may be pleased to grant a decree for
permanent injunction restraining the defendants from dispossessing the plaintiff otherwise than by
following the process of law, from the tenanted shop as per specification given in the site plan and from
interfering in the plaintiff’s peaceful use and enjoyment thereof.

(b) a decree for mandatory injunction directing the respondent No.
………………………. to restore and reconstruct the outer boundary wall and the entry
gate of the shop to its original height of………………………. feet’ from the present
of………………………. feet reduced and demolished by him and his men
on………………………. and to restore the original width of the entry gate
to………………………. feet.
(c) such other relief, which this Hon’ble Court may deem fit and proper may also be
granted to the plaintiff in the interest of justice.

Place………………………. Plaintiff

Dated………………………. Through

Advocates

VERIFICATION

Verified at………………………. on this day of………………………. 19………………………. that the contents of
paras………………………. to………………………. of the plaint are true and correct to my knowledge and those
of paras ………………………. to………………………. of the plaint are correct on the information received and
believed to be true. Last para of the plaint is a prayer clause to this Hon’ble Court by the plaintiff.
Place: Plaintiff.

Dated: