Civil applications

Application under Order 39 Rules 1-2 CPC for prohibitory injunction in a partition suit

Name: Justis AI
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IN THE COURT OF THE LEARNED DISTRICT JUDGE,

ROHINI COURTS, DELHI

CS NO.Civil suit number /Year

IN THE MATTER OF:

Plaintiff's name…. Plaintiff

VERSUS

First defendant's name and others…. Defendants

APPLICATION UNDER ORDER Order number RULES 1 AND 2, READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908, FOR GRANT OF A PROHIBITORY INJUNCTION AGAINST THE DEFENDANTS

MOST RESPECTFULLY SHOWETH:

1.That the Plaintiff has filed the present suit for partition, which is pending adjudication before this Hon'ble Court.

2.That the contents of the partition suit may be read as part and parcel of the present application, and the same are not being reproduced herein for the sake of brevity.

3.That, in view of the facts and circumstances set out in the accompanying partition suit, the Plaintiff apprehends that the Defendants will transfer, alienate, mortgage or otherwise create a third-party interest in the suit property, and will thereby prevent the Plaintiff from receiving her Plaintiff's share in the suit property (e.g., 1/7th) share in the suit property.

4.That the Plaintiff submits that unless all the Defendants are restrained from transferring, alienating, mortgaging or creating any third-party interest in the suit property, irreparable harm, loss and injury will be caused to the Plaintiff, which cannot be adequately compensated in terms of money, and the very purpose of instituting the present suit will be defeated.

5.That the balance of convenience lies in favour of the Plaintiff and against the Defendants, and the Plaintiff is bound to succeed in the suit on all probabilities.

PRAYER

In view of the above facts and circumstances, it is, therefore, most respectfully and humbly prayed that this Hon'ble Court may graciously be pleased to:

(a)pass an ex-parte interim order restraining all the Defendants, namely Defendants No. 1 to Total number of defendants, their agents, administrators, attorneys and representatives, from selling, transferring, alienating, mortgaging or creating any third-party charge in respect of the suit property situated at Flat No. Suit property flat number, Suit property locality, Builder/society name of the suit property, Plot No. Plot number of the suit property, Suit property area/city, Delhi – Suit property PIN code, more specifically shown in the site plan annexed hereto;

(b)pass such other and further orders as this Hon'ble Court may deem fit and proper in the facts and circumstances of the present case, in favour of the Plaintiff and against the Defendants.

PLAINTIFF

Place: New Delhi

DateTHROUGH COUNSEL

Counsel's law firm name & ASSOCIATES

Office No. 1, Counsel's office address, Delhi – Counsel's office PIN code

(M) Counsel's mobile number

IN THE COURT OF THE LEARNED DISTRICT JUDGE,

ROHINI COURTS, DELHI

CS NO.Civil suit number /Year

IN THE MATTER OF:

Plaintiff's name…. Plaintiff

VERSUS

First defendant's name and others…. Defendants

AFFIDAVIT

I, Plaintiff's name, aged about Plaintiff's age years, wife of Shri Plaintiff's husband's name, daughter of Late Shri Plaintiff's father's name, resident of Flat No. Plaintiff's flat number, Pocket Plaintiff's pocket, Sector Plaintiff's sector, Plaintiff's locality, Delhi, do hereby solemnly affirm and declare as under:

1.That I am the Plaintiff in the above-mentioned case and, as such, I am well conversant with the facts and circumstances of the case and am competent to swear this affidavit.

2.That the accompanying application has been drafted by my counsel under my instructions, and its contents have been read over and explained to me in my vernacular; the same are true and correct to my knowledge and belief, and the contents of the application shall be read as part and parcel of this affidavit, and are not repeated herein for the sake of brevity.

DEPONENT

VERIFICATION:

I, the deponent above named, do hereby verify that the contents of the above affidavit are true to my knowledge and belief, that no part of the same is false, and that nothing material has been concealed therefrom.

Verified at Delhi on this Date of verification day ofMonth of verification, Year of verification.

DEPONENT

IN THE COURT OF THE LEARNED DISTRICT JUDGE,

ROHINI COURTS, DELHI

CS NO.Civil suit number /Year

IN THE MATTER OF:

Plaintiff's name…. Plaintiff

VERSUS

First defendant's name and others…. Defendants

APPLICATION UNDER ORDER Order number RULES 1 AND 2, READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908, FOR GRANT OF A PROHIBITORY INJUNCTION AGAINST THE DEFENDANTS

MOST RESPECTFULLY SHOWETH:

1.That the Plaintiff has filed the present suit for partition, which is pending adjudication before this Hon'ble Court.

2.That the contents of the partition suit may be read as part and parcel of the present application, and the same are not being reproduced herein for the sake of brevity.

5.That the balance of convenience lies in favour of the Plaintiff and against the Defendants, and the Plaintiff is bound to succeed in the suit on all probabilities.

PRAYER

In view of the above facts and circumstances, it is, therefore, most respectfully and humbly prayed that this Hon'ble Court may graciously be pleased to:

(b)pass such other and further orders as this Hon'ble Court may deem fit and proper in the facts and circumstances of the present case, in favour of the Plaintiff and against the Defendants.

PLAINTIFF

Place: New Delhi

DateTHROUGH COUNSEL

Counsel's law firm name & ASSOCIATES

Office No. 1, Counsel's office address, Delhi – Counsel's office PIN code

(M) Counsel's mobile number

IN THE COURT OF THE LEARNED DISTRICT JUDGE,

ROHINI COURTS, DELHI

CS NO.Civil suit number /Year

IN THE MATTER OF:

Plaintiff's name…. Plaintiff

VERSUS

First defendant's name and others…. Defendants

AFFIDAVIT

1.That I am the Plaintiff in the above-mentioned case and, as such, I am well conversant with the facts and circumstances of the case and am competent to swear this affidavit.

DEPONENT

VERIFICATION:

Verified at Delhi on this Date of verification day ofMonth of verification, Year of verification.

DEPONENT

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All templates

IN THE COURT OF THE LD. DISTRICT JUDGE (COMMERCIAL COURT), DIST. District name, Court complex name COURTS, DELHI.

C.S. (COMM) NO. Commercial suit number OF 20Last digit of year of suit

IN THE MATTER OF:

Plaintiff company name PVT. LTD.: PLAINTIFF

VERSUS

MR. Defendant's name

Proprietor of M/s. Defendant's firm name Trading Company: DEFENDANT

(P.S. Police station number)

AFFIDAVIT UNDER ORDER XI RULE 6(3) OF THE COMMERCIAL COURTS ACT, 2015 READ WITH SECTION 65B OF THE INDIAN EVIDENCE ACT, 1872

I, Deponent's name, Authorised Representative of M/s. Company name of deponent's employer Pvt. Ltd., having its office at Company office address, do hereby solemnly affirm and declare as under:

1.That I am the Authorised Representative of the Plaintiff Company in the above-noted suit and am fully conversant with the facts and circumstances of the case. I am, therefore, competent to swear this affidavit.

Civil applications

Affidavit under Order XI Rule 6(3) Commercial Courts Act read with Section 65B Evidence Act for electronic records

IN THE COURT OF SH. Judge's name

Date of hearingLD. ADJ, SHAHDARA DISTRICT, KARKARDOOMA COURTS, DELHI.

P.C. NO. P.C. number OF 20Year of P.C. number

IN THE MATTER OF :-

Petitioner's name (part 1) Petitioner's name (part 2): PETITIONER

VERSUS

THE STATE (NCT OF DELHI) & ORS.: RESPONDENTS

N.D.O.H.: Next date of hearing

APPLICATION ON BEHALF OF THE APPLICANT / RESPONDENT NO. 2 FOR SUMMONING THE WITNESSES AS PER THE LIST OF WITNESSES FILED ON RECORD ON Date of filing the list of witnesses, SO AS TO BRING ON RECORD THE JUDICIAL FILES OF THE CASES REFERRED TO IN THE PRESENT MATTER.

MOST RESPECTFULLY SHOWETH:

1.That the present probate petition is pending before this Hon'ble Court and is now fixed for Next date of hearing for defense evidence.

2.That on Date of filing the list of witnesses, the Applicant / Respondents No. 2 and 3 filed the list of witnesses in support of their defense in the present case, which was taken on record by this Hon'ble Court vide order dated Date of order taking the list of witnesses on record.

Civil applications

Application by respondent for summoning witnesses with judicial records in probate petition

BEFORE THE HON’BLE Designation of judge JUDGE, Court number COURT, Court location

Applicant's name: APPLICANT

APPLICATION ON BEHALF OF THE APPLICANT, NAMELY Mrs. Applicant's name, SEEKING EXEMPTION FROM PERSONAL APPEARANCE.

Mrs. Applicant's name, aged about Applicant's age years, daughter of Applicant's father's name, wife of Applicant's husband's name, resident of Applicant's address – Applicant's PIN code …Applicant

Versus

First respondent's name and Dr. Second respondent's name …Respondents

Filed onDate of filing

Case No.Case number

It is most respectfully submitted to this Hon’ble Court as under:-

1.That the Applicant is the Petitioner No. 1 in the above-mentioned case.

2.That the Applicant is unable to appear before this Hon’ble Court on account of urgent official work. On this account, the Applicant will not be able to appear before this Hon’ble Court today. The Applicant has conveyed the same to her counsel over telephone and has instructed him to move the present application seeking exemption from personal appearance.

Civil applications