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NARSEE MONJEE INSTITUTE OF MANAGEMENT
STUDIES SCHOOL OF LAW
SUIT FOR INJUNCTION
SUBJECT: DRAFTING, PLEADING ANDCONVEYANCING
BATCH 2021-2026
ASSIGNMENT – 3
SUBMITTED TO: SUBMITTED BY:
PROF. SAHHANA REDDY NAME: MAHIKA RAO
ASST. PROF OF LAW. SAP ID – 81022100062
NMIMS (SOL), BENGALURU [Link]., LL.B. (HONS.) III YEAR
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IN THE COURT OF SENIOR CIVIL JUDGE (DISTRICT ), BANGALORE
IA NO. 423 OF 2024
IN
SUIT NO. 505 OF 2024
IN THE MATTER OF:
Ms. Maya Singh Raghavan
D/O Satish Singh
R/O 3rd cross, Jayanagar
Ashoka Pillar, Bengaluru
500016
…............................ Plaintiff / Applicant
VERSUS
Mr. Rajeev Singh
R/O 1st block, J.P Nagar
SG Pallia, Bengaluru
500098
…......................... Defendant / Respondent
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APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER 39 RULE 1 & 2
r/w SECTION 151 OF CODE OF CIVIL PROCEDURE, 1908
MOST RESPECTFULLY SHOWETH:
The Plaintiff / Applicant, above named, respectfully submits as under:
1. That the plaintiff has filed the present suit for Threat of illegal dispossession and sale of
property (Shanti Bhavan)
2. The Plaintiff, Maya, brings forth this suit against the Defendant, Rajeev, on the grounds of
an imminent threat of illegal dispossession and sale of property, namely the ancestral home
known as "Shanti Bhavan," is all Maya has left of her parents hereinafter referred to as the
“Property”
3. Maya's childhood and identity were closely linked to her upbringing in Shanti Bhavan. Her
haven of beloved memories was the house with its creaking floors and gardens. It was a
loving environment because of her parents' moral principles and compassion. Shanti
Bhavan was more than just a building, it housed memories of family members and
commemorated achievements. It was a place of belonging, love, and laughter for Maya.
She was now fighting to protect it for more reasons than just keeping possessions she was
doing it to honour her parents’ legacy and protect her own essence.
4. The Plaintiff has produced strong proof of her unquestionable ownership of the Property.
This proof consists of:
• Ancestral property deed conclusively demonstrating Maya's rightful ownership and title to
the Property.
• receipts for property taxes continuously filed in Maya's name, which further attests to her
ongoing ownership and occupation.
• These records' legitimacy and authenticity are still uncontested, providing a solid
foundation for the Plaintiff's ownership claim over the Property.
5. Rajeev has completely declined to assist the Plaintiff in establishing her legal claim to the
property. Rajeev has decided to ignore the evidence that Maya is the rightful owner of the
land and is not open to having a rational conversation or negotiating over this.
6. Rajeev is keeping Maya from using the property she is legally entitled to and from enjoying
it because he is inciting fear and threatening physical harm.
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7. Maya lives in closer proximity to Shanti Bhavan and will be adversely affected in the event
that the property is sold. She has a stake in keeping control of the land and protecting her
ownership rights.
8. The plaintiff also claims that the suit's final verdict might take a long time to come down.
She further claims that losing Shanti Bhavan would cause her to lose a significant portion
of her identity and legacy, which would be extremely upsetting. Due to the significant
burdens the plaintiff would face, this application was made.
9. By holding off on selling the Property until after the final decision, Rajeev, on the other
hand, would experience the least amount of inconvenience because he is not connected to
the Property's history or significance.
10. that the plaintiff/applicant has a strong prima-facie case and that the current action has a
good chance of succeeding
11. that the plaintiff has the advantage over the defendants in terms of convenience.
12. In the facts and circumstances of case mentioned herein above this Hon’ble Court may
graciously be pleased to
13. That the suit property is situated within the jurisdiction of this Hon’ble Court. Regarding
the cause of action, narrated above, this Hon’ble Court has the jurisdiction to entertain and
try this suit.
14. That the Plaintiff has come to know that the defendant is trying to dispose of the suit
property and for this purpose, some persons have contacted him through a property dealer.
In case, defendant not restrained from disposing of or creating third party interest in respect
of the suit property during pendency of the suit, the plaintiff shall suffer irreparable injury
and loss which cannot be compensated in terms of money. Any such transaction would also
lead to multiplicity of proceedings
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PRAYER
It is, therefore most respectfully prayed that this Hon’ble Court may be pleased to
1. Until the current lawsuit is resolved, Rajeev, his agents, representatives, and everyone else
working on his behalf are prohibited from selling, alienating, or otherwise disposing of
Shanti Bhavan by a temporary injunction.
2. pass such other and further order(s) as may be deemed fit and proper on the facts and in the
circumstances of this case.
PLAINTIFF / APPLICANT
THROUGH
MR RAJESH RAO
ADVOCATE
PLACE: BENGALURU
DATE: 03.10.2020
VERIFICATION
Verified at Bangalore on this day of 03.10.2020 that the contents of paras 1 to 14 of the plaint
are true and correct to my knowledge and those paras 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.
The Petitioner above named solemnly affirm and state that the statements made in paragraph
Nos.1 to 14 are true to the best of their knowledge, information and belief.
PLAINTIFF / APPLICANT
PLACE: BENGALURU
DATE: 03.10.2020
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APPLICATION FOR TEMPORARY INJUNCTION
IN THE COURT OF SENIOR CIVIL JUDGE DISTRICT,
BANGALORE
IA NO. 423 OF 2024
IN
SUIT NO. 505 OF 2024
IN THE MATTER OF;
Ms. Maya Singh Raghavan
...................................Plaintiff / Applicant
VERSUS
Mr. Rajeev Singh
..............................Defendant / Respondent
AFFIDAVIT
I, Ms Maya Singh Raghavan, D/O Satish Singh aged about 35 years , residing at 3rd cross,
Jayanagar Ashoka Pillar, Bengaluru 500016 do hereby state on solemn affirmation as follows
1. The property described in the plaint originally belonged to Mr and Mrs. Singh (Maya’s
parents) who died in June 2018 and on their death, the suit property came to be devolved
upon Maya, however defendant has been claiming the ownership of the property and he is
on the verge of selling the property to a faceless corporation.
2. That since last one and a half years, the relationship between the plaintiff and the defendant
is so strained that there have been frequent quarrels, and it has finally become necessary for
the plaintiff to file a suit.
3. The plaintiff claims that, aside from the suit property, the defendant has been preventing
them from enjoying it. The plaintiff further claims that they have no other ancestors or
family property.
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4. WHATEVER stated above is true and correct to the best of my knowledge and belief, and
so I have signed hereunder at PLAINTIFF
5. I submit that, the documents produced in para 1 to 14 of the accompanying plaint are true
and correct to the best of my knowledge, information and belief.
6. I submit that, the documents produced in the plaint are XEROX copies of the original.
PLACE: BENGALURU
DATE: 03.10.2020
DEPONENT
SCHEDULE OF THE PROPERTY
All that the House No.88, measuring 4000.00 Sq. Yards situated at Road no.6 Ashoka Pillar,
Bangalore and bounded by:
NORTH : WEST COAST ROAD
SOUTH : Plot no. 9
EAST : Plot no. 6
WEST : Plot no. 5
After both parties have read and understood the contents of the injunction suit, the parties
hereunder undertake and undersigned have this property with free will and consent on the first
mentioned date, month, and year, in the presence of the following witnesses:
WITNESSES
1. ADVOCATE
2. AUNT