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SUIT FOR INJUNCTION RESTRAINING NUISANCE

IN THE COURT OF THE………………..

Suit No………………… of 19………………..

C. D………………………………………………………….. Plaintiff

versus

C. F……………………………………………………….. Defendant

The abovenamed plaintiff most respectfully submits as under: —

1. The Plaintiff is, and at all the times hereinafter mentioned was, the absolute owner of the house No…………………. Street…………………

2. The defendant is, and at all the said times was, the absolute owner of a plot of ground in the same street………………..

3. On the……………….. day of……………….. 19………………… the defendant erected upon his said plot a slaughter-house, and still maintains the same; and from that day until the present time has continually caused cattle to be brought and killed there and has caused the blood and offal to be thrown into the street opposite the said house of the plaintiff.

4. In consequence, the plaintiff has been compelled to abandon the said house, and has been unable to rent the same.

5. The plaintiff gave a registered notice to the defendant to restrain himself from committing the nuisance, to which he did not reply. The notice was received by him on……………….. 19………………..

6. Cause of action arose within the jurisdiction of this court on……………….. 19……………….. when the defendant received notice of the plaintiff.

7. The suit is valued at Rs………………… twelve times of the rent at which the house of the plaintiff was formerly let, and court fee for injunction is paid accordingly.

RELIEF CLAIMED:

The plaintiff claims that the defendant be restrained by injunction from committing or permitting any further nuisance.

Plaintiff

Through Advocate

VERIFICATION

I, abovenamed plaintiff, do hereby verify that the contents of paras ……………….. to……………….. of the plaint are true to my personal knowledge and those of paras……………….. and……………….. thereof are based on legal advice which I believe to be true.

Verified on this…………….. day of……………….. 19……………….. at………………..

Plaintiff

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