SUIT FOR DAMAGES FOR OBSTRUCTING WAY AND FOR NJUNCTION TO DEMOLISH THE OBSTRUCTION
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 the time hereinafter mentioned was possessed of (a house in the village of…………….. of the District of…………….. )
2. He was entitled to a right of way from the house over a certain field to a public highway and back again from the highway over the field to the house of himself and his servants with vehicles, or on foot at all times of the year.
3. On the…………….. day of…………….. 19……………… defendant wrongfully obstructed the said way, so that the plaintiff could not pass with vehicles, or on foot or in any manner along the way and has ever since wrongfully obstructed the same.
4. The plaintiff has suffered damages of Rs……………… due to wrongfully obstruction caused by the defendant.
5. Cause of action arose on…………….. 19…………….. when defendant obstructed the defendant for the first time from using his right of way. This court has jurisdiction to try the suit.
6. The suit is valued at…………….. rupees and court-fees is paid thereon, and court-fee on the second relief for demolition of the unauthorised construction of the defendant is also paid on the same valuation, at its one fifth amount, i. e. on Rs. …………….. only.
RELIEF CLAIMED:
The plaintiff claims:
(i) payment of Rs……………… as damages from the defendant for the wrongful obstruction.
(ii) demolition of the constructions of the defendant obstructing wrongfully the way of the plaintiff by issuing a permanent injunction.
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