IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PLAINTIFF
-VS-

------------------------------- ….. DEFENDANTS

PLAINT UNDER ORDER 7 RULE 1 AND SECTION 151 0F CPC

I.PLAINTIFF :
--------------------------------------------------------------------------------------------
-------------------------------------------------------------------------

The address for service of the Plaintiff is the same as above and care of
VPS LAW FIRM, Advocates, Coimbatore - 641 018.

II. DEFENDANTS:
-------------------------------------------------------------------------------------

The address for service of the Defendant is the same as above.

III. 1. The plaintiff submits that the suit property, a vacant land, was
purchased by him by virtue of a registered Sale Deed dated 23.01.2006 with
registration No.------ of 2006 in the office of Sub-registrar, -----------------,
---------------------------, from one ------------------------ by paying the sale
consideration of Rs.-------------/-. The Plaintiff had obtained the
Encumbrance certificate for the property before the purchase and made
reasonable enquiries with the neighbours of the property about the
possession and title thereof which revealed that his seller had the title and
possession. The Plaintiff has produced the notarized copies of all the above
documents along with the plaint. The Plaintiff is a bonafide purchaser for a
valuable consideration and without knowledge of any encumbrance over the
suit property.
1/4
2. Eversince the date of purchase, the Plaintiff has been in peaceful,
continuous possession and enjoyment thereof. The Defendants, who do not
have any right, title and interest whatsoever over the suit property, had
attempted to trespass into the same on 27.04.2009 at about 04.00 p.m. by
threatening the Plaintiff that it should be sold to them for a throw-away price
lest the Plaintiff could not enjoy the property peacefully. However, the
Plaintiff had successfully thwarted their attempts and they ran away leaving
a threat to stage a come back and disturb the Plaintiff’s possession thereof
again.

3. The intention and actions of the Defendants are clearly illegal and
unjust. They have men and materials at their beck and call and capable of
executing their threats. In the circumstances, unless the Defendants are
restrained from doing so, the Plaintiff will be put to irreparable loss and
hardships which can not be adequately compensated. The Plaintiff has a
prima facie case and the balance of convenience is also in his favour. Hence
the suit.

4. The cause of action for the suit arose on ----------------------, when

the plaintiff purchased the suit property and has been in continuous peaceful
possession and enjoyment thereof ever since then; On -------------,when the
Defendants attempted to trespass into the property; and left a threat to
continue his illegal attempts; all at Coimbatore within the jurisdiction of this
Honourable Court.

5. The suit is valued at Rs. for the purpose of courts fees and
jurisdiction and a Court Fee of Rs. is paid under Sections 27 ( c )
of the T.N.C.F.AND S.V. Act.

2/4
 DETAILS OF VALUATION
For the Relief of
Permanent injunction
in column (a ) Rs.

Court Fee Paid Rs.

--------------------------------
Total Rs. Rs.
--------------------------------

06. The Plaintiff therefore prays that this Honourable Court may

be pleased to pass a decree of:-

a) PERMANENT INJUNCTION restraining the Defendants and

their agents from trespassing into the suit property and disturbing the

Plaintiff’s peaceful possession and enjoyment thereof in any manner

whatsoever;

b) DIRECTING THE DEFENDANTS to pay costs of this suit;

and

c) GRANT such other and further orders deemed fit and

necessary in the circumstances of the case.

ADVOCATE FOR PLAINTIFF PLAINTIFF

VERIFICATION
I, the Plaintiff above named, do hereby solemnly declare
that the facts stated in Para Nos.1 to 6 above are true and correct to
the best of my knowledge and belief and I signed this verification
at Coimbatore on 27th day of April, 2009.

PLAINTIFF
SCHEDULE OF PROPERTIES

--------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------

PLAINTIFF

3/4
 VERIFICATION

I, the Plaintiff above-named, do hereby solemnly affirm and

sincerely declare that the Description of property stated above is true and
correct to the best of my knowledge and belief and I signed this
verification on this the --th day of ----------, 2009 at ----------------------.

PLAINTIFF

LIST OF DOCUMENTS filed under Order 7 rule 14 of CPC

-----------------------------------------------------------------------------------------
Sl.No. Date of document Description of document
-----------------------------------------------------------------------------------------

ADVOCATE FOR PLAINTIFF

4/4
 IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

O.S.No. of 2009

Plaintiff

Versus
Defendant

PLAINT UNDER
ORDER 7 RULE 1 AND
SECTION 151 0F CPC

Encl:

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PLAINTIFF
-VS-

------------------------------- ….. DEFENDANTS

VERIFICATION AFFIDAVIT OF ------------------------ FILED

UNDER ORDER 6 RULE 15(4) OF CPC

I,
--------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------- do
hereby solemnly affirm and sincerely state as follows:-

1. I submit that I am the power agent of the Plaintiff in the above

suit and as such I am well acquainted with the facts and circumstances
of the case.

2. I submit that I hereby declare that what are all the facts stated in
the Para 1 to last of the Plaint are true and correct to the best of my
knowledge, belief and information.

In said circumstances, I pray that this Honourable Court may be

pleased to accept this Affidavit for the compliance of the provision of
Order 6 Rule 15(4) of CPC and thus render justice.

Solemnly affirmed and signed

in my presence on this
th
day of 2009 at ------------------

Advocate, ------------------
IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

O.S.No. of 2009

Plaintiff

Versus
Defendant

VERIFICATION AFFIDAVIT
OF --------------------- FILED
UNDER ORDER 6 RULE
15(4) OF CPC

Encl:

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- .... RESPONDENTS/DEFENDANTS

PETITION UNDER ORDER 26 RULE 9 AND SECTION 151 OF

CPC

I. PETITIONER:
--------------------------------------------------------------------------------------------
---------------------------------------------------------------------

The address for service of the Plaintiff is the same as above

and care of VPS LAW FIRM, Advocates, Coimbatore - 641 018.

DEFENDANTS:-
---------------------------------------------------
--------------------------------------

The address for service of the Respondents are the same as above.

III. For the reasons stated in the affidavit, the Petitioner respectfully
prays that this Honourable court may be pleased to pass an order
appointing an advocate -commissioner to note down the physical
features of the property described in the petition along with
photographs and file a report thereof along with a rough plan and
grant such other and further orders deemed fit and necessary and
thus render justice.

DESCRIPTION OF PROPERTIES

--------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------
ADVOCATE FOR PETITIONER

IN THE COURT OF THE

DISTRICT MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

Petitioner/Plaintiff

Versus

Respondent/Defendant

PETITION UNDER ORDER

26 RULE 9 AND SECTION
151 OF CPC

Encl:Affidavit

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- .. . RESPONDENTS/DEFENDANTS

AFFIDAVIT OF ------------------------

I,
--------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------,do
hereby solemnly affirm and sincerely state as follows:

1. I am the Petitioner herein and power agent of the Plaintiff in the

above suit.

2. I pray that the plaint in the above suit may kindly be treated as part and
parcel of this affidavit.

3. The petitioner submits that the petition-mentioned property, a vacant land,

was purchased by him by virtue of a registered Sale Deed dated 23.01.2006
with registration No.------------------ in the office of Sub-registrar,
----------------------, --------------------, from one ------------------------------ by
paying the sale consideration of Rs.----------------/-. The Petitioner had
obtained the Encumbrance certificate for the property before the purchase
and made reasonable enquiries with the neighbours of the property about the
possession and title thereof which revealed that his seller had the title and
possession. The Petitioner has produced the notarized copies of all the above
documents along with the plaint. The Petitioner is a bonafide purchaser for a
valuable consideration and without knowledge of any encumbrance over the
petition-mentioned property.
2. Eversince the date of purchase, the Petitioner has been in peaceful,
continuous possession and enjoyment thereof. The Respondents, who do not
have any right, title and interest whatsoever over the petition-mentioned
property, had attempted to trespass into the same on 27.04.2009 at about
04.00 p.m. by threatening the Petitioner that it should be sold to them for a
throw-away price lest the Petitioner could not enjoy the property peacefully.
However, the Petitioner had successfully thwarted their attempts and they
ran away leaving a threat to stage a come back and disturb the Petitioner’s
possession thereof again.
3. The intention and actions of the Respondents are clearly illegal and
unjust. In the circumstances, unless an advocate -commissioner is appointed
to note down the physical features of the property described in the
petition along with photographs and file a report thereof along with a
rough plan, the petitioner will be put to much loss and hardships.
4. Therefore, the Petitioner prays that this Honourable court may be
pleased to pass an order appointing an advocate -commissioner to note
down the physical features of the property described in the petition
along with photographs and file a report thereof along with a rough plan
and grant such other and further orders deemed fit and necessary and thus
render justice.

Solemnly affirmed and

signed before me at
------------------- on

PETITIONER

Advocate, ----------------------.

2/2
IN THE COURT OF THE
DISTRICT
MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

AFFIDAVIT OF THE
PETITIONER
IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

O.S.No. of 2009

Plaintiff

Versus
Defendant

PLAINT UNDER ORDER 7

RULE 1 OF C.P.C.

Encl:

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

PETITION UNDER ORDER 39 RULES 1 & 2 AND SECTION 151 OF

CPC
I. PETITIONER:
--------------------------------------------------------------------------------------------
---------------------------------------------------------------------

The address for service of the Petitioner is the same as above

and care of VPS LAW FIRM, Advocates, Coimbatore - 641 018.

II. DEFENDANTS:-
--------------------------------------------------------------------------------------------
------------------------------------------------------------------

The address for service of the respondent is the same as above

III. For the reasons stated in the affidavit, the Petitioner respectfully

prays that this Honourable court may be pleased to pass an order

of TEMPORARY INJUNCTION restraining the and his agents

from trespassing into the property mentioned hereunder and disturbing

the Petitioner’s peaceful possession and enjoyment thereof in any

manner whatsoever till the disposal of the above suit and an order of

AD- INTERIM INJUNCTION to the same effect till the disposal of

this application and grant such other and further orders deemed fit

and necessary in the circumstances of the case.

DESCRIPTION OF PROPERTIES
ADVOCATE FOR PETITIONER
IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

Petitioner/Plaintiff

Versus

Respondent/Defendant

PETITION UNDER
ORDER 39 RULES 1 & 2
AND SECTION 151 OF CPC

Encl:Affidavit

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

AFFIDAVIT OF ------------------

I. PETITIONER:
--------------------------------------------------------------------------------------------
-----------------------------------------------------------------,do hereby solemnly
affirm and sincerely state as follows:

1. I am the Petitioner herein and power agent of the Plaintiff in the

above suit.

2. I pray that the plaint in the above suit may kindly be treated as part and
parcel of this affidavit.

3. The petitioner submits that the petition-mentioned property, a vacant land,

was purchased by him by virtue of a registered Sale Deed dated
--------------with registration No.--------------- in the office of Sub-registrar,
--------------, --------------------------, from one ----------------------- by paying
the sale consideration of Rs.-----------------/-. The Petitioner had obtained the
Encumbrance certificate for the property before the purchase and made
reasonable enquiries with the neighbours of the property about the
possession and title thereof which revealed that his seller had the title and
possession. The Petitioner has produced the notarized copies of all the above
documents along with the plaint. The Petitioner is a bonafide purchaser for a
valuable consideration and without knowledge of any encumbrance over the
petition-mentioned property.

2. Eversince the date of purchase, the Petitioner has been in peaceful,

continuous possession and enjoyment thereof. The Respondents, who do not
have any right, title and interest whatsoever over the petition-mentioned
property, had attempted to trespass into the same on ---------------- at about
--------- by threatening the Petitioner that it should be sold to them for a
throw-away price lest the Petitioner could not enjoy the property peacefully.
However, the Petitioner had successfully thwarted their attempts and they
ran away leaving a threat to stage a come back and disturb the Petitioner’s
possession thereof again.
3. The intention and actions of the Respondents are clearly illegal and
unjust. In the circumstances, unless they are restrained there from, the
petitioner will be put to much loss and hardships.
4. Therefore, the Petitioner prays that this Honourable court

may be pleased to pass an order of TEMPORARY INJUNCTION

restraining the and his agents from trespassing into the property

mentioned hereunder and disturbing the Petitioner’s peaceful

possession and enjoyment thereof in any manner whatsoever till the

disposal of the above suit and an order of AD- INTERIM

INJUNCTION to the same effect till the disposal of this application

and grant such other and further orders deemed fit and necessary in

the circumstances of the case.

Solemnly affirmed and

signed before me at
--------------------------- on

PETITIONER
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

AFFIDAVIT OF ----------------------

I. PETITIONER:
--------------------------------------------------------------------------------------------
---------------------------------------------------------------,do hereby solemnly
affirm and sincerely state as follows:

1. I am the Petitioner herein and power agent of the Plaintiff in the

above suit.

2. I pray that the plaint in the above suit may kindly be treated as part and
parcel of this affidavit. The Plaintiff who is my husband, is unable to attend
the court to prosecute the proceedings due to personal
inconveniences and it was expedient and necessary to appoint a power
agent for the prosecution of the said proceedings and I am aware of all his
suit transactions.
3. Therefore, the Petitioner prays that this Honourable court may be
pleased to permit me to file the suit as the power agent of the Plaintiff and
render justice .
Solemnly affirmed and
signed before me at
------------------ on

PETITIONER

Advocate, ---------------------.
IN THE COURT OF THE
DISTRICT
MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

AFFIDAVIT OF THE
PETITIONER
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

PETITION UNDER ORDER 3 RULE 2 AND SECTION 151 OF CPC

I. PETITIONER:
--------------------------------------------------------------------------------------------
---------------------------------------------------------------------

The address for service of the Petitioner is the same as above

and care of VPS LAW FIRM, Advocates, Coimbatore - 641 018.

II. RESPONDENTS:-
--------------------------------------------------------------------------------------------
-----------------------------------------------------------------

The address for service of the respondent is the same as above

III. For the reasons stated in the affidavit, the Petitioner respectfully prays
that this Honourable court may be pleased to permit me to file the suit as
the power agent of the Plaintiff and render justice.

ADVOCATE FOR PETITIONER

IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

Petitioner/Plaintiff

Versus

Respondent/Defendant

PETITION UNDER
ORDER 3 RULE 2 AND
SECTION 151 OF CPC

Encl:Affidavit

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

AFFIDAVIT OF --------------------------

I,
--------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------ ,do
hereby solemnly affirm and sincerely state as follows:

1. I am the Petitioner herein and power agent of the Plaintiff in the

above suit.

2. I pray that the plaint in the above suit may kindly be treated as part and
parcel of this affidavit. There is an urgent need to get an injunction order in
the above suit .
3. Therefore, the Petitioner prays that this Honourable court may be
pleased to treat the above suit and connected petitions as EMERGENT and
render justice .
Solemnly affirmed and
signed before me at
--------------------- on

PETITIONER

Advocate, ------------------------.
IN THE COURT OF THE
DISTRICT
MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

AFFIDAVIT OF THE
PETITIONER
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

PETITION UNDER SECTION 151 OF CPC

I. PETITIONER:
--------------------------------------------------------------------------------------------
---------------------------------------------------------------------

The address for service of the Petitioner is the same as above

and care of VPS LAW FIRM, Advocates, Coimbatore - 641 018.

II. RESPONDANTS:-
--------------------------------------------------------------------------------------------
-----------------------------------------------------------------

The address for service of the respondent is the same as above

III. For the reasons stated in the affidavit, the Petitioner respectfully prays
that this Honourable court may be pleased to treat the above suit and
connected petitions as EMERGENT and render justice.

ADVOCATE FOR PETITIONER

IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

PETITION UNDER
SECTION 151 OF CPC

Encl:Affidavit

Presented On:

Address for Service

V.P.SARATHI
Advocate
Coimbatore - 18.
 IN THE COURT OF THE DISTRICT MUNSIF OF COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

-----------------------------
Rep. by his/her power agent
--------------------------- ….. PETITIONER/PLAINTIFF
-VS-

------------------------------- ….. RESPONDENTS/DEFENDANTS

REPORT FILED BY THE COMMISSIONER/ADVOCATE

1. In pursuance of warrant of commission issued to me in the above

case, I had inspected the Suit Property on ------------ at about ------,
after giving notice to the counsel for the Petitioner. The Respondents
were not present during my visit. Petitioner’s Counsel and the
Petitioner were also present, throughout my visit. ------------------------
whose house is situate on North of the Suit property was also present
with his family members.
2. The Petitioner’s counsel had given oral instructions at the time of my
visit. The scope of the warrant is to visit the Suit Property and note
down its Physical Features. I have drawn a Rough Sketch not drawn
to the scale and this may be considered as part and parcel of my
report.
3. The Suit Property is a
-----------------------------------------------------The Petitioner took the
photos of the Suit property in my present which shows the physical
features of the Suit Property.
4. Just opposite the Suit property ---------------------------------------
5. The entire four sides of the Suit property has been fenced with
barbed wire with stone pillars. The Suit property measured 58 feet
East-West on both sides and 188 feet North-South on both sides.
6. At the time of my visit the Petitioner opened the lock of the gate
situated on the North-Eastern corner of the Suit property and we
 entered into the Suit property.
7. I enclose herewith Rough Sketch not drawn to Scale, Photographs 7
Nos. with C.D, along with Bill. I have received the remuneration
from the counsel for the Petitioner and I herewith return the warrant
duly executed.

Advocate/Commissioner

2/2
IN THE COURT OF THE
DISTRICT MUNSIF OF
COIMBATORE

I.A.No. of 2009

O.S.No. of 2009

PETITIONER/PLAINTIFF

-VS-
RESPONDENT
S/
DEFENDANTS

REPORT FILED BY
THE COMMISSIONER
/ADVOCATE

Presented on:-

Address for Service