IN THE COURT OF SENIOR CIVIL JUDGE, ROHINI COURTS,

DELHI

CIVIL SUIT NO 2016

IN THE MATTER OF :-

PLAINTIFF

VERSUS
DEFENDANTS

APPLICATION UNDER ORDER XXXIX RULES 1 AND 2 READ WITH

SECTION 151 CPC
MOST RESPECTFULLY SHOWETH:-
1. That the plaintiff has filed the accompanying suit for injunction the contents
of the same be kindly read as part and parcel of this application which are
not repeated herein for the sake of brevity.
2. That the plaintiff has good prima facie case in his favour and there is every
likelihood of her succeeding in the suit.
3. That the balance of convenience also lies in favour of the plaintiff and
against the defendant.
4. That in case the defendants are not restrained by means of an ad-interim ex-
parte injunction during the pendency of the present suit, then the plaintiff
shall suffer irreparable loss and injury which cannot be compensated in
terms of money.
Prayer:-
It is therefore, most respectfully prayed that this Hon’ble court be pleased to
pass and ad-interim ex-parte order restraining the defendants no 1 and 2, their
family members, assignees, relatives, representatives, attorneys from alienating,
mortgaging, pleding or creating third party interest in respect of the suit
…….attached with the plaint, during the pendency of the present suit. This
Hon’ble court be also pleased to pass any other order which it deems fit and
 proper, under the facts and circumstances of the case, in favour of the plaintiff
and against the defendants, in the interest of justice.

IN THE HON’BLE COURT OF MS. SHEFALI SHARMA, CIVIL JUDGE,

ROHINI COURT, DELHI

CIVIL SUIT NO 4/2018

IN THE MATTER OF:

V PLAINTIFF

VERSUS

C & ANR DEFENDANTS

DOH 02.09.2016

AFFIDAVIT

I, , , do hereby solemnly affirm and declare as under:-

 1. That the Deponent is the Defendant No.3 in the present Suit and well

conversant with the fact of the same and hence competent to swear this

affidavit.

2. That the accompanying reply of the application under order XXXIX Rules 1

and 2 read with section 151 CPC has been drafted by the counsel of the

Deponent under his instruction and the same has been read over to him and

explained even in the vernacular language which is stated to be true and

correct to the best of his knowledge.

3. That the contents of the APPLICATION may be treated as an part and parcel

of this affidavit as the same are not being repeated herein for the sake of

brevity and to avoid repetition.

DEPONENT

VERIFICATION:-

Verification at Delhi on this 2nd day of Sep, 2016, that the content of

this affidavit are true and correct and nothing has been concealed therefrom.

DEPONENT