Interim Injunction Application

IN THE [court_name] I.A. NO. ________ OF 20____ IN SUIT NO. [suit_number] IN THE MATTER OF: [plaintiff_name] ... PLAINTIFF / APPLICANT VERSUS [defendant_name] ... DEFENDANT / RESPONDENT APPLICATION UNDER ORDER XXXIX RULES 1 AND 2 READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908, FOR GRANT OF TEMPORARY INJUNCTION MOST RESPECTFULLY SHOWETH: 1. NATURE OF THE DISPUTE [subject_matter] 2. That the Applicant has filed the accompanying suit against the Respondent, and the contents of the plaint may kindly be read as part and parcel of this application and are not repeated here for the sake of brevity. 3. PRIMA FACIE CASE 3.1 The Applicant has a strong prima facie case on the merits, as follows: [prima_facie_case] 3.2 There is a serious question to be tried in the suit, and the Applicant is likely to succeed at trial. 4. IRREPARABLE INJURY 4.1 If the injunction sought is not granted, the Applicant will suffer irreparable loss and injury, in the following manner: [irreparable_injury] 4.2 The injury apprehended is such as cannot be adequately compensated in money, and the Applicant has no other equally efficacious remedy. 5. BALANCE OF CONVENIENCE [balance_of_convenience] The balance of convenience lies wholly in favour of the Applicant and against the Respondent. The inconvenience likely to be caused to the Respondent by the grant of the injunction is far outweighed by the injury the Applicant will suffer if it is refused. 6. That the Applicant has approached this Hon'ble Court promptly and without delay, and there has been no acquiescence, waiver or laches on the Applicant's part. 7. That the Applicant undertakes to abide by any order as to damages that this Hon'ble Court may make in the event the injunction is found to have been wrongly obtained. 8. That unless restrained by an order of this Hon'ble Court, the Respondent is likely to act in the manner apprehended, thereby rendering the reliefs claimed in the suit infructuous and defeating the very purpose of the suit. 9. That this application is made bona fide and in the interests of justice. PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to: (a) Grant a temporary injunction restraining the Respondent, its agents, servants, representatives and all persons claiming through or under it, in the following terms: [injunction_sought] (b) Grant an ad-interim ex-parte injunction in the above terms pending disposal of this application, the matter being urgent and any delay likely to defeat the purpose of this application; (c) Pass such other or further orders as this Hon'ble Court may deem just and proper in the facts and circumstances of the case. AND FOR THIS ACT OF KINDNESS, THE APPLICANT SHALL AS IN DUTY BOUND EVER PRAY. Place: ______________ Date: [application_date] [plaintiff_name] APPLICANT Through ______________________ ADVOCATE FOR THE APPLICANT NOTE ON THE THREE REQUIREMENTS A temporary injunction is granted only where all three of the following are satisfied together: a prima facie case, irreparable injury not compensable in money, and the balance of convenience. Each must be pleaded and supported by material, not merely asserted. This application must be supported by an affidavit. Where an ex-parte injunction is sought, Order XXXIX Rule 3 requires the applicant to give notice to the opposite party, unless the court records reasons for dispensing with it, and to comply with the filing and service obligations prescribed thereunder.