In the court of civil judge junior division 1s at Jalpaiguri

(Suit for permanent injunction)

Md Chamaul HOQUE S/O- Najrul Hoque ,resident of Baroghoriya , P.O-Dhapganj ,P.S-Kotwali, Dist –
Jalpaiguri

=vs=

1. Baharul Allom s/o- late khajaluddin Md.

2. Johirul Hoque S/o- Dharajuddin Md.

The plaintiff above most respectfully sewthe:-

1. That one Dharajuddin Md. Was the recorded owner of the land under mouza –Goralbari,
R.S. Khatian -1045 , R.S.-sheet no- 14, R.S.plot no- 1452 land measuring .09 de, R.S. Plot
No – 1453 land measuring .013de. as SHOLO ANNA share.
2. That said Dharajuddin Md. Was the recorded owner of the land on 26.04.78 he
transferred the land to the plaintiff under the said Mouza-, plot , khatian along with
other plots in separate schedule vide registered Deed No-2639 dated 26.04.78
3. That said Dharajuddin transferred under sheet no- 14 under schedule -2 , khatian no-
1049, R.S.plot no- 1453 land measuring with specific boundary and further under
schedule 1 Sheet no-14, khatian no-1047, plot no-1442 land measuring .09 de. Along
with other lands that after getting possession the plaintiff constructed several structure
that is land under Mouza – Goralbari , R.S. khatian no- 1045, R.S. plot no- 1053 land
measuring .013de.under Khatian no- 1047 ,Sheet no-14, plot no- 1452, land measuring
.09de.
4. That the plaintiff since purchase possessing the land as per possession given by said
Dharajuddin Md. Measuring land , fixing pillar , around the suit land .
5. That the defendant were near relative to the plaintiff recently giving disturbance in the
peaceful enjoyment of plaintiff’s property and further trying to erect the pakka structure
on the suit plots.
6. That on 16.05.18 the defendant along with 10/12’/, in their locality tried to constructed
structure on the suit land on being given objection by the plaintiff they could not
succeed on their motive.
7. That for the above acts of the defendant is required to be restrain by an injunction order
to disturb the plaintiff in any way in the peaceful enjoyment of the plaintiff’s property
and further restraining the defendant to enter into the suit land or to construct any kind
of structure in the suit land.
8. That the cause of action arrows on 10.06.19, 16.06.19 when the defendant tried to enter
in the suit land and the same is continuing within the jurisdiction of the learned court.
9. That the suit is for permanent injunction the same is valued Rs-100 and court fee
accordingly paid.
That plaintiff there fore pray:-
a. A permanent injunction restraining the defendant to give obstruction to the plaintiff
any way to the peaceful enjoyment of the plaintiff’s property.
 b. A permanent injunction restraining the defendant to enter in the suit land and to
construct any kind of structure.

c. A temporary in terms of prayer above.

d. Any other relief or relives .
e. Cost of the suit .

Schedule:-

Dist- Jalpaiguri, Mouza – Goralbari,Sheet no-14 , R.S. khtian No-1047,Plot no- 1452 land measuring
.09 De.

Boundary:-

Schedule :-

Khatian no- 1049 , Sheet No- 14, Plot No- 1453 land measuring .013 De.