स्थायी निषेधाज्ञा वाद, स्थगन आवेदन सहित

IN THE COURT OF Civil Judge (Senior Division), S.A.S. Nagar (Mohali)

Civil Suit No. ............ of ............

Harpreet Singh, S/o Sh. Amarjit Singh, aged 52 years, retired, resident of House No. 214, Phase 3B1, S.A.S. Nagar (Mohali) ... Plaintiff

versus

Jaswinder Singh, S/o Sh. Gurdev Singh, aged 47 years, businessman, resident of House No. 9, Sector 21-C, Chandigarh ... Defendant

Suit for permanent injunction restraining the defendant from dispossessing the plaintiff from, or interfering with the plaintiff's peaceful possession of, the suit property, with an application for a temporary injunction (stay) while the suit is pending.

The plaintiff states as follows:

1. 1. THE PROPERTY. The suit property is House No. 214, Phase 3B1, S.A.S. Nagar (Mohali), 300 sq. yards, bounded on the north by House No. 215 and on the south by a 30-foot road (the "suit property").

1. 2. THE PLAINTIFF'S RIGHT. The plaintiff bought the suit property from Sh. Mohinder Singh by registered sale deed No. 4172 dated 11.08.2004 and has been its owner since then.

1. 3. POSSESSION. The plaintiff has lived in the house with his family since 2004 and is in actual, peaceful possession.

1. 4. CAUSE OF ACTION. On 2 September 2026 the defendant came with six men, said the plot belongs to him, and threatened to break the boundary wall and take possession by force. The latest threat or act was on 1 April 2026, and the cause of action continues for as long as the defendant persists in it. Before filing, the plaintiff asked the defendant to stop: A legal notice dated 5 September 2026 was sent by registered post; the defendant did not reply.

1. 5. JURISDICTION AND VALUATION. The suit property lies within the territorial limits of this Court and the cause of action arose here. The suit is valued at ₹1,30,000 (Rupees One Lakh Thirty Thousand only) for jurisdiction and court fee. Court fee is paid as the court fee table of this Court requires on that valuation.

1. 6. OTHER PROCEEDINGS. No other suit or proceeding between the parties about the suit property has been filed or decided.

1. 7. DOCUMENTS. The plaintiff relies on: Sale deed dated 11.08.2004; property tax receipts for 2024-25; electricity bills; legal notice dated 05.09.2026 with postal receipt..

PRAYER

The plaintiff prays for a decree of permanent injunction restraining the defendant, and anyone acting for the defendant, from dispossessing the plaintiff from, or interfering with the plaintiff's peaceful possession of, the suit property; for the costs of the suit; and for any other relief the Court thinks fit.

VERIFICATION

Verified at S.A.S. Nagar (Mohali) on 2 April 2026 that paragraphs 1 to 5 are true to my knowledge and paragraphs 6 and 7 are true on the records and on information I believe to be true; nothing material has been concealed.