IN THE COURT OF THE VACATION CITY CIVIL AND SESSIONS JUDGE AT BANGALORE INTERLOCUTORY APPLICATION NO.

_____ of 2013 In ORIGINAL SUIT NO. BETWEEN: Sri Abraham T.J. and others AND: Bharatiya Janata Party and others Defendants Plaintiffs OF 2013

APPLICATION UNDER SECTION 11 OF THE BANGALORE CITY CIVIL COURT ACT, 1979 READ WITH SECTION 28 OF THE KARNATAKA CITY CIVIL COURTS ACT, 1964 AND SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908. 1. The plaintiffs respectfully seek that the facts, averments, contentions, pleadings, argument and every other narration contained in the accompanying plaint may kindly be treated as forming an integral part of this interlocutory application. 2. The plaintiffs respectfully submit that the evil of political parties knowingly making false promises during election time is a matter of grave concern to the voters of our country. Further, the elections to the 14th Vidhana Sabha of Karnataka are scheduled to be held on 05-May-2013 and there is every likelihood of the BJP political party indulging in the making of a fresh set of false election promises with a view to induce the unsuspecting voters in the State to vote for that party by reposing their faith upon such fraudulent misrepresentation. Thereby, the trust reposed by the class of public of which these plaintiffs are the representatives would be gravely and irreversibly injured.

3.

As such, it has become necessary to obtain an injunction upon the BJP political party, in public interest, from knowingly making false promises to the voters in respect of the elections to the 14th Vidhana Sabha of Karnataka that have been scheduled to be held on 05-May-2013.

4.

Also, the plaintiffs are of the bonafide impression that the frustrated voting population of the State would deserve to note, at this juncture, that such a suit as is being filed before this Honble Court would, upon coming into public knowledge, deter political parties which knowingly make false election promises from repeating such conduct with respect to the elections to the 14th Vidhana Sabha of Karnataka that have been scheduled to be held on 05-May-2013. PRAYER Wherefore, to: a) Receive the accompanying plaint in exercise of its powers under SECTION 11 OF THE BANGALORE CITY CIVIL COURT ACT, 1979 READ WITH SECTION 28 OF THE KARNATAKA CITY CIVIL COURTS ACT, 1964 AND SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908 and treat the urgency as pleaded by these plaintiffs as satisfactory and adequate for the purpose of entertaining the accompanying plaint and to pass appropriate Orders thereupon; b) Pass any other order or to issue any direction as may be deemed expedient by this Honble Court to be desirable in the circumstances of this case, in the interest of justice. Bangalore Date: 02-May-2013 Advocate for Plaintiffs under the facts and special circumstances

narrated above, this Honble Court may graciously be pleased