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

_____ of 2013 In ORIGINAL SUIT NO. BETWEEN: 1. Sri Abraham T.J. S/o Joseph T.A. Aged about 53 Years #2457, 16th "B" Main H.A.L 2nd Stage Indiranagar Bangalore-560 008 State of Karnataka Sri Mohan Raj S/o Ramu Aged Major No.49, 1st Main, 7th Cross B.Nagasandra, Yamalur Post Bangalore 560 037 State of Karnataka Dr.S.M.Gopal S/o Patel Muniyappa Aged about 52 years Sheshapur, Lakshmisagar Panchayat Srinivaspur Taluk Kolar District 563127 State of Karnataka Sri Jayarama H.V S/o Venkataiah H.K Aged about 54 years #156, Hottiganahosahalli Channapattana Ramanagaram 571 501 State of Karnataka Sri Nagesh T. S/o Thimmegowda Aged about 46 years #141/D, Hottiganahosahalli Channapattana Ramanagaram 571 501 State of Karnataka OF 2013

Plaintiff No.1

2.

Plaintiff No.2

3.

Plaintiff No.3

4.

Plaintiff No.4

5.

Plaintiff No.5

6.

Sri Jayaramaiah S/o Late Sanjeevaiah Aged about 41 years #57, Virupasandra Ramanagaram 571 511 State of Karnataka Sri Ramakrishnappa S/o Venkatappa Aged about 52 years No.12, Subbaiah Garden Layout Hongasandra Bangalore 560 068 State of Karnataka Sri Srinivasa B.V S/o Late Venkategowda Aged about 42 years No. 256, 9th Main, Nagendra Block Bangalore 560 085 State of Karnataka. Sri S.Suresh S/o S.Srinivasaiah Aged about 43 years No. 24-1-E, Basavanagudi Road Bangalore 560 004 State of Karnataka

Plaintiff No.6

7.

Plaintiff No.7

8.

Plaintiff No.8

9.

Plaintiff No.9

10. Sri Kumaraswamy M.C. S/o Chinnappaiah Aged about 37 years No. 208, 8th Main 4th Stage BEML layout Rajarajeshwarinagar Bangalore 560 098 State of Karnataka 11. Sri Suhail Baig S/o Jabbar Baig Aged about 47 years No. 46, Millers 2nd Cross Road Benson Town Jayamahal Bangalore 560 046 State of Karnataka 12. Sri Srinivasa H.R. Late H.T.Ramaiah Aged about 49 years No. 16/1, Jain Temple Street V.V.Puram

Plaintiff No.10

Plaintiff No.11

Plaintiff No.12

Bangalore 560 004 State of Karnataka 13. Sri S.Ravichandran S/o Shivadanam Aged about 36 years No.365, Venkataswami Reddy Layout B.Narayanapura Bangalore 560 048 State of Karnataka AND: 1. Bharatiya Janata Party Represented by its President Sri Rajanath Singh President at present as also during May, 2008 Having its Central Head Office at #11 Ashoka Road New Delhi 110 001 Sri D.V.Sadananda Gowda President, during May, 2008 Bharatiya Janata Party, Karnataka and Former Chief Minister of Karnataka Sworn in as the 20th Chief Minister (04-Aug-2011 to 12-Jul-2012) Having its Head office at: Jagannatha Bhavana #48, Temple Street, 11th Cross Malleshwaram Bengaluru 560 003 State of Karnataka Sri Pralhad Joshi President, Bharatiya Janata Party, Karnataka Having its Head office at: Jagannatha Bhavana #48, Temple Street, 11th Cross Malleshwaram Bengaluru 560 003 State of Karnataka Sri B.S.Yediyurappa Former Chief Minister of Karnataka Sworn in as the 19th Chief Minister (30-May-2008 to 31-Jul-2011) Bharatiya Janata Party, Karnataka Having its Head office at:

Plaintiff No.13

Defendant No.1

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Defendant No.2

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Defendant No.3

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Defendant No.4

Jagannatha Bhavana #48, Temple Street, 11th Cross Malleshwaram Bengaluru 560 003 State of Karnataka 5. Sri Jagadish Shivappa Shettar Chief Minister of Karnataka Sworn in as the 21st Chief Minister Bharatiya Janata Party, Karnataka Having its Head office at: Jagannatha Bhavana #48, Temple Street, 11th Cross Malleshwaram Bengaluru 560 003 State of Karnataka

Defendant No.5

APPLICATION UNDER ORDER XXXIX RULES 1 & 2 R/W 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. PRAYER Wherefore, to: a) Pass an ex-parte, ad-interim Order of stay upon the defendants by restraining them from knowingly disseminating or administering false election promises for the purpose of inducing the voters to the forthcoming 14 th Vidhana Sabha of Karnataka to thereby vote for the candidates set up by the defendant political party, BJP, in the interest of justice, equity and good conscience; 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. under the facts and special circumstances

narrated above, this Honble Court may graciously be pleased

Bangalore Date: 02-May-2013 Advocate for Plaintiffs