IN THE CITY CIVIL COURT AT MADRAS

I.A.No. of 2015
in
O.S. No. of 2015
V.Arumugam (M/72),
S/o. Mr.Veerapathiran,
No.177, Omsakthi Vinayakar Koil Street,
T.H.Road, M.R.Nagar,
Kodungaiyur, Chennai- 600 118. … Petitioner /Plaintiff
-Vs-
1. Mrs.J.O.Belakchin Nirmala,
W/o. David,
No.6/15, Thiruvalluvar Salai,
Kodungaiyur,
Chennai- 600 118.

2. Mr.David,
No.6/15, Thiruvalluvar Salai,
Kodungaiyur,
Chennai- 600 118. … Respondents/Defendants

AFFIDAVIT
I, V.Arumugam, S/o. Mr.Veerapathiran, aged about 72 years,

residing at No.177, Omsakthi Vinayakar Koil Street, T.H.Road,

M.R.Nagar, Kodungaiyur, Chennai- 600 118, do hereby solemnly affirm

and sincerely stated as follows;

1. I am the petitioner herein and the plaintiff in the above suit and I

am well aware of the facts and circumstances of the case.

2. I respectfully submit that I crave leave of this Hon’ble Court to

treat this affidavit filed along with the plaint as part and parcel of these

grounds.

3. I respectfully submit that I have filed the above suit for a

permanent injunction restraining the defendants, their men, agents,

servants, employees, representatives or any other person claiming

through or under them from entering into or disturbing the peaceful

possession and enjoyment of the plaintiff or anyone claiming under

them of schedule premises and also among other grounds raised in the

plaint, which may be referred to for better particulars.

4. I respectfully submit that it is in view of this I am filing this

petition for grant of an ad interim injunction restraining the

respondents from in any manner interfering with peaceful possession of

the petitioner schedule mentioned premises. I state that the balance of

convenience is in my favour as he is in lawful possession of the

premises and prays grant of an interim injunction since he is being

disturbed by the respondents with the help of men with muscle and

money power. In the alternative, no prejudice will be caused to the

respondents, since admittedly the respondents do not have any right

whatsoever to disturb the petitioner from the suit premises.

I, therefore humbly pray that this Hon’ble Court may be pleased to

grant an ad interim injunction restraining the respondents/defendants,

their men, agents, servants, employees, representatives or any other

person claiming through or under them from entering into or

disturbing the peaceful possession and enjoyment of the plaintiff or

anyone claiming under them of schedule premises, pending disposal of

the suit and render justice

Solemnly affirmed at Chennai, on this BEFORE ME

the 23rd day of April, 2015

And signed his name in my presence ADVOCATE, CHENNAI

 IN THE CITY CIVIL COURT AT MADRAS
I.A.No. of 2015
in
O.S. No. of 2015
V.Arumugam (M/72),
S/o. Mr.Veerapathiran,
No.177, Omsakthi Vinayakar Koil Street,
T.H.Road, M.R.Nagar,
Kodungaiyur, Chennai- 600 118. … Petitioner /Plaintiff
-Vs-
1. Mrs.J.O.Belakchin Nirmala,
W/o. David,
No.6/15, Thiruvalluvar Salai,
Kodungaiyur,
Chennai- 600 118.

2. Mr.David,
No.6/15, Thiruvalluvar Salai,
Kodungaiyur,
Chennai- 600 118. … Respondents/Defendants

PETITION UNDER ORDER XXXIX RULES 1 & 2 OF THE C.P.C

For the reasons stated in the accompanying affidavit, it is prayed

that this Hon’ble Court may be pleased to grant an ad interim injunction

restraining the respondents/defendants, their men, agents, servants,

employees, representatives or any other person claiming through or

under them from entering into or disturbing the peaceful possession

and enjoyment of the plaintiff or anyone claiming under them of

schedule premises, pending disposal of the suit and render justice.

Dated at Chennai on this the 23rd day of April, 2015.

Petitioner/Plaintiff Counsel for the Petitioner/Plaintiff

 SCHEDULE OF PROPERTY
All that part and parcel of the land measuring 660 sq.ft along
with house and shop bearing Door No.177, Om sakthi Vinayakar Koil
Street, T.H.Road, M.R.Nagar, Kodungaiyur, Chennai-600 118,

admeasuring north to south 60 feet, east to west 11 feet, east

admeasuring 660 square feet, or thereabouts comprised in Plot No.101
allotted by the Tamilnadu Slum Clearance Board vide allotment order
Se.Mu.No.909/96/A dated 26.07.1996, old S.No.100/3B, new
S.No.99/2 in Kodungaiyur Village, Chennai, together with common
pathway, 10*10 Toilet, Electricity connection, water and sewerage
connection thereon and being bounded in the:

North by: Land belongs to Muniyandi Devar,

South by: T.H.Road,
East by : 4 feet pathway and house belongs to my daughter
West by : Devid Songs School and shop

Situated within the registration district of Chennai-North and situated

within the Registration District of Chennai and Sub-Registration
District Sembium.

Admeasuring:

North to South : 60 feet;

East to West: 11 feet;

In all measuring 660 Sq. ft.,

Dated at Chennai on this the 23rd day of April, 2015.

Petitioner. Counsel for Petitioner