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Plaint Before The Senior Civil Judge or District Judge at Trivandrum

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Mukesh Tomar

1) Arjun Nair has filed a suit against his neighbor Sandeep Thomas seeking an injunction to stop a cloth washing and coloring business being operated illegally out of Thomas' apartment. 2) Thomas began this commercial operation on August 1st 2020 without permission, and it is causing waste water to flow past Nair's home and is a nuisance. 3) Despite complaints, authorities have not stopped the illegal activity. Nair seeks a court order permanently restraining Thomas from continuing the commercial operation.

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Plaint Before The Senior Civil Judge or District Judge at Trivandrum

Uploaded by

Mukesh Tomar
130 views3 pages
1) Arjun Nair has filed a suit against his neighbor Sandeep Thomas seeking an injunction to stop a cloth washing and coloring business being operated illegally out of Thomas' apartment. 2) Thomas began this commercial operation on August 1st 2020 without permission, and it is causing waste water to flow past Nair's home and is a nuisance. 3) Despite complaints, authorities have not stopped the illegal activity. Nair seeks a court order permanently restraining Thomas from continuing the commercial operation.

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1) Arjun Nair has filed a suit against his neighbor Sandeep Thomas seeking an injunction to stop a cloth washing and coloring business being operated illegally out of Thomas' apartment. 2) Thomas began this commercial operation on August 1st 2020 without permission, and it is causing waste water to flow past Nair's home and is a nuisance. 3) Despite complaints, authorities have not stopped the illegal activity. Nair seeks a court order permanently restraining Thomas from continuing the commercial operation.

Copyright:

© All Rights Reserved
Download as DOC, PDF, TXT or read online from Scribd
Download as doc, pdf, or txt
130 views3 pages

Plaint Before The Senior Civil Judge or District Judge at Trivandrum

Uploaded by

Mukesh Tomar
1) Arjun Nair has filed a suit against his neighbor Sandeep Thomas seeking an injunction to stop a cloth washing and coloring business being operated illegally out of Thomas' apartment. 2) Thomas began this commercial operation on August 1st 2020 without permission, and it is causing waste water to flow past Nair's home and is a nuisance. 3) Despite complaints, authorities have not stopped the illegal activity. Nair seeks a court order permanently restraining Thomas from continuing the commercial operation.

Copyright:

© All Rights Reserved
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PLAINT

BEFORE THE SENIOR CIVIL JUDGE OR DISTRICT JUDGE AT


TRIVANDRUM

CIVIL SUIT NO. 84 OF 2020

IN THE MATTER OF:

Arjun Nair, son of Shri Bhagirath Nair aged about 25 Years R/o S-20/43, Shree
Raj Complex, Sastamangalam, Trivandrum

..... Plaintiff
Versus

Sandeep Thomas, son of Shri Nagendra Thomas aged about 45 R/o B- 8/23,
Krishna Society, Kowliam, Trivandrum

.....Defendant

SUIT FOR INJUNCTION AGAINST NUISANCE

MOST RESPECTFULLY SHOWETH:

1. That the plaintiff is a business man residing at S-20/43, Shree Raj Complex,
Sastamangalam, Trivandrum.

2. That the Defendant is the owner and in possession of Flat No 205 at R/o B-
8/23, Krishna Society, Kowliam, Trivandrum.

3. That on 1 August, 2020, the Defendant has erected upon his aforesaid plot a
cloth washing and colouring unit, which is illegal as per the notification passed
by the Municipal Council and and per Environment law. In the said colouring
unit the Defendant is engaged in washing clothes using machines, colouring it
with the help of machines and use huge quantity of water in the residential
area. As a result huge quantity of waste water is being flowing through the
front side of the house of Plaintiff.

4. The Defendant is using the Flat for commercial purpose without seeking
permission from any authority.

5. That the Plaintiff has sent several complaints to the public authorities to stop
this nuisance and illegal activity, but in vain.

6. That on account of the use of Flat by the Defendant for commercial purpose,
Plaintiff has been unable to peacefully reside in the house.

7. That cause of action has arose on 1 August, 2020 and continues to exist even
at present with use of the Flat for the aforesaid unlawful purpose.

8. That the suit property is situated within the Jurisdiction of this Hon’ble
Court. Having regard to the cause of action, narrated above, this Hon’ble Court
has the Jurisdiction to entertain any try this Suit.

9. The Plaintiff accordingly claims that the Defendant be restrained by way of


decree of injunction from using the suit Flat as a Commercial Property thereby
committing or permitting, any further nuisance.

10. In the facts and circumstances of case mentioned herein above this Hon’ble
Court may graciously be pleased to:

Prayer

That the Plaintiff, therefore, pray that this Hon'ble Court may pass -
a) A decree restraining the Defendant Permanently from operating his Cloth
Washing and Coloring unit from Flat No 205 at R/o B- 8/23, Krishna Society,
Kowliam, Trivandrum.

b) Any other relief, which the Hon'ble court deems fit, may please be granted to
the plaintiff in the interest of justice.

PLAINTIFF THROUGH

Date: 22 August, 2020 ………..........

Place: Trivandrum, Kerala Plaintiff

…….………..

Pleader

VERIFICATION

I, Arjun Nair, the above named Plaintiff states on solemn affirmation that
contents of Para 1 to 10 of the Plaint are true and correct to the best of my
knowledge and belief and those of legal averments are true and correct on the
basis of legal advice received and believed to be true by me.

Date: 22 August, 2020 ………..........

Place: Trivandrum, Kerala Plaintiff

…….………..

Pleader

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