IN THE COURT OF JUNIOR CIVIL JUDGE AT DELHI
O.S No._______ of 2021
John Martin Sharma S/o Ram Singh
R/o Janak Puri B-123, New Delhi ……… Plaintiff
Robert Frank Pandey S/o Deepak Kumar
R/o Janak Puri B-125, New Delhi ………Defendant
Suit for the Injunction On the use of Parking Space as a dumping area.
The Plaintiff submitted as under:
- The plaintiff is a resident of Janak Puri B-123 New Delhi, and the Defendant is a neighbour of the plaintiff.
- The plaintiff is the owner of parking space of 200sq yard which is used by him as a place for parking.
- The plaintiff who owns a Rolls Royce car worth of Rs. 4 Crore must be harmed by the garbage thrown by the defendant neighbour.
- That parking space is besides the house of the plaintiff, which is used by the resident of Janak Puri B-125 i.e. defendant as a dumping yard for the waste material of her house.
- That the Defendant was all the time throwing the waste material in that Parking space near the house of the plaintiff.
- Since a very long time of being used as a dumping yard by the defendant, there is a collection of huge waste material that leads to the health problem and damage to the car of the plaintiff.
- That the court has jurisdiction on this matter to fix an injunction on the use of Parking space as a dumping area as it restricts his free movement and also leads to affect health and cause damage to property due to defendant action.
It is Prayed that a decree for the injunction is passed in favour of the plaintiff against the defendant. And some other relief as the court thinks fit.
Advocate for the plaintiff Plaintiff
(Avinash Chaudhary) (John Martin Sharma )
I John Martin Sharma, do hereby verify that the contents of the paras no. 1,2,3,4 and 5 are true to my knowledge and the contents of remaining paras are according to legal advice from my advocate which I believe to be true.
Place: Janak Puri B-123 Plaintiff
Date: 26/04/2021 (John Martin Sharma)