RESTORATION OF MOVABLE PROPERTY THREATENED WITH DESTRUCTION AND FOR AN INJUNCTION
IN THE COURT OF_____________ (add detail court)
_________________ (suppose A.B.)(add description and residence).
__________________ (suppose C.D.)(add description and residence) . . .
A. B., the above-named plaintiff, states as follows:-
- Plaintiff is, and at all times hereinafter mentioned was, the owner of [a portrait of his grandfather ?which was executed by an eminent painter], and of which no duplicate exists [or state any facts showing that the property is of a kind that cannot be replaced by money].
- On the________ day of________19___ he deposited the same for the safe-keeping with the defendant.
- On the________day of________ 19___ , he demanded the same from the defendant and offered ?to pay all reasonable charges for the storage of the same.
- The defendant refuses to deliver the same to the plaintiff and threatens to conceal, dispose of, cut ?or injure the same if required to deliver it up.
- No pecuniary compensation would be an adequate compensation to the plaintiff for the loss of the [painting].
- [Facts showing when the cause of action arose and that the Court has jurisdiction.]
- The Value of the subject-matter of the suit for the purpose of jurisdiction is ____rupees and for the purpose of court-fees is________rupees.
- The plaintiff claims:-
- that the defendant be restrained by injunction from disposing of, injuring or concealing the said [painting];
- that he be compelled to deliver the same to the plaintiff.