Public Nuisance

Mr………………………….., the above-named plaintiff, states as follows :

1.	The defendant has wrongly heaped up each and stones on a public road know as …………… street at ………… so as to obstruct the passage, of the public along the same and threatens and intends, unless restrained from so doing to continue and repeat the said wrongful act.

2.	[Facts showing when the cause of action arose and that Court has jurisdiction.]

3.	The value of the subject-matter of the suit for the purpose of jurisdiction is ………… rupees and for the purpose of court fee is …….. rupees.

4.	The plaintiff claims -

(1)	a declaration that the defendant is not entitled to obstruct the passage of the public along the said public road;

(2)	an injunction restraining the defendant from obstructing the passage of the public along the said public road and directing the defendant to remove the  earth and stones wrongfully heaped up as aforesaid.