Restoration Of Movable Property Threatened With Destruction, And For An Injunction Legal Draft Template

<h2>A.B., </h2>the above-named plaintiff, states as follows:-1. Plaintiff is, and at

all times hereinafter mentioned was, the owner of [ aa portrait of his

grand-father 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].2. On the .......day of

.........19...., he deposited the same for safe-keeping with the defendant.3. 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.4. 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.5. No pecuniary

compensation would be an adequate compensation to the plaintiff for the loss of

the ( painting ).[

As in paras.6 and 7 of Form No.1.]1.2.3.4.5.6.7.8. The plaintiff claims-1. that the defendant be

restrained by injunction from disposing of, injuring or concealing the said [

painting ];2. that he be compelled

to deliver the same to the plaintiff.