Restoration Of Movable Property Threatened With Destruction And For Aninjunction Drafting Plaints 881 - Legal Draft

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

1.       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.

2.       On the ....................... day of ................ 20...... deposited the same for safe-keeping with the defendant.

3.       On the ................... day of ................. 20 ....... 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;

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

7.       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.

1.       The Plaintiff claims -

a.       That the defendant be restrained by injunction from disposing of, injuring for concealing the said planning;

b.       That he be compelled to deliver the same to the plaintiff.