Interim injunction application with the three classic grounds – prima facie case, balance of convenience and irreparable loss – plus supporting affidavit.
When to use this draft
File with, or immediately after, the plaint where the subject matter must be preserved until the suit is decided.
Essential contents
- Prima facie arguable case on the pleaded facts
- Balance of convenience in favour of the applicant
- Irreparable loss not compensable in money
- Affidavit in support sworn before an Oath Commissioner
- Prayer for ad-interim relief till decision of the application
Drafting notes
- Address all three ingredients separately with headings - courts look for each.
- Ask for ad-interim relief in a distinct paragraph so it can be granted the same day.
- Where status quo is sought, define precisely what state of affairs is to be preserved.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.