Sample Reply of Defendant to Application under Order 39 Rules 1 & 2 and Section 151 CPC

IN THE COURT OF CIVIL JUDGE (SENIOR DIVISION) AT [PLACE]

Title Suit No. ___ of 2023

Plaintiff: [Name of Plaintiff]

Defendant: [Name of Defendant]

REPLY OF THE DEFENDANT TO THE APPLICATION UNDER ORDER 39 RULES 1 & 2 AND SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908

The Defendant above-named most respectfully submits as follows:

1. That the present application filed by the Plaintiff is wholly misconceived, baseless, and not maintainable in the eyes of law.
2. That the Plaintiff has no prima facie case in his favour and the balance of convenience is also not in his favour.
3. That the Plaintiff has suppressed material facts from this Hon'ble Court and has approached the Court with unclean hands.
4. That the Defendant is the lawful owner and possessor of the suit property and the Plaintiff has no right, title, or interest therein.
5. That no irreparable loss or injury would be caused to the Plaintiff if the injunction is not granted.
6. That the application has been filed solely with a view to harass the Defendant and to create a false cause of action.

It is, therefore, most respectfully prayed that this Hon'ble Court may be pleased to dismiss the application of the Plaintiff with costs and pass such other order(s) as this Hon'ble Court may deem fit and proper.

Place: [Place]
Date: [Date]

Counsel for the Defendant