Draft Suit For Injunction
Draft Suit For Injunction
MEMO OF PARTIES.
1. ABC P. Limited
(Office Address) Plaintiff
VERSUS
2. Mr. X
(Residential Address) Defendant No. 1
3. EGF P. Ltd.
(Office Address) Defendant No. 2
IN THE COURT OF____________, ____________
6. That pursuant thereto, the Defendant No. 1 was asked to resign from
the Plaintiff Company. Subsequently the Defendant No. 1 gave his
resignation on 01.12.2021 giving one month’s notice and stating that
31.12.2021 would be his last working day. But to the surprise of the
Plaintiff Company, the Defendant No. 1 stopped attending the office
of the Plaintiff Company from 10.12.2021. the Plaintiff Company
tried contacting Defendant No. 1 but he had changed his number and
email address.
12. That in case the present application is not allowed then the grave
prejudice will be caused to the Plaintiff. Therefore, it is humbly
requested before this Hon’ble Court to grant the relief of damages to
the tune of _________ along with interest and mandatory injunction
to restrict the Defendant No. 2 Company from poaching any more
agents/distributors from the Plaintiff No. 1 Company.
13. That the balance of convenience also lies in the favour of the Plaintiff
and against the Defendants.
14. That there are adequate grounds for grant of ad interim mandatory
injunction in favour of the Plaintiff. The present application is being
bona fide and in the interest of justice.
15. Grave irreparable loss would be caused to the Plaintiff which can not
be compensated only in terms of money.
PRAYER
In view of the facts of the circumstances stated above this Hon’ble Court
and in favour of the Plaintiff restrain from poaching any more any
d) Any other relief (s) as this Hon’ble Court may deem just, fit and
PLAINTIFF