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Injuntion Application Zorro

The plaintiff, Mubeen Enterprises, has filed a suit against M/S ORO Industries for defamation, seeking a declaration, permanent injunction, and damages. The application requests a temporary injunction to prevent the defendant from continuing a defamatory campaign against the plaintiff, which includes public allegations made in a newspaper advertisement. The plaintiff argues that they have a strong case and will suffer irreparable harm if the defendant's actions are not restrained.

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Waseem Ali
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26 views3 pages

Injuntion Application Zorro

The plaintiff, Mubeen Enterprises, has filed a suit against M/S ORO Industries for defamation, seeking a declaration, permanent injunction, and damages. The application requests a temporary injunction to prevent the defendant from continuing a defamatory campaign against the plaintiff, which includes public allegations made in a newspaper advertisement. The plaintiff argues that they have a strong case and will suffer irreparable harm if the defendant's actions are not restrained.

Uploaded by

Waseem Ali
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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IN THE COURT OF DISTRICT JUDGE EAST AT KARACHI

Suit No: _____/2024

Mubeen Enterprises, Sole Proprietorship,

Muhammad Hanif S/O Saleh Muhammad ................. Plaintiff


Versus
M/S ORO INUDSTRIES ...........................
Defendant

APPLICATION UNDER ORDER XXXIX RULES 1 & 2


READ WITH SECTION 151 CPC

Respectfully Sheweth:

1. That the plaintiff has filed the accompanying suit for declaration, permanent

injunction, damages for defamation against the defendant before this Hon’ble

Court,

2. That the plaintiff craves leave of this Hon’ble Court and prays that the

contents and annexure of the accompanying plaint/suit may kindly be read as

part and parcel of this application as those are not being repeated herein for

the sake of brevity.

3. That the defendant has a reputation of building barriers, creating hurdles by

dragging the competition through unnecessary litigation, false cases and

oppositions.

4. That defendant has now crossed all the limits and borders of business ethics

by publically defaming the plaintiff and leveling serious allegations the

plaintiff through the advertisement dated 21-08-2024 in the Jang newspaper.


5. That the defendant is hell bent upon using all the measures to defame the

competitors and the plaintiff in a bid to lower the reputation of their business,

person, and the goodwill earned by them. Defendant has repeatedly shown

his willingness to go to extreme lengths to defame the competitors, plaintiff

in particular.

6. That the there is great apprehension that defendant will continue to attack

the reputation by publishing such like advertisement in the nationwide

newspapers and that defendant will not stop the defamatory campaign

against the plaintiff.

7. That this application meets all the criteria for grant of temporary injunction as

interim injunction is by defintion a preventive remedy with the object of

preventing irreparable loss/damage to the parties in a suit.

8. That the plaintiff has a good prima facie case in his favor and against the

defendant and is likely to succeed therein.

9. That the balance of convenience also lies in favor of the plaintiff and against

the defendant.

10.That the plaintiff and the business shall suffer irreparable loss if the

defendant is not restrained and prohibited from the illegal defamatory

campaign.

Therefore, It is therefore respectfully prayed that during the pendency of the


accompanying suit the defendant, their agents, servants, relatives etc. may kindly
be restrained from running further defamatory campaign or running such like
advertisement contain the name of plaintiff, it’s business or its products and it’s
intellectual property by passing an interim injunction in favor of the plaintiff.

Plaintiff
Advocate for plaintiff

Karachi

Dated: ....................

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