SUIT FOR DAMAGES AND INJUNCTION FOR OBSTRUCTING A RIGHT TO USE WATER FOR IRRIGATION
IN THE COURT OF THE....................
Suit No..................... of 19....................
C. D.................................................................... Plaintiff
versus 
C. F................................................................. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. The plaintiff is, and was at the time hereinafter mentioned, possessed of certain lands situate, etc., and entitled to take and use a portion of the water of a certain stream for irrigating the said lands.
2. On the.................... day of.................... 19..................... the defendant prevented the plaintiff from taking and obstructing and diverting the said stream.
3. The plaintiff verbally requested the defendant not to do so and also gave a registered notice dated.................... received by the defendant on.................... 19..................... requesting him to restrain himself from doing any further the wrongful act aforesaid, and also to tender Rs..................... as damages for his wrongful act already committed and damage caused to the plaintiff. The reply of the defendant denying his liability was received by the plaintiff on............. 19..............
4. The defendant is liable to be restrained by issue of a permanent prohibitory injunction and to pay damages to the plaintiff for the wrongful act already committed and damage caused to the plaintiff as aforementioned.
5. The cause of action arose on.................... 19.................... within jurisdiction of this Court when the defendant first committed the wrongful act, secondly on.................... 19.................... when the defendant received the notice of the plaintiff and lastly on.................... 19.................... when the plaintiff received the reply of the defendant denying his liability.
6. The suit is valued at Rs...................... the amount of damages claimed and Rs..................... for the purposes of issuing injunction, and Court, fee is paid on both the reliefs accordingly.
RELIEFS CLAIMED:
The Plaintiff claims the following reliefs:
(i) The Defendant be restrained by issuing a permanent injunction restraining the defendant from interfering into the right of the plaintiff by preventing the plaintiff in any way from taking and using the said portion of the said water.
(ii) Payment of Rs..................... as damages for the wrongful act of the defendant already done and damage caused to the plaintiff.
Plaintiff 
Through Advocate 
VERIFICATION
I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true.
Verified on this................. day of.................... 19.................... at....................
Plaintiff