The plaintiff most respectfully submits that the impugned actions of the defendant are not only arbitrary but also contrary to the established principles of natural justice. The defendant has acted in a manner that is illegal, mala fide, and without jurisdiction. The plaintiff has fulfilled all his obligations in accordance with the said agreement, but the defendant has failed to perform his part. The actions of the defendant have resulted in financial loss and mental harassment to the plaintiff. Several notices were served upon the defendant, but no reply was received. Under these circumstances, the plaintiff has no other option but to approach this Hon’ble Court seeking appropriate relief, including compensation and specific performance of the contract. The plaintiff respectfully submits that he is the lawful owner of the suit property and has been in peaceful possession of the same for the last several years. The defendant, without any legal right or authority, has attempted to interfere with the possession of the plaintiff. Despite repeated requests and warnings, the defendant did not stop his illegal activities. The cause of action arose when the defendant tried to encroach upon the property and threatened to dispossess the plaintiff. It is therefore prayed that this Hon’ble Court may kindly grant a decree of permanent injunction in favor of the plaintiff and restrain the defendant from causing any further interference. That the Plaintiff is a law-abiding citizen and the absolute owner and in peaceful possession of property bearing Municipal No. 45, situated at Civil Lines, Moradabad (hereinafter referred to as the “suit property”). That the Plaintiff purchased the suit property through a registered Sale Deed dated 12.03.2015, and since then has been residing therein along with his family members without any interference. That the Defendant is the owner of the adjacent property bearing Municipal No. 46 and has recently started raising illegal construction beyond his boundary, thereby encroaching upon a portion of the Plaintiff’s land. That the Plaintiff came to know about such illegal encroachment on 05.01.2026, when the Defendant began construction of a boundary wall extending approximately 2 feet into the Plaintiff’s property. That the Plaintiff immediately objected to such unauthorized construction and requested the Defendant to stop the same. However, the Defendant paid no heed and continued with the illegal activities. That the Plaintiff also approached the local municipal authorities and lodged a complaint dated 10.01.2026, but no effective action has been taken so far. That the Defendant’s actions are illegal, arbitrary, and in violation of the Plaintiff’s lawful rights. The same has caused mental agony and financial loss to the Plaintiff. That the cause of action first arose on 05.01.2026 and continues to subsist as the Defendant is still threatening to complete the illegal construction. That this Hon’ble Court has the jurisdiction to entertain and try the present suit as the suit property is situated within the territorial limits of this Court. That the suit is valued for the purposes of court fees and jurisdiction at Rs. 50,000/- and appropriate court fees have been affixed herewith. In view of the above facts and circumstances, it is most respectfully prayed that this Hon’ble Court may be pleased to pass a decree of permanent injunction restraining the Defendant, his agents, servants, or any person acting on his behalf from encroaching upon or interfering with the Plaintiff’s peaceful possession of the suit property, direct the Defendant to remove the illegal construction raised on the Plaintiff’s land, award damages of Rs. 50,000/- in favour of the Plaintiff for the loss and mental harassment suffered, grant any other relief which this Hon’ble Court may deem fit and proper in the interest of justice. The plaintiff most respectfully submits that the impugned actions of the defendant are not only arbitrary but also contrary to the established principles of natural justice. The defendant has acted in a manner that is illegal, mala fide, and without jurisdiction. The plaintiff has fulfilled all his obligations in accordance with the said agreement, but the defendant has failed to perform his part. The actions of the defendant have resulted in financial loss and mental harassment to the plaintiff. Several notices were served upon the defendant, but no reply was received. Under these circumstances, the plaintiff has no other option but to approach this Hon’ble Court seeking appropriate relief, including compensation and specific performance of the contract. The plaintiff respectfully submits that he is the lawful owner of the suit property and has been in peaceful possession of the same for the last several years. The defendant, without any legal right or authority, has attempted to interfere with the possession of the plaintiff. Despite repeated requests and warnings, the defendant did not stop his illegal activities. The cause of action arose when the defendant tried to encroach upon the property and threatened to dispossess the plaintiff. It is therefore prayed that this Hon’ble Court may kindly grant a decree of permanent injunction in favor of the plaintiff and restrain the defendant from causing any further interference. That the Plaintiff is a law-abiding citizen and the absolute owner and in peaceful possession of property bearing Municipal No. 45, situated at Civil Lines, Moradabad (hereinafter referred to as the “suit property”). That the Plaintiff purchased the suit property through a registered Sale Deed dated 12.03.2015, and since then has been residing therein along with his family members without any interference. That the Defendant is the owner of the adjacent property bearing Municipal No. 46 and has recently started raising illegal construction beyond his boundary, thereby encroaching upon a portion of the Plaintiff’s land. That the Plaintiff came to know about such illegal encroachment on 05.01.2026, when the Defendant began construction of a boundary wall extending approximately 2 feet into the Plaintiff’s property. That the Plaintiff immediately objected to such unauthorized construction and requested the Defendant to stop the same. However, the Defendant paid no heed and continued with the illegal activities. That the Plaintiff also approached the local municipal authorities and lodged a complaint dated 10.01.2026, but no effective action has been taken so far. That the Defendant’s actions are illegal, arbitrary, and in violation of the Plaintiff’s lawful rights. The same has caused mental agony and financial loss to the Plaintiff. That the cause of action first arose on 05.01.2026 and continues to subsist as the Defendant is still threatening to complete the illegal construction. That this Hon’ble Court has the jurisdiction to entertain and try the present suit as the suit property is situated within the territorial limits of this Court. That the suit is valued for the purposes of court fees and jurisdiction at Rs. 50,000/- and appropriate court fees have been affixed herewith. In view of the above facts and circumstances, it is most respectfully prayed that this Hon’ble Court may be pleased to pass a decree of permanent injunction restraining the Defendant, his agents, servants, or any person acting on his behalf from encroaching upon or interfering with the Plaintiff’s peaceful possession of the suit property, direct the Defendant to remove the illegal construction raised on the Plaintiff’s land, award damages of Rs. 50,000/- in favour of the Plaintiff for the loss and mental harassment suffered, grant any other relief which this Hon’ble Court may deem fit and proper in the interest of justice. Submit