Draft a plaint in a suit for demolition of construction made by the defendant on the plaintiff's vacant land. The plaintiff seeks to obtain possession as well as temporary injunction restraining the defendant. Assume nam

In the court of Civil Judge at............ Suit No. ............ of............ XY, s/o............ resident of............ Plaintiff Versus YZ, s/o............ resident of............ Defendant Most respectfully sayeth: 1. That the plaintiff is the owner in possession of land comprising in khata, khatauni No. ............ situated at............ 2. That plot No. ............ given at the foot of the plaint lies in possession. 3. That the said plot had been lying vacant for a very long time and the plaintiff used it occasionally. 4. That the cause of action accrued to the plaintiff on............ 5. That the defendant has built a house comprising two rooms without any permission or consent of the plaintiff. 6. That the defendant has absolutely no title to the said plot of land and his act is wholly unauthorised and illegal. 7. That the defendant has refused to vacate the said land and to demolish the house when asked by the plaintiff. 8. That the value of the suit for the purposes of jurisdiction has been fixed at Rs............ And for the purposes of declaration and correct and authorised court fee stamp Rs............ have been affixed on the plaintiff. 9. That no suit has been instituted against the defendant on the same or similar cause of action in any other court including High Court and Supreme Court of India. It is therefore, most respectfully prayed that the possession of the land in the suit be given to the plaintiff through decree of the court with directions to the defendant to pull down and remove the house and restore the land to its formal condition within a period specified by the court and other relief as the court thinks fit and suitable. And for this act of kindness, the humble plaintiff as in duty bound and shall ever pray. Plaintiff Through Advocate Boundaries of the Plot No............ East............ West............ North............ South............ Verification I, ............ declare that the contents of paras 1-9 of the plaint are true to my knowledge and belief. Verified at............ on............ XY AB Advocate