Draft a petition for prevention of Oppression & Mismanagement u/s 241 of The Companies Act, 2013 with NCLT. Assume facts.

Petition for prevention of Oppression & Mismanagement u/s 241 of The Companies Act, 2013 with NCLT Before the NCLT, New Delhi In the matter of XYZ Garments having its Registered office at ............, Delhi And Mr. P s/o. ............ r/o ............ Mr. Q s/o. ............ r/o ............ Mr. R s/o. ............ r/o ............ Petitioners Vs. Mr. D s/o. ............ r/o ............ Mrs. D w/o ............ r/o............ Respondents The petitioners submit as under: That XYZ is a registered company under the provisions of the Companies Act having its Head office a Delhi. That P,Q& R are the shareholders of the company having an aggregate shareholding of 40%, i.e., more than 10% required to file this petition. That Mr. D and Mrs. D have gained interest in a new company and are diverting the orders of XYZ to new company which is detrimental to the interests of XYZ Ltd. XYZ in their Annual General Meeting held on .......... have removed Mr. & Mrs. D from Directorship of the Company after following the process laid by law. Certified copies of minutes and returns filed with the Registrar of Companies are enclosed. That the petitioner feels that the oppressive methods of respondents should be stopped forthwith. The petitioners have already suffered irreparable loss. In view of above this petition is filed to seek appropriate orders restraining Mr. and Mrs. D to act as Director of the company and to prevent them to continue with their oppressive methods. The petition has been made bona fide in interest of justice. Affidavit verifying the petition is annexed. Prescribed filing fee of ₹............ is enclosed. It is hereby prayed that : An order may be issued preventing Mr. and Mrs. D from continuing to their oppressive methods. Any other order that this Hon'ble Tribunal may think fit & proper in the circumstances of the case. For & on behalf of petitioner Place: ............ Date: ............ Sd/-