Dear Experts ,
i need all of your advise for drafting a reply of O 39 Rule 1,2 application of injunction.
facts of the application are as follows-\
1.the defendent is sole owner of the built up structure i.e residential as well as commercial building from year 1991 when he got mutation on his favour vide a registered sale deed.
2.before it his father and grand father was on possession of this land through mortage.
3.the plaintiff get ad interim injunction few days ago and filed a case for possession .
4.there is some problem with revenue enteries as they were entered wrong during the mutation in year 1991 after purchasing the said land by the defendent.in mutation in owner column defendent name is entered and in posession column defendent with two other persons is wrongly entered in year 1991 jamabundi.there was no name of thes two co posessioners before year 1991 and they were never remained in posession of the said suit land and at present time the defendent is still continuing his posession in this built up structure ie built in year 1992.
5.the defendents are not constructing nor making any structure they are just converting interior decoration for opening a bank branch.
the applicant had taken the ad interim injunction only on the base of these wrong enteries and causing defendent a huge loss of about 50 000 rs per month and more as bank will shift to another location .
i request you to help me in making the reply of this injunction so that ad interim injunction will break down .kindly support few citation in support.
