Drafting an application for temporary injunction, faster

An application for temporary injunction is one of those filings where the structure is settled but the work is real. Everything turns on whether you've built the prima facie case cleanly, shown the balance of convenience, and pleaded irreparable injury with the authority to back each limb — and then said it in a way the court can grant. Marshalling the facts and the case law against that three-fold test is the part I wanted Miss Lucy to take a first pass on.

This is written for civil practitioners, not as a lecture on Order 39. You know the test; the point here is the drafting workflow.

What an injunction application usually needs

Under Order 39 Rules 1 and 2, the application has to make out a prima facie case, show that the balance of convenience favours your client, and establish that refusal would cause irreparable injury — each supported by the pleaded facts and, where it matters, by authority. The prayer has to ask for the specific restraint you want. The pieces are standard; building all three limbs convincingly on the facts of this matter is the work.

Where the time actually goes

The slow part is two-fold: pleading each limb of the test so it's actually established and not merely asserted, and finding the case law on the kind of injunction you're seeking — restraining alienation, infringement, dispossession, whatever it is — on facts near enough to yours. Research and drafting, side by side, against a test that's easy to state and harder to satisfy.

How Miss Lucy fits in

You give her the facts and what your client needs restrained, in plain English. She comes back with relevant case law — citations checked against the actual reporters, not invented — and a first draft that pleads the three-fold test and frames the prayer. You edit and tighten from a draft instead of starting cold, and she holds the context when you come back to the matter.

She is a tool, not a substitute for your judgment — the draft is a starting point you review and own. But for getting an injunction application built against its test, it saves the long part of the day.

Related: Specific Relief Act, 1963 — injunctions & specific performance

Try it on a real matter

The honest test is your own file. There's a free trial, no card needed — take an injunction matter you're actually working on and see whether the first draft saves you the time.

Try Miss Lucy free →