IN THE COURT OF THE CIVIL JUDGE

(JD) AT TUMKUR

CAVEAT PETITION NO. /2009

BETWEEN :

TUMKUR DISTRICT COFFEE & OTHER WORKERS UNION ®,

(CITU SPONSORED) NAZARABAD,
UNION OFFICE ROAD, TUMKUR- 572101
REG: NO: DRT (B1)T.U.A.S.R 22/97-98
REPRESENTED BY ITS SECRETARY.
SRI N.K. SUBRAMANYA …………………………………………CAVEATOR

AND :
SUGUNA POULTRY FARM LTD
S.F. NO: 34,
DEVARAJANAHALLI VILLAGE
BELLAVI HOBLI
TUMKUR TALUK-572107
KARNATAKA
REPRESENTED BY ITS PROPRIETORS
Mr SUNDAR RAJAN
Mr SOUNDER RAJAN……………………………..RESPONDENT

CAVEAT PETITION UNDER SECTION 148(A) READ WITH

SECTION 151 OF THE CIVIL PROCEDURE, 1908.

The Caveators in the above Caveat Petition most

respectfully submit, as follows:-

1. That, the addresses of the Parties for the

purpose of service of summons, notices, from this
Hon’ble Court is as set-out in the cause-title.
The Caveators may also be served through their
Counsels SRIDHARA BABU. N, ADVOCATE, LEGAL
DOCUMENTATIONS, G.K. ROAD, K.R. EXTENSION,
Tumkur-572101.

2. The Caveators submit that, they are

registered Trade Union espousing the cause of
exploited workers in various fields. The
caveators under Democratic rights and Legal
process through written representations and
suitable complaints are demanding humane
treatment of workers in the respondent hatchery
farm which is having more than 150 labourers. The
said labourers are active members of caveator
union.

3. The Caveators further submit that, since the

trade union has already filed complaint before
Labour officer about the labour law violations.
The respondent’s are trying lot of pinpricks to
suppress the law full demands by dividing the
workers unity through unlawful and unfair means.
On reliable information respondents are planning
to throw out enmasse workers that is members of
caveator union by filing Suit for Injunction or
other consequential relief/s before this Hon’ble
Court.

4. The Caveators are apprehended that, the

Respondent would file a Suit for Injunction
restraining the members of Caveator’s union from
entering the work place, thereby depriving
livelihood of all in order to suppress
illegalities. The respondents in turn want to
mis-utilise the ex-parte orders to suppress
workers entry to work place in the guise of civil
court orders. Hence, the Caveators pray that,
this Hon’ble Court may be pleased to cause notice
of any such Original Suit or Application that,
would be filed for grant of any Stay/injunction
to be served on the Caveators before such Suit
is heard and any Interim Order passed thereon.
If an interim Stay is granted against the
Caveators, the Caveators will be put to
irreparable loss and hardship, which can not be
compensated in terms of money or monies worth.
Hence, this Caveat Petition.
5. Postal Voucher for having issued the
aforesaid notice by registered post is affixed
hereunder.

6. That, the Fixed Court Fee is paid on Caveat

Petition.

WHEREFORE, in the above facts and

circumstances of the case it is most respectfully
prayed that, this Hon’ble Court may be pleased to
grant an opportunity of hearing to the Caveators
before granting any ex-parte interim order in
favour of the Respondent, in case, the Respondent
prefer any Suit or Petition in the interest of
justice and equity.

PLACE : Tumkur.
DATED: 15-04-2009 CAVEATOR

ADVOCATE FOR THE CAVEATOR

V E R I F I C A T I O N

I N.K.SUBRAMANYA, SECRETARY OF TUMKUR DISTRICT

COFFEE & OTHER WORKERS UNION ®, the Caveator, do
hereby state that what is stated above is true
and correct to the best of my knowledge, belief
and information.

CAVEATOR
 IN THE COURT OF THE CIVIL JUDGE
(JD) AT TUMKUR
CAVEAT PETITION NO. /2009

BETWEEN :
TUMKUR DISTRICT COFFEE & OTHER WORKERS UNION ®,
CAVEATOR
AND :
SUGUNA POULTRY FARM LTD ………..RESPONDENT

I N D E X

SL. NO. DESCRIPTION NO OF PAGES

1. CAVEAT PETITION UDNER

SECTION 148(A) OF
THE CODE OF CIVIL
PROCEDRUE, 1908. 1-3

2. POSTAL RECEIPT

3. VAKALATH

4. PROCESES MEMO alongwith Caveat Petition

PLACE: TUMKUR
DATED: 15-04-2009
ADVOCATE FOR CAVEATORS
 IN THE COURT OF THE CIVIL JUDGE
(JD) AT TUMKUR
CAVEAT PETITION NO. /2009

BETWEEN :
TUMKUR DISTRICT COFFEE & OTHER WORKERS UNION ®,
CAVEATOR
AND :
SUGUNA POULTRY FARM LTD ………..RESPONDENT

PROCESS MEMO

The caveator humbly prays this Hon’ble court to issue summons to

caveator if any suit / IA is filed in the interest of Justice. Necessary
process fee is paid herewith.

PLACE: TUMKUR
DATED: 15-04-2009
ADVOCATE FOR CAVEATORS
 IN THE COURT OF THE CIVIL JUDGE
(JD) AT TUMKUR
CAVEAT PETITION NO. /2009

BETWEEN :
TUMKUR DISTRICT COFFEE & OTHER WORKERS UNION ®,
CAVEATOR
AND :
SUGUNA POULTRY FARM LTD ………..RESPONDENT

MEMO

The caveator produces the postal receipt for having posted the caveat
petition copy to respondent.

PLACE: TUMKUR
DATED: 15-04-2009
ADVOCATE FOR CAVEATORS