How to use AI to draft a temporary injunction application in a civil case smartly

In this article, you will discover how to draft a temporary injunction application using AI, which will transform your late-night panic into confident 20-minute deliveries. This step-by-step guide will teach you a strategic prompting technique that helps lawyers handle emergency legal drafting with precision, covering everything from legal principles to court-ready applications that impress not just your seniors but also your clients.

Introduction

It was late at night when I came back home after a hectic day of work, and I received a WhatsApp message from my senior that said,

“Urgent. Need an injunction application draft for Anil Sharma’s case tomorrow in the morning.”

I called the client, who said there was some illegal construction that was about to start in a couple of days, and we need an urgent order to restrain his neighbour from doing so. 

He asked me if I could make the draft by tomorrow morning. 

I do not know about you, but earlier I used to panic in such situations, but not anymore.

I told him I would draft the application in 20 minutes.

You should have heard the shock on the other end.  “Wait..20 minutes?! How?”

Simple. I had AI on my side.

It is not some fancy sci-fi stuff. 

It is a tool that understands the law and helps you structure your thoughts in no time, and if you provide apt prompts, it can do everything for you. 

To be honest with you, AI takes care of the major work and leaves you with a legal draft that is ready for court, but you will need to make minor adjustments.

Obviously, you still need to know your law. You still need to use your mind.

Are you curious to know how it works?

Let me break it down for you step by step so the next time you get that message or your client makes such a request, you will know exactly what to do.

Before that, l will teach you a bit of basics about injunction before showing you the process. 

Starting with what an injunction is.

What is an injunction?

Put in simple terms, it is an order of the court restraining a party from doing a specific act or compelling them to carry out a certain action. 

They can be temporary or permanent in nature. In this article, we will deal with temporary injunctions. But let us understand the difference. 

What are the types of injunctions?

So basically, there are mainly two main types of injunctions:

1. Temporary Injunctions

A temporary injunction is a temporary relief granted by the court to preserve the subject matter of the dispute until further orders or final orders are passed in the suit.

2. Permanent Injunctions

A permanent injunction is a final relief granted by the court, requiring a party to perform a certain act and also restraining a party from committing a specific act indefinitely. Unlike a temporary injunction, which is only for a limited period, a permanent injunction is issued after the final judgment in the suit and remains in force until it is overturned by a higher court.

I have provided a table below that demonstrates the key differences between these two types for easy understanding.

Key differences between temporary and permanent injunction

Aspect	Temporary Injunction	Permanent Injunction
Duration	Until further orders or final judgment	Indefinitely, until it is overturned by a higher court.
When Granted	At any stage of the suit	Only after the final hearing
Purpose	Prevent immediate harm	Provide final relief
Legal Basis	Section 37(1) of the Specific Relief Act read with Order XXXIX of the Civil Procedure Code, 1908	Sections 37(2) and 38 of the Specific Relief Act

For those of you who are students or fresh advocates, it is essential for you to understand the provisions that govern a temporary injunction.

What are the legal provisions governing a temporary injunction?

The following legal provisions primarily govern temporary injunctions.

1. Section 37(1) of the Specific Relief Act, 1963 
2. Order XXXIX of the Code of Civil Procedure, 1908 (CPC) 

Now that you have a fair understanding of the legal provisions that govern injunctions, the courts, over time, have laid down certain principles that are equally important to learn.

What are the principles that govern a temporary injunction?

I will explain those principles to you using a Supreme Court judgment.

Basically, an application for the grant of a temporary injunction is governed by the principles of law laid down by the Supreme Court in the case of Dalpat Kumar & Anr. v. Prahlad Singh & Ors. [(1992) 1 SCC 719], wherein the Court held that a temporary injunction is a discretionary power and can be granted when the court is satisfied of the following:

1. Prima facie case – This means that the applicant has to demonstrate a strong case at the first instance, that the court is inclined to grant relief in favour of the applicant.
2. Irreparable injury – The applicant must show that if the order of injunction is not passed in his favour, then grave loss, harm, and injury will be caused to the applicant that is irreparable and cannot be compensated in terms of money.
3. Balance of convenience – The applicant must lastly show that the applicant would suffer more harm than the respondent if the order of injunction is not passed in favour of the applicant.

Let us now move on to the drafting bit using AI.

How to use AI to draft a temporary injunction application?

I am going to use ChatGPT to draft this injunction application. You can prefer using any other AI tool as well. 

I will give an explanation after each step in red so that you understand how to use and how not to use AI to draft.

STEP 1: 

Here, I am going to tell GPT as follows:

“I am a lawyer and I have to draft an application for a temporary injunction and the same has to be filed in the Bombay High Court. What information do you require from me to draft the application?”

Explanation: If you look at the instructions given to ChatGPT, you will see that they are tailored to my specific needs. I also ask ChatGPT to ask me questions about what information it requires to draft the application. If I had given basic instructions like draft a temporary injunction, then it would have generated only a template for me. So it is necessary to give specific instructions. Additionally, you should not dump the full story or facts of your case all at once and expect a miracle to happen. It is important to go step by step.

STEP 2: 

ChatGPT asked me certain questions, and I systematically answered them to avoid any confusion. 

These were the questions that ChatGPT generated based on the prompt that I gave and accordingly, my answers to those questions. 

Explanation: Once ChatGPT provides you with a list of questions, you don’t have to blindly copy and paste the entire set of facts into that chat; that is exactly where most people go wrong. Instead, you should answer each question one by one, and the answers should not be vague. This will help AI to understand the context properly, and the draft generated will not be half-baked and in a template format. 

STEP 3: 

ChatGPT generated the draft of the application. While the draft captures the structure, there is definitely scope for refining certain aspects in order to make it more persuasive. 

Here is the first draft that ChatGPT generated

After reading through the first draft, I gave the following prompt: 

1. “Add a statement that, since this application is filed during the pendency of the suit, the Plaintiff relies upon the facts mentioned in the suit for the sake of brevity instead of repeating all the facts. However, the facts of the case can be mentioned briefly.
2. Add a statement about the nature of the suit and what relief is sought in the suit against the Defendant. The suit is filed for a mandatory and permanent injunction against the Defendant to direct the removal of unauthorized construction, and permanently restrain the Defendant from carrying on unauthorized construction on the Plaintiff’s land.
3. Remove the headings and make it into continuous paragraphs numerically
4. Wherever any document is referred to, mention it as hereto annexed and marked Exhibit A, and so on. 
5. You also need to show urgency in the matter that requires filing this application.
6. Correlate the grounds to the facts of the case.”

Explanation: Once ChatGPT has generated the first draft, you must accept it as a good starting point and do not make the mistake of accepting it at face value. You might wonder how to improve it. Do you simply write “improve this” or “make this better”. The answer is NO. You would rather give specific instructions, as I have done. In this step, you are not just editing, but you are strategically making the application fit the box.  Think of AI as your first year junior who can get 70% of the work done, but it is you who has to use your legal acumen and make the changes.

STEP 4: 

Based on the above prompt, ChatGPT generated the revised draft. It was a good draft. 

Here is the revised draft.

“Now that you have generated the draft of the temporary injunction application, help me review it before filing. Check whether: All legal ingredients like prima facie case, balance of convenience, and irreparable harm are clearly brought out. The structure flows logically and reads like a real pleading. The tone and language are appropriate for the Bombay High Court. Exhibits are properly marked. Any repetitive, vague, or AI-ish sounding phrases need to be edited. Suggest specific edits or redrafted paragraphs where necessary and make the changes accordingly.”

Explanation: After ChatGPT has revised the draft, you will be tempted to download and move on, but this step is the real deal. You check not just for typos but for substance, structure and perusasiveness in the draft. You check whether the flow is logical or whether the legal tests are demonstrated, or whether all exhibits are properly marked or whether the tone is appropriate. 

Finally, ChatGPT prepared a final draft of the temporary injunction application for me in less than 20 minutes. 

This is what was generated by ChatGPT:

ORDINARY ORIGINAL CIVIL JURISDICTION

 INTERIM APPLICATION NO. ___ OF 2025

  IN

 CIVIL SUIT NO. 1250 OF 2025
                                                                     
                                               

IN THE MATTER OF

APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER XXXIX RULES 1 AND 2 OF THE CODE OF CIVIL PROCEDURE, 1908

The Plaintiff abovenamed respectfully submits as follows:

1. The Plaintiff has instituted the present Suit being Civil Suit No. 1250 of 2025 before this Hon’ble Court seeking (i) a decree of mandatory injunction directing the Defendant to forthwith remove the unauthorised construction carried out on a portion of the Plaintiff’s property being Plot No. 123, Bandra (West), Mumbai, and (ii) a decree of permanent injunction restraining the Defendant from carrying out any further construction or encroachment on the said Plot. The present Interim Application is filed during the pendency of the Suit to seek urgent interim reliefs in order to prevent further unauthorised construction and to preserve the subject matter of the Suit. For the sake of brevity, the Plaintiff relies upon the facts stated in the Plaint and respectfully reiterates the relevant facts hereinbelow.
2. The Plaintiff is the absolute and lawful owner in possession of Plot No. 123, situated at Bandra (West), Mumbai (“the said Plot”), having acquired the same through a Family Settlement dated 25.01.2022 and a registered Sale Deed dated 01.03.2022, both of which are hereto annexed and marked as Exhibit A and Exhibit B respectively. The Plaintiff has been in peaceful, continuous, and exclusive possession of the said Plot and has been discharging all obligations such as payment of municipal taxes and utility bills, which are hereto annexed and marked as Exhibit C.
3. The Defendant is the owner of the adjoining Plot No. 124. In or around early May 2025, the Defendant, without any legal right, title, or authority, commenced unauthorized excavation and construction activities encroaching into a portion of the Plaintiff’s said Plot. The Plaintiff issued a Legal Notice dated 22.05.2025 calling upon the Defendant to forthwith cease the said illegal acts. A copy of the said Legal Notice is hereto annexed and marked as Exhibit D. Despite this, the Defendant has continued construction with increased speed. Photographs showing the encroachment and ongoing construction activity are hereto annexed and marked as Exhibit E.
4. The cause of action arose in May 2025 when the Plaintiff discovered the illegal construction activities by the Defendant over the Plaintiff’s property, and the same continues to subsist as the Defendant persists with the said construction.
5. The Plaintiff has a strong prima facie case, being the registered owner of Plot No. 123 and in exclusive, continuous possession thereof, as evidenced by Exhibits A to C. The Defendant, having no legal right or interest in the Plaintiff’s land, has initiated construction over the encroached portion without any authority, justification, or consent.
6. The balance of convenience clearly tilts in favour of the Plaintiff, who merely seeks to preserve the existing state of affairs and prevent the Defendant from altering the physical and legal character of the suit property. Any prejudice caused to the Defendant, who is acting illegally, is outweighed by the grave and irreversible harm faced by the Plaintiff.
7. If the Defendant is permitted to continue with the construction, the Plaintiff will suffer irreparable loss. Once permanent structures are erected, removal becomes difficult and may compromise the Plaintiff’s proprietary rights permanently. Monetary compensation cannot redress such loss.
8. There is immediate urgency in the matter. Despite being issued a legal notice, the Defendant has accelerated the pace of construction in an attempt to create a fait accompli. If interim relief is not granted forthwith, the Plaintiff’s right to seek effective redress will be rendered illusory.
9. In light of the above, the Plaintiff respectfully prays that this Hon’ble Court may be pleased to:
       a) Restrain the Defendant, by an order of temporary injunction, from carrying out any construction, excavation, dumping of materials, structural activity, or interference of any nature whatsoever on any portion of Plot No. 123, Bandra (West), Mumbai, pending the hearing and final disposal of the Suit;
       b) Direct the Defendant to maintain status quo as regards title, possession, and physical condition of the said Plot No. 123 during the pendency of the Suit; and
       c) Pass such other orders as this Hon’ble Court may deem just and proper in the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS, THE PLAINTIFF AS IN DUTY BOUND SHALL EVER PRAY.

Mumbai
Dated: __ June 2025
Advocate for the Plaintiff

This was the draft that was generated by chatGPT.

Now let me show you the final draft with manual edits in red

                          IN THE HON’BLE HIGH COURT OF JUDICATURE AT BOMBAY
                                    ORDINARY ORIGINAL CIVIL JURISDICTION 

                                       INTERIM APPLICATION NO. ___ OF 2025
                                                                        IN
                                                  CIVIL SUIT NO. 1250 OF 2025

IN THE MATTER OF
Anil Sharma

Age-65, Of Bombay Indian Inhabitant,

Residing at 36, Poonam Heights, 

Flat No.1205, 12th Floor, 

Bandra West, Mumbai – 40005                                        …Plaintiff/Applicant

                                                            Versus

Rajesh Gupta

Aged 65, of Bombay Indian Inhabitant,

Residing at Rekha Sadan,

Flat No.1, 1st Floor, Malad East,

                             

APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER XXXIX RULES 1 AND 2 OF THE CODE OF CIVIL PROCEDURE, 1908

The Plaintiff abovenamed respectfully submits as follows:

1. The Plaintiff has instituted the present Suit being Civil Suit No.1250 of 2025 before this Hon’ble Court seeking (i) a decree of mandatory injunction directing the Defendant to forthwith remove the unauthorised construction carried out on a portion of the Plaintiff’s property being Plot No.123, Bandra (West), Mumbai, and (ii) a decree of permanent injunction restraining the Defendant from carrying out any further construction or encroachment on the said Plot. The present Interim Application is filed during the pendency of the Suit to seek urgent interim reliefs in order to prevent further unauthorised construction and to preserve the subject matter of the Suit. For the sake of brevity, the Plaintiff relies upon the facts stated in the Plaint and respectfully reiterates the relevant facts hereinbelow.
2. The Plaintiff is the absolute and lawful owner in possession of Plot No.123, situated at Bandra (West), Mumbai (“the said Plot”), having acquired the same through a Family Settlement dated 25.01.2022 and a registered Sale Deed dated 01.03.2022, both of which are hereto annexed and marked as Exhibit “A” and Exhibit “B” respectively. The Plaintiff has been in peaceful, continuous, and exclusive possession of the said Plot and has been discharging all obligations such as payment of municipal taxes and utility bills, which are hereto annexed and marked as Exhibit “C”.
3. The Defendant is the owner of the adjoining Plot No.124. In or around early May 2025, the Defendant, without any legal right, title, or authority, commenced unauthorized excavation and construction activities encroaching into a portion of the Plaintiff’s said Plot. The Plaintiff issued a Llegal Nnotice dated 22.05.2025 calling upon the Defendant to forthwith cease the said illegal acts. A copy of the said Llegal Nnotice is hereto annexed and marked as Exhibit “D”. Despite this, the Defendant has continued the construction with increased speed. Photographs showing the encroachment and ongoing construction activity are hereto annexed and marked as Exhibit “E”.
4. The cause of action arose in May 2025 when the Plaintiff discovered the illegal construction activities by the Defendant over the Plaintiff’s property, and the same continues to subsist as the Defendant persists with the said construction.
5. The Plaintiff has a strong prima facie case, being the registered absolute owner of Plot No.123 and in exclusive, continuous possession thereof, as evidenced by Exhibits A to C. The Defendant, have no legal right or interest in the Plaintiff’s land, have initiated construction over the encroached portion without any authority, justification, or consent.
6. The balance of convenience is clearly tilts in favour of the Plaintiff, who merely seeks to preserve the existing state of affairs and prevent the Defendant from altering the physical and legal character of the suit property. Any prejudice caused to the Defendant, who is acting illegally, is outweighed by the grave and irreversible harm faced by the Plaintiff.
7.  If the Defendant is permitted to continue with the construction, the Plaintiff will suffer grave, harm and irreparable loss. Once permanent structures are erected, removal becomes difficult and may compromise the Plaintiff’s proprietary rights permanently. Monetary compensation cannot redress such loss.
8. There is an immediate urgency in the matter. Despite being issued a legal notice, the Defendant has accelerated the pace of construction in an attempt to create a fait accompli. If interim relief is not granted forthwith, the Plaintiff’s right to seek effective redress will be rendered illusory.
9. The Plaintiff has paid the fixed court fees of Rs.20/- on this Application.
10. The Plaintiff craves leave to add, delete, amend and/or alter any of the aforesaid averments, submissions and grounds with the leave of this Hon’ble Court.
11. The Plaintiff shall rely upon the documents a list of which is annexed hereof.
12. In the circumstances aforesaid light of the above, the Plaintiff respectfully prays that this Hon’ble Court may be pleased to:
13. Restrain the Defendant, by an order of temporary injunction, from carrying out any construction, excavation, dumping of materials, structural activity, or interference of any nature whatsoever on any portion of Plot No.123, Bandra (West), Mumbai, pending the hearing and final disposal of the suit;    

b) Direct the Defendant to maintain status quo as regards title, possession, and physical condition of the said Plot No.123 during the pendency of the Suit; and

c) Ad-interim reliefs in terms of prayer clause (a) and (b) 

d) Pass such other orders as this Hon’ble Court may deem just and proper in the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS, THE PLAINTIFF AS IN DUTY BOUND SHALL EVER PRAY.

Mumbai
Dated: __ June 2025

Advocate for the Plaintiff

Conclusion

And that is the gist of it.

So next time, when you have to draft an injunction application or if your senior or clients want the application on an urgent basis, do not panic.

Simply use AI and draft like a pro and hand over the draft in minutes.

This will undoubtedly have a significant impact on your career and help you advance it.

Frequently asked questions

1. Can a person get a temporary injunction at any stage of the lawsuit? 

Yes, temporary injunctions can be sought at any stage of the suit, unlike permanent injunctions which are only granted after final hearing. This flexibility allows for urgent interim relief when circumstances demand immediate intervention.

2. What types of cases commonly require temporary injunctions? 

Common scenarios include property disputes (like unauthorized construction), intellectual property violations, breach of contract with ongoing harm, defamation cases and situations involving violation of statutory rights.

3. Can a person get same day relief? 

In extremely urgent cases, courts can grant ex-parte ad-interim relief on the same day, however it is very rare that that court grants ex-parte ad-interim. It is necessary to demonstrate exceptional urgency and that delay would cause irreparable harm. Notice to the opposite party is required unless circumstances make it impractical.

4. Do you still need to understand injunction law if you are using AI? 

AI helps structure and organize your legal arguments, but you must understand the underlying legal principles, applicable precedents, and case specific nuances. AI is a tool that enhances your legal knowledge and it is not a replacement for it.

5. What are the consequences of violating an injunction order? 

Violating an injunction order constitutes contempt of court, which can result in imprisonment, fine, or both. The court takes such violations seriously as they undermine judicial authority.