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https://advocatemmmohan.com/2019/02/07/in-a-suit-filed-under-section-38-of-the-specific-relief-act-possession-on-the-date-of-suit-is-a-must-for-grant-of-permanent-injunction-when-the-first-respondent-plaintiff-has-failed-to-prove-that-he/
in a suit filed under Section 38 of the Specific Relief Act, possession on the date of suit is a must for grant of permanent injunction. When the first respondent-plaintiff has failed to prove that he was in actual possession of the property on the date of the suit, he is not entitled for the decree for permanent injunction