What conduct should be restrained?
Define the specific act: transfer of property, use of information, exercise of a right, termination of service, or another change. An vague or overbroad order may be difficult to enforce and disproportionate.
Interim relief serves a principal claim
The motion does not stand alone. Identify the principal claim, the right to be protected, and how the order preserves effective final relief. Urgency does not replace a cause of action and prima facie merit.
Present harm and the balance of consequences
Explain what will occur without the order, whether money can compensate, and the harm to the opposing party if granted. The court may consider third parties and narrower alternatives.
Good faith and complete disclosure
An urgent motion, particularly ex parte, requires disclosure of material facts, including adverse ones. Attach correspondence and records in context, not an excerpt creating a misleading picture.
Do not wait until the last moment
Delay may undermine urgency. Once risk is discovered, preserve evidence, document timing, consider a demand, and prepare the principal case. An undertaking and security may be required.
Concluding point
A sound injunction motion joins an apparent right, concrete danger, balance of harm, and precise remedy. Speed is important but does not replace a complete foundation.
This is general information, not legal or financial advice. Interim relief is discretionary.
Principal legal sources
- Civil Procedure Regulations, 5779-2018.
- Courts Law [Consolidated Version], 5744-1984.