Section 45 injunctions are unavailable where territorial limits, an adequate appeal, and incomplete relief block the requested restraint.

Relief under Section 45 of the Specific Relief Act cannot be used to restrain interference with judicial acts of election officers where the alleged interference would occur outside the Court's territorial jurisdiction. The remedy was also unavailable because an adequate specific appellate remedy existed against the adverse election decision. Further, the order sought would not have afforded complete relief, as the appeals had already been decided and the impugned circular could no longer affect them. On those grounds, the order under Section 45 was held not legally sustainable and was set aside.

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Issues: Whether an injunction could be granted under Section 45 of the Specific Relief Act to restrain interference by a circular with the judicial functions of election officers and appellate authorities, and whether the application was barred by the availability of an adequate legal remedy and by territorial jurisdiction limits.

Analysis: The order sought to restrain future interference with officers who were acting judicially in dealing with claims and objections to electoral rolls. The Court held that such interference, if any, would occur outside the Ordinary Original Civil Jurisdiction, so the statutory jurisdiction under Section 45 could not be used to control acts taking place in the mufassal. The applicant also had a specific appellate remedy against the adverse election decision, and the existence of that remedy barred recourse to Section 45. In addition, the remedy granted by the order could not be complete, since the appeals had already been decided and the impugned circular could no longer affect them.

Conclusion: The order under Section 45 was not legally sustainable and was set aside; the appeal succeeded.

Ratio Decidendi: Relief under Section 45 of the Specific Relief Act cannot be granted where the complained-of interference lies outside the Court's territorial jurisdiction, where an adequate specific remedy already exists, or where the order sought would not afford complete relief.

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