Interim injunction in trust dispute denied where applicants lacked bona fides, prima facie case, and balance of convenience.

Interim injunction is unavailable where the applicants cannot show bona fides, fail to establish a prima facie case, and do not demonstrate balance of convenience in their favour. The commentary notes that, in a Section 92 CPC trust dispute, leave had been granted only against certain defendants, the trust records and meetings were linked to Madurai, and serious doubts arose from findings of collusion and lack of clean hands. Relief was also refused because the transfer of control had already occurred by operation of law, so an injunction could not be used to reverse a completed legal event. The request to continue the status quo order was therefore rejected.

---

---

Issues: Whether the petitioners were entitled to continue the status quo order and obtain interim injunction in the pending appeal, and whether the application was supported by a prima facie case, balance of convenience, and bona fides.

Analysis: The suit was instituted under Section 92 of the Code of Civil Procedure, 1908 and leave was obtained only against certain defendants, while the Trust's registered office and the relevant meetings and records were shown to be at Madurai. The materials also showed serious doubts about the petitioners' bona fides, including findings of collusion and lack of clean hands. On the merits of interim relief, the transfer of control of the 9th respondent had already occurred by operation of law, so an injunction could not be used to reverse an accomplished event. The Court also found that no credible material was produced to show diversion of Trust funds or to establish a prima facie case, and that the balance of convenience and likely prejudice favoured the 9th respondent, particularly in light of the business transfer and the practical consequences of the status quo order.

Conclusion: The petitioners were not entitled to any further interim protection, and the request to continue or grant injunction failed.

Final Conclusion: The interim restraint was lifted, the petition for injunction was rejected, and the connected applications were disposed of in favour of the respondent side.

Ratio Decidendi: Interim injunction cannot be granted where the applicant lacks bona fides, fails to establish a prima facie case, and the relief sought would reverse a completed legal transfer rather than preserve an existing state of affairs.

---