Gujarat High Court Civil Manual (subordinate court practice), 1960
Proper discretion should be exercised in issuing ex-parte injunctions under Order XXXIX. Before granting such an injunction, it is the duty of the presiding officer of the Court to take every care to protect the interest of the absenteed defendant and to ensure to him the earliest opportunity of being heard. District Judges when dealing with appeals or inspecting Courts should scrutinize the materials upon which ex parte injunctions have been granted.