SUIT FOR SPECIFIC PERFORMANCE FOR PURCHASE OF LAND BY VENDEE FOR DAMAGES
IN THE COURT OF THE………………..
Suit No………………… of 19………………..
C. D………………………………………………………….. Plaintiff
versus
C. F……………………………………………………….. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. That the defendant contracted on……………….. 19……………….. through an agreement in writing to purchase……………….. Bighas Bhumidhari Land of Khata No………………… situate in village……………….. of……………….. District, detailed in the foot of the plaint, from the plaintiff, within six months from the abovementioned date, for Rs………………… out of which the plaintiff had paid Rs………………… on the date of agreement aforesaid.
2. That the defendant did not come forward to purchase the land aforesaid within the stipulated time, and in the last month on……………….. 19……………….. the plaintiff gave him a registered notice to attend the sub-Registrar’s office at ……………….. with the balance money of Rs………………… (………………………………….) for getting the sale deed executed by the plaintiff in his favour and transfer of the land accordingly. The Plaintiff attended the Sub-Registrar’s office on the date abovementioned and remained there throughout the working hours of the day, but the defendant did not turn up with money aforesaid for getting the execution of the sale deed aforesaid.
3. That the plaintiff had been ready and willing to execute a proper sale deed within the period of six months aforesaid and particularly on the appointed date aforementioned, but the defendant did not turn up to perform his part of the contract and to pay the balance of the purchase money on the appointed date/or the defendant, on……………….. 19……………….. refused to perform his part of the contract and to pay the balance of the settled purchase amount aforesaid. The plaintiff has suffered damage of Rs………………… by the said refusal of the defendant.
4. That the cause of action arose on……………….. 19………………… the appointed date which was the last date of the specific period of six months for the execution of the sale deed, and this court has jurisdiction to decide the suit.
5. That the suit is valued at Rs…………………. the balance of the purchase amount for the purpose of jurisdiction and Rs………………… for the purpose of Court-fee and court-fee is paid according to the reliefs claimed.
RELIEFS CLAIMED:
The Plaintiff claims the following reliefs:
(1) to issue a mandatory injunction to the defendant to pay the balance amount of Rs………………… of the sale price and get the execution of sale deed done in his favour from the plaintiff. Or in the alternative.
(2) payment of Rs………………… from the defendant with interest from the date of payment thereof to him, and Rs………………… as damages, with interest from the date of suit till payment.
Plaintiff
Through Advocate
VERIFICATION
I, abovenamed plaintiff, do hereby verify that the contents of paras ……………….. to……………….. of the plaint are true to my personal knowledge and those of paras……………….. and……………….. thereof are based on legal advice which I believe to be true.
Verified on this…………….. day of……………….. 19……………….. at………………..
Plaintiff