SUIT FOR SPECIFIC PERFORMANCE OF PURCHASING LAND
IN THE COURT OF THE………………..
Suit No………………… of 19………………..
C. D………………………………………………………….. Plaintiff
versus
C. F……………………………………………………….. Vehnfant
The abovenamed plaintiff most respectfully submits as under: —
1. On the……………….. day of……………….. 19……………….. the plaintiff and the defendant entered into an agreement, and the original document is hereto annexed.
OR
(On the……………….. day of……………….. 19………………… the plaintiff and the defendant mutually agreed that the plaintiff should sell to the defendant and the defendant should purchase from the plaintiff forty bighas of land in the village of ……………….. for……………….. rupees).
2. On the……………….. day of……………….. 19………………… the plaintiff, being then the absolute owner of the property and the same being free from all encumbrances as was made to appear to the defendant, tendered to the defendant a sufficient instrument of transfer of the same (or, was ready and willing, and is still ready and willing, and offered to transfer the same to the defendant by sufficient instrument) on the payment by the defendant of the sum agreed upon.
3. The plaintiff gave a registered notice dated……………….. 19……………….. received by the defendant……………….. on……………….. 19………………… to attend the Sub-Registry of the District……………….. at 10 A. M. with the money in consideration of the proposed purchase for the land aforesaid and have the sale deed duly registered as executed by the plaintiff on payment of the aforesaid price due. But the defendant did not appear in the office of the Sub-Registrar aforesaid upto 4 p. m. on the day aforesaid, even though the plaintiff remained there from 10 A. M. to 4 P. M. after giving intimation of the fact of his appearance and presence to the Sub-Registrar aforesaid.
4. The cause of action arose on……………….. 19………………… when the defendant did not appear before the Sub-Registrar aforesaid even after notice and pay the money of the purchase price as agreed, and this Court has jurisdiction to try the suit.
5. The suit is valued at Rs………………… the proposed and agreed sale price of the land aforesaid, and Rs………………… for the purpose of court fee, and court fee is paid thereon.
RELIEFS CLAIMED:
The reliefs claimed by way of this suit are as follows:
(i) The defendant be directed by issuing a mandatory injunction to pay……………….. rupees to the plaintiff the price of the land and have the registered sale deed from the office of the Sub-Registrar.
(ii) Interest on the amount of sale price at a reasonable rate be awarded to the plaintiff.
(iii) Costs of the suit be given to the Plaintiff.
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