SUIT FOR SPECIFIC PERFORMANCE
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. On the……………….. day of……………….. 19………………… the plaintiff and the defendant entered into an agreement, in writing, and the original document is hereto annexed. The defendant was absolutely entitled to the immovable property described in the agreement.
2. On the……………….. day of……………….. 19………………… the plaintiff tendered……………….. rupees to the defendant, and demanded a transfer of the said property by a sufficient instrument.
3. On the……………….. day of……………….. 19………………… the plaintiff again demanded such transfer, (or the defendant refused to transfer the same to the plaintiff).
4. The defendant has not executed any instrument of transfer.
5. The plaintiff is still ready and willing to pay the purchase-money of the said property to the defendant.
6. Cause of action arose on……………….. 19……………….. when the defendant refused to transfer the property to the plaintiff, and this Court has jurisdiction to try the suit.
7. The suit is valued at Rs………………… the agreed consideration of the transfer aforesaid.
RELIEFS CLAIMED:
The plaintiff claims:
(1) that the defendant to transfer the said property to the plaintiff by a sufficient instrument (following the terms of the agreement);
(2) ……………….. rupees compensation for withholding the same.
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