BREACH OF AGREEMENT TO PURCHASE LAND

 

IN THE COURT OF_____________ (add detail court)

Suit no.____/20____

_________________ (suppose A.B.)(add description and residence).

Plaintiff

against?

__________________ (suppose C.D.)(add description and residence) . . .

Defendant

A. B., the above-named plaintiff, states as follows :-

1. On the__________day of____19_____, the plaintiff and defendant entered into an agreement, and the Original document is hereto annexed.

[Or, on the_______day of_______19_______, the plaintiff and defendant mutually agreed that the plaintiff should sell to the defendant and that 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 incumbrances, 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 a sufficient instrument] on the payment by the defendant of the money agreed upon.
3. The defendant has not paid the money.
4. [Facts showing when the cause of action arose and that the Court has jurisdiction.]
5. The Value of the subject-matter of the suit for the purpose of jurisdiction is _____rupees and for the purpose of court-fees is_______rupees.
6. [Relief claimed.]