IN THE COURT OF_____________ (add detail court)
_________________ (suppose A.B.)(add description and residence).
__________________ (suppose C.D.)(add description and residence)
A. B., the above-named plaintiff, states as follows :-
- On the_________day of_________19____________, the plaintiff and 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.
- On the_________day of_________19____, the plaintiff tendered ________ rupees to the defendant, and demanded a transfer of the said property by a sufficient instrument.
- On the day of 19 , the plaintiff again demanded such transfer, [or the defendant refused to transfer the same to the plaintiff.]
- The defendant has not executed any instrument of transfer.
- The plaintiff is still ready and willing to pay the purchase-money of the said property to the defendant.
- [Facts showing when the cause of action arose and that the Court has jurisdiction.]
- 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.
- The plaintiff claims:-
- that the defendant transfers the said property to the plaintiff by a sufficient instrument [following the terms of the agreement];
- ________ rupees compensation for withholding the same.