SPECIFIC PERFORMANCE

 

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, in writing, and the original document is hereto annexed.
2. The defendant was absolutely entitled to the immovable property described in the agreement.
3. On the_________day of_________19____, the plaintiff tendered ________ rupees to the defendant, and demanded a transfer of the said property by a sufficient instrument.
4. On the day of 19 , the plaintiff again demanded such transfer, [or the defendant refused to transfer the same to the plaintiff.]
5. The defendant has not executed any instrument of transfer.
6. The plaintiff is still ready and willing to pay the purchase-money of the said property to the defendant.
7. [Facts showing when the cause of action arose and that the Court has jurisdiction.]
8. 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.
9. The plaintiff claims:-
   1. that the defendant transfers the said property to the plaintiff by a sufficient instrument [following the terms of the agreement];
   2. ________ rupees compensation for withholding the same.