IN THE COURT OF THE JUNIOR CIVIL JUDGE.

CITY CIVIL COURT

AT VISAKHAPATNAM.
O.S.NO.---- OF -----2020
Between:
J.K.Rao,
S/o Madhava Rao,
Aged 40 years,
R/o Srinagar,
Visakhapatnam. ……. Plaintiff

And
D. Krishna rao,
S/o Muralidhar,
Aged 45 years
R/o Kailasgiri,
Visakhapatnam. …….
Defendant.

PLAINT FILED UNDER SECTION 26 R/W ORDER VII, RULE 1 OF CPC

1. Description of the Plaintiff….

2. Description of the Defendant….

3. It is humbly submitted that the plaintiff purchased the House belonging to the defendant by entering
into an agreement for sale dated….. The defendant is the owner of the schedule mentioned house and he
offered the same house for sale to the plaintiff. Plaintiff agreed to purchase the schedule mentioned
house for Rs. ... and paid the part of sale consideration to the defendant who executed the agreement for
sale. By and under the recitals of the agreement for sale the defendant has agreed to execute a sale deed in
favour of plaintiff as and when demanded by him with his expenses. Even though plaintiff is ready and
willing to pay the remaining part of sale consideration to the defendant he is evading to execute the sale
deed.

4. It is submitted that though plaintifF got issued a legal notice to the defendant requesting him to execute
the sale agreement in favour of the plaintiff, the defendant has not received the said notice. Hence this suit
for specific performance of the agreement for sale

5. Cause of action: -----

6. Jurisdiction:- Schedule property is situated within the territorial jurisdiction of this Hon‘ble Court

7. Valuation of the suit: - Value of the suit is Rs. 25.00,000/-. The court fee of Rs. .......... is paid thereon
as per the A Court Fee Rules.

8. Limitation:- Suit is filed within limitation period.

9. In the above said circumstances it is prayed that Hon’ble Court may be pleased to pass a judgment” and
decree favour of the plaintiff and against the defendant.

a) For specific performance of agreement of sale dated……and direct the defendant to execute a sale
deed in favour of plaintiff and on his default/failure Hon'ble Court itself execute the sale deed in favour of
the plaintiff;

b) To award damages to the plaintiff in view of the delay taken place in execution of the sale deed by the
defendant.

c) Costs of the suit;

d) and grant such other relief as this Hon'ble Court deem fit and proper in the circumstances of the case.

Counsel for the plaintiff Plaintiff

Verification

I, the above named plaintiff. herein do hereby declare it the above mentioned facts are true and correct to
the best of knowledge, belief and information

Hence verified the same on this …….. day of ……

Plaintiff

Schedule of Property

(Give full description and location of the House)

Plaintiff
List of Documents:

1.

2.

Plaintiff.