IN THE COURT OF SENIOR CIVIL JUDGE,

(DISTRICT…….), DELHI
CIVIL SUIT NO._______ OF ____
IN THE MATTER OF:
Shri V.K. Gupta
S/o Gaurav Gupta
R/o XYZ
New Delhi PLAINTIFF
VERSUS
Shri Gagan Khanna
S/o Ashok Khanna
R/o ABC
New Delhi DEFENDANT
SUIT FOR PERMANENT INJUNCTION
Sir
The plaintiff respectfully submits as under:
1. That the plaintiff entered into an agreement to sell by paying the consideration
amount of Rs. 1 lac to the defendant, who is the owner and in possession of premises
bearing no. _____ New Delhi hereinafter referred to as ‘Suit Property’ which is
shown in site plan attached hereto.
2. That the plaintiff agreed to purchase the house of defendant for a sum of Rs. 5 lac out
of which an amount of Rs. 1 lac was received by defendant from plaintiff.
3. That the sale deed was to be executed after 45 days of the payment of the
abovementioned consideration amount of Rs. 1 lac paid by plaintiff to defendant.
4. That the plaintiff was asked for specific performance of contract on the part of the
defendant, the defendant has refused to perform his part of the contract.
5. That the plaintiff was asked for execution of the sale deed, the defendant refused to
execute sale deed and refused to sell his house to plaintiff saying that the process has
gone up.
6. That thereafter plaintiff came to know that the defendant has also started negotiations
with prospective buyers through property dealers.
7. That the act of defendant of refusing to sell his house to plaintiff despite receiving
consideration amount of Rs. 1 lac is illegal, arbitrary and without any logic.
8. That the plaintiff was always willing to perform his part of the contract even after the
defendant has refused to execute the sale deed after 45 days and the plaintiff is still
willing to pay the remaining amount of consideration for the purchase of the house.
9. That the cause of action in favour of plaintiff and against the defendant to file the
present suit first arose when after 45 days defendant refused to execute the sale deed.
Cause of action further arose when defendant started negotiations with prospective
buyers through property dealers and cause of action still subsists.
10. That Hon’ble court has jurisdiction to try the present suit as parties are residing at
Delhi and working for gain at Delhi and property is situated at Delhi.
11. That for the purpose of court fee and pecuniary jurisdiction the suit is valued for
permanent injunction Rs. 130, on which requisite court fee has been affixed.
12. That plaintiff prays this Hon’ble court to pass a decree for permanent injunction in
favour of plaintiff and against the defendant restraining the defendant from selling his
house to a third party or creating any third party interest or rights or alienating the
property.

Any other and further order which this Hon’ble court deem fit and proper in the
circumstance of the case may also be granted/passed in favour of plaintiff and against
the defendant.

PAINTIFF
Place……….
Dated………
Through Counsel
 VERIFICATION
Verified at Delhi on this…..day of February, 20…., that the contents of para 1 to 7 of the suit
are true as per my knowledge and belief and contents of para 8 to 10 are true on the basis of
information received and believed to be true. Last para is humble prayer to this Hon’ble
court.
PAINTIFF
Place……….
Dated………