IN THE COURT OF _____________________________

C.S. (OS) NO______________ OF 20___

IN THE MATTER OF:

PLAINTIFF

VERSUS

DEFENDANT

SUIT FOR SPECIFIC PERFORMANCE OF AGREEMENT TO SELL COMMERCIAL UNIT ADMEASURING

___ SQ FT.

MOST RESPECTFULLY SHOWETH:

SUIT FOT THE POSSESSION OF HOUSE NO.48, GULSHAN

COLONY, KARACHI, THROUGHSPECIFIC PERORMANCE

OF THE AGREEMENT, DATED 12 AUGUST, 2014.

The above-named plaintiff states as follow:

1. That by an agreement, dated 12 August 2014, duly executed and singed by the defendant, he
contracted to sell to the plaintiff his immoveable property, viz, House No.48, Gulshan Colony,
Karachi, with all accessories and appurtenances for Rs.12,750.00. The boundaries of the houses are
as follows:

North-----House of Abid Noor son of Abdullah

South-----Govt Primary School.

East-------House of Naveed Ahmad.

West-----Open plot belonging to Ch. Waqas Jutt

2. That the plaintiff requested the defendant to specifically perform the agreement on his part, to
accept the sum of Rs.12,750,00 and to execute the conveyance of sale in plaintiff’s favor, but the
defendant has not done so, and a week ago refused to convey the house to plaintiff.
3. That the plaintiff has been and is still ready and willing specifically to perform the agreement on
his part of which the defendant has had notice.

4. That the cause of action arose against the defendant on 12th August 2014, the date by which the
defendant had stipulated to execute and sign a conveyance of sale in favor of the plaintiff.

5. That the agreement was signed at Karachi and the property to question is also situate in Karachi,
the Civil Court at Karachi has, therefore, jurisdiction to try the suit.

6. That the value of the subject-matter of the suit for the purposes of Court-fee and jurisdiction is Rs.
12,755.00.

It is, therefore, respectfully prayed that a decree for possession

through specific performance of House No.48, Gulshan Colony,

Karachi, be passed in favor of the plaintiff against defendant

And the defendant be ordered to perform the agreement

specially And do all such acts as may be necessary to put the

plaintiff in full Possession of the did property and to pay the

costs of suit.

Dated: 4th January 2015.

Syed Noor Ali

Through

Hafeez ul Rahman Advocate.

Verification

Verified at Karachi, this 4th day of January, 2015, that the contents of plaint are true to the best of
my knowledge and beliefs.