SUIT FOR SPECIFIC PERFORMANCE FOR PURCHASE OF LAND BY VENDEE FOR

DAMAGES

IN THE COURT OF THE....................

Suit No..................... of 19....................

C. D.................................................................... Plaintiff

versus

C. F................................................................. Defendant

The abovenamed plaintiff most respectfully submits as under: —

1. That the defendant contracted on.................... 19.................... through an agreement in

writing to purchase.................... Bighas Bhumidhari Land of Khata No..................... situate in
village.................... of.................... District, detailed in the foot of the plaint, from the plaintiff,
within six months from the abovementioned date, for Rs..................... out of which the plaintiff
had paid Rs..................... on the date of agreement aforesaid.

2. That the defendant did not come forward to purchase the land aforesaid within the stipulated
time, and in the last month on.................... 19.................... the plaintiff gave him a registered
notice to attend the sub-Registrar’s office at .................... with the balance money of
Rs..................... (........................................) for getting the sale deed executed by the plaintiff in
his favour and transfer of the land accordingly. The Plaintiff attended the Sub-Registrar’s office
on the date abovementioned and remained there throughout the working hours of the day, but
the defendant did not turn up with money aforesaid for getting the execution of the sale deed
aforesaid.

3. That the plaintiff had been ready and willing to execute a proper sale deed within the period
of six months aforesaid and particularly on the appointed date aforementioned, but the
defendant did not turn up to perform his part of the contract and to pay the balance of the
purchase money on the appointed date/or the defendant, on.................... 19....................
refused to perform his part of the contract and to pay the balance of the settled purchase
amount aforesaid. The plaintiff has suffered damage of Rs..................... by the said refusal of
the defendant.

4. That the cause of action arose on.................... 19..................... the appointed date which was
the last date of the specific period of six months for the execution of the sale deed, and this
court has jurisdiction to decide the suit.

5. That the suit is valued at Rs...................... the balance of the purchase amount for the
purpose of jurisdiction and Rs..................... for the purpose of Court-fee and court-fee is paid
according to the reliefs claimed.

RELIEFS CLAIMED:

The Plaintiff claims the following reliefs:

(1) to issue a mandatory injunction to the defendant to pay the balance amount of
Rs..................... of the sale price and get the execution of sale deed done in his favour from the
plaintiff. Or in the alternative.

(2) payment of Rs..................... from the defendant with interest from the date of payment
thereof to him, and Rs..................... as damages, with interest from the date of suit till payment.

Plaintiff

Through Advocate

VERIFICATION

I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to....................
of the plaint are true to my personal knowledge and those of paras.................... and....................
thereof are based on legal advice which I believe to be true.

Verified on this................. day of.................... 19.................... at....................

Plaintiff