SUIT
FOR SPECIFIC PERFORMANCE OF AGREEMENT TO SELL
[CD1]
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.
On....................
19.................... C. F. Defendant through an agreement to sell
his.................... bighas of Bhumidhari land, situate in
village.................... of tahsil.................... of
District.................... detailed in the schedule hereto annexed agreed to
sell the land aforesaid to the plaintiff for Rs..................... /- (Rs.
........................................ ), within six months from the date of
the agreement aforesaid after taking permission from the Collector of the
District, as the defendant belongs to the Schedule Castes.
2.
The
agreement aforesaid was got registered before the Sub-Registrar
.................... of District.................... and
Rs..................... were paid as earnest money and possession of the land
was given to the plaintiff.
3.
The
plaintiff has been requesting the defendant to obtain the permission from the
Collector and to execute the sale deed for consideration as aforesaid.
4.
That
when the period of six months aforesaid was about to expire, the plaintiff
intimated the defendant through a registered notice dated....................
19.................... received by the defendant on.................... to
execute the sale deed after obtaining the required permission of the Collector
of the District, but the defendant did not do the same.
5.
Cause
of action arose within the jurisdiction of this Court on....................
19.................... after the expiry of six months from the date of
agreement aforesaid, when the defendant received the notice of the plaintiff
and thereafter the plaintiff neither replied to the notice of the plaintiff,
nor complied with the terms thereof.
6.
The
valuation of the suit is Rs..................... and for the purpose of court
fee is Rs..................... the one fifth amount of the valuation in case of
seeking an injunction, and court fee thereon is paid.
7.
The
balance of convenience is in favour of the plaintiff and it is expedient that a
mandatory injunction may be issued to the defendant to execute the sale deed as
agreed.
RELIEF CLAIMED:
The relief claimed by way
of this suit is:
The defendant be directed
by issuing a mandatory injunction to execute the sale deed as agreed in favour
of the plaintiff.
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
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