Specific Performance (No. 1)
In the Court of ......................................
KK……………………………………………………………….resi……… ...................... Plaintiff
against
GM…………………………….……………………………….resi………….) .................... Defendant KK., the above-named plaintiff, states as follows:- 1. By an agreement dated the ………….... day of…………… ...... and signed by the defendant, he contracted to buy of [or sell to] the plaintiff certain immovable property therein described and referred to, for the sum of.......................... rupees. 2. The plaintiff has applied to the defendant specifically to perform the agreement on his part, but the defendant has not done so. 3. The plaintiff has been and still is ready and willing specifically to perform the agreement on his part of which the defendant has had notice. [i. Facts showing when the cause of action arose and that the Court has jurisdiction. ] ii. The value of the subject-matter of the suit for the purpose of jurisdiction is ...........................rupees and for the purpose of court-fees is ............................................rupees.] 4. The plaintiff claims that the Court will order the defendant specifically to perform the agreement and to do all acts necessary to put the plaintiff in full possession of the said property [or to accept a transfer and possession of the said property] and to pay the costs of the suit. Dated : Plaintiff / Defendant Through, Advocate
Verification:
I,...................................................., do hereby verify that the contents from paras 1 to ______ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein. Affirmed at …………………………. this ______. Plaintiff / Defendant
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