Sample Draft on Suit On Specific Performance

IN THE COURT OF CIVIL JUDGE

(SENIOR DIVISION) , JAIPUR

A s/o B , aged…, occupation, resident ……

-------------------------------------------- Plaintiff

Versus
Xs/o Z , aged…, occupation, resident ……
-------------------------------------------- Defendant

Suit no…./19

Suit for Specific Performance of Contract for the sale of House

The above named plaintiff states as follows—

1. That by an agreement dated ….. the defendant agreed to sell

to Plaintiff the House described below for the sum of rupees
… and on the same day defendant received …. From the
Plaintiff rupees ….. as earnest money
2. That the defendant agreed about remaining sum of rupees ….
 Shall be paid to him on the date …. At the time of the
registration of the sale deed in the registrar office

3. That on the date……. Plaintiff went to the office

4. ….
5. ……
6. ……
7. That the plaintiff has been and still already and willing to
perform the agreement on his part of which defendant had
notice
8. That the cause of action for the suit arose on… when
defendant refused to execute the sale deed in respect of the
said house in favour of the plaintiff
9. That the house agreed to be sold by the defendant is situated
at……. Within jurisdiction of this court
10. That the valuation of the suit for the purpose of Jurisdiction
and payment of court fee is rupees… on which a court fee of
Rupees …has been paid

Wherefore the Plaintiff claims –

Or It is Prayed
A
B Rupees as Compensation
C Costs of the suit be also awarded to the plaintiff

Place…..
Date…. A
Plaintiff
 Verification
I , As/o B , the aforesaid plaintiff ,do hereby verify that the content
of paragraph no. are true to my personal knowledge and the
content of the remaining paragraphs are based on the legal advice
from my advocate which I believe to be true

Place…..
Date …. A
Plaintiff
K
Advocate

Written Statement

IN THE COURT OF CIVIL JUDGE

(SENIOR DIVISION) , JAIPUR

A s/o B , aged…, occupation, resident ……

-------------------------------------------- Plaintiff

Versus
Xs/o Z , aged…, occupation, resident ……
-------------------------------------------- Defendant

Suit no…./19

Written Statement on the behalf of Defendant

1. That the defendant not enter into agreement
2. That the defendant has not received any amount
3. The defendant denies each and every allegation made in
paragraph 3
4. Para 5-7 are legal paras
5. It is therefore prayed that the suit may be dismissed with cost
6. Defendant has not receive any notice
7. There is no agreement so defendant is not bound to perform
his part

Place…..
Date…. ….
Defendant
Verification
I ,…….., the aforesaid plaintiff ,do hereby verify that the content of
paragraph no. are true to my personal knowledge and the content
of the remaining paragraphs are based on the legal advice from my
advocate which I believe to be true

Place…..
Date …. A
Defendant