Specific Performance (No.1)

Mr……………………, 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 there in 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.

4.	[Facts showing when the cause of action arose and that Court has jurisdiction.]

5.	The value of the subject-matter of the suit for the purpose of jurisdiction is ………… rupees and for the purpose of court fee is …….. rupees.

6.	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.