In the Court of District Judge at Dehradun

Suit No. _______ of 2016

Mr. A.B. Singh S/O Mr. C.D. Singh
123 KH Sri Enclave, Panditwari
Dehradun, U.K. -248007

_________________________ Plaintiff

Mr E.F. Gupta S/O Mr. G.H. Gupta

456 GH Bidholi
Dehradun, U.K. -248001

_________________________ Respondent

Suit for Specific Performance of a contract to sell a residential plot

The plaintiff respectfully states the follows:
Inducement
1) The plaintiff is a software engineer working as Project Head at Microsoft Inc.
2) The respondent is a property broker having his office at 456GH Bidholi,
Dehradun, U.K.
Material facts of the case
3) The plaintiff agreed with the respondent on 21 December 2015 to purchase
the plot no. 475/76, Ashirwad Enclave, Dehradun, U.K. The copy of the sale
agreement has been attached with the plaint.
4) The boundaries of the plot are as follows :
a. East plot No. 474/76
b. West Plot No. 476/76
c. North Road
d. South Plot No. 475/75
5) The total value of the plot as agreed upon by the parties in the agreement is
Rs. 5,50,000 /- ( Five Lac fifty thousand rupees only)
6) The respondent accepted Rs. 2,00,000/- (Two Lac Rupees only) via Check no.
47584 of the Punjab National Bank, Ballupur Branch and agreed to do the
registry on the payment of the remaining sum of Rs. 3,50,000/- (three lac
fifty thousand rupees only).
7) The plaintiff showed his intention to perform by trying to offer the
remaining amount at various occasions but the respondent refused the
acceptance of the amount.
8) The plaintiff served a notice regarding the same to the respondent on 3
April, 2016

9) The plaintiff is ready to make the payment of the remaining amount i.e. Rs.
3,50,000/- (three lac fifty thousand rupees only) but the respondent is not
willing to transfer the aforesaid plot.
Cause of action and limitation
10) The cause of action for the present suit first arose on 03.04.2016, when the
respondent refused to convey the said property as per the terms of the
agreement and hence, the suit filed today is within time.
Valuation
11) The suit is valued for the purpose of jurisdiction and court-fee at Rs.
3,50,000/- (three lac fifty thousand rupees only).
Jurisdiction
12) The plot is located in Dehradun, which is within this court's territorial
jurisdiction.
13) The value of the contract is Rs. 5,50,000 /- ( Five Lac fifty thousand rupees
only) which is within this court's pecuniary jurisdiction.
Relief claimed
14) The plaintiff therefore prays that
a. The court be pleased to order the respondent to perform his part of
the contract by accepting the remaining payment and conveying the
said plot to the plaintiff.
b. The plaintiff be permitted to deposit the balance of consideration in
this Hon'ble Court.
c. The respondent be ordered to pay compensation for mental
harassment and cost of this litigation.

(Signature of the Plaintiff)

Place: Dehradun
Dated: 20 April, 2016
Rohitashwa Singh
Council for the Plaintiff

Verification
I, A.B. Singh S/O Mr. C.D. Singh, do hereby solemnly verify that the contents from
paras 1 to 9 are correct and true to the best of my knowledge and contents from
para 10 to 14 are based on legal advice, which I believe to be correct. Affirmed at
Dehradun this 20th Day of April 2016.

(Signature of the Plaintiff)