In the court of senior civil judge, Bahawalpur Muhammad akram S/O muhammad asghar, cast jatt, R/O house # 27, model town b, bahawalpur (Plaintiff) Versus Ali nawaz S/O Haq nawaz, cast arain , R/O house #22 model town C, bahawalpur (defendant) Suit for specific performance of agreement to sell house # 23 model town C, Bwp with permanent injunction
Plaintiff respectfully submitts as under, 1. That defendant named above is the full owner of house # 23 model town c, bahawalpur
with complete possession. 2. That defendant under his need of money offered to the plaintiff for the sale of his house
mention in clause 1. For the sum of Rs 70,00,000/- seventy lakh, which the plaintiff accepted 3. On 20th june 2011, defendant issued an deed for agreement to sell after accepting earnest
money of Rs 30,00,000 and receipt of the said earnest money in favor of plaintiff in front of witnesses. Copies of deed and receipt are attached hereinafter. 4. It was stipulated in the agreement that defendant shall be bount to convey the property to
the plaintiff within one month i.e. 20th of july 2011 on receiving the remaining amount of Rs 40,00,000 (fourty lakh). 5. That the plaintiff offered on 15th day of july 2011 to the defendant sum of Rs 40,00,000
and requested to write sale deed in favor of plaintiff along with the possession on plaintiffs cost. 6. That defendant on has refused to convey the said property, thus this suit. 7. thus cause of action arose against the defendant two days back on refusal. 8. That the propery is situated in bwp therefore honorable court has jurisdiction. 9. The court fees of Rs 150000 has been attached with the plaint.
It is therefor respectfully prayed that 1. Decree be passed in favor of plaintiff against the defendant to fulfill
his obligation 2. Further to restrict the defendant, or his agent, legal hairs to sell,
exchange, mortgage and gift the said property. 3. The cost of suit may also be awarded. Dated: 20 /07/ 2011 (Signature of plainfiff) Verification: It is verified on oath on this 20th day of july 2011 at bwp that para 1-7 are correct to the best of my knowledge and belief and para 8 and 9 are correct to my information.
Signature of plaintiff
