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Legal Drafting-1

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Muhammad Umer
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2 views

Legal Drafting-1

Uploaded by

Muhammad Umer
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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legal Drafting – I

Topic: Suit for specific performance

Shaffan Jaffer 4953-BS-LLB-21


Shayan Imran 4955-BS-LLB-21
Jazib Ud Din 4965-BS-LLB-21
Hassan Shehriyar 4971-BS-LLB-21
Hassan Tahir 4949-BS-LLB-21
IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Civil Suit No.___________/2024

Haider Ali Son of Ch. Muhammad Nazir R/o House No.45 – Sodiwal Multan Road
District, Lahore.

…Plaintiff
VERSUS

Farrukh Javed Son of Yar Muhammad R/o House No.76 – DHA, Phase 4, Lahore

…Defendant

SUIT FOR SPECIFIC PERFORMANCE WITH PERMANENT INJUNCTION

Respectfully Sheweth:

1. That the addresses of the parties given in the title of this suit are correct and sufficient for
the purposes of summons and effecting the service through the process of this Hon'ble
Court.
2. That brief facts of filling the instant suit are that the plaintiff and defendant entered into
an agreement to sell regarding the property measuring 10-Marlas, registration No.
675/2014 situated at Plot No. 300, Overseas Block 2 Bahria Town, Lahore against the
consideration of Rs.25,00,000/-, out of which the plaintiff paid Rs.5,00,000/- as earnest
amount and it was settled that the plaintiff will pay the remaining amount of
Rs.20,00,000/ on 10.10.2014 and will get transfer the suit property in his name. (Copy of
the agreement is attached herewith)
3. That after elapse of stipulated time period the plaintiff time and again approached the
defendant and requested to transfer the suit property in his name, but the defendant
lingered on the matter for one pretext or the other and now the defendant has refused to
accept the genuine and lawful request of the plaintiff and also refused to transfer the suit
property in the name of the plaintiff and further extended threats that he will alienate the
suit property to someone else, hence this suit.
4. That the cause action firstly accrued in favor of the plaintiff and against the defendant
when the plaintiff purchased the said property and finally when the defendant has refused
to accept the genuine and lawful request of the plaintiff, which is continuing.
5. That the suit property situated in Lahore, cause of action arose in Lahore and the parties
of suit are also residing at Lahore, therefore this Hon’ble court has complete jurisdiction
to adjudicate upon this matter.
6. That the value of suit for purpose of court fee and jurisdiction fixed for Rs.25,00,000/-
and requisite court fee of Rs.15,000/- will be affixed on the plaint as per order of the
court.

Prayer:

Under the circumstances it is humbly prayed that the defendant is directed to pay the amount
owed to the plaintiff or accept the remaining amount and transfer the property to the plaintiff.

Any other relief to which this honorable court deems fit and appropriate in favor of the plaintiff
may also be awarded. The cost of the suit may also be awarded.

Plaintiff through:

Sadoon Abass Gondal

Advocate High Court


Session Court, Lahore.

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