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    Sunday, 13 December 2015

    Draft of Suit for Specific Performance


    IN THE COURT OF SENIOR CIVIL JUDGE, KARACHI

    Syed Noor Ali son of Syed Amir Rasool, caste by Syed, R/O House No.532, Street No.5, Gulshan Colony, Karachi.
    ……… Plaintiff.
    Versus

    Tariq Mahmood son of Mahmood Ali, caste by Jutt, R/O Samanabad, Karachi.
    ......Defendant

    SUIT FOT THE POSSESSION OF HOUSE NO.48, GULSHAN 
    COLONY, KARACHI, THROUGHSPECIFIC PERORMANCE 
    OF THE AGREEMENT, DATED 12 AUGUST, 2014.

    The above-named plaintiff states as follow:

    1. That by an agreement, dated 12 August 2014, duly executed and singed by the defendant, he contracted to sell to the plaintiff his immoveable property, viz, House No.48, Gulshan Colony, Karachi, with all accessories and appurtenances for Rs.12,750.00. The boundaries of the houses are as follows:
    North-----House of Abid Noor son of Abdullah
    South-----Govt Primary School.
    East-------House of Naveed Ahmad.
    West-----Open plot belonging to Ch. Waqas Jutt

    2. That the plaintiff requested the defendant to specifically perform the agreement on his part, to accept the sum of Rs.12,750,00 and to execute the conveyance of sale in plaintiff’s favor, but the defendant has not done so, and a week ago refused to convey the house to plaintiff.

    3. That the plaintiff has been and is still ready and willing specifically to perform the agreement on his part of which the defendant has had notice.

    4. That the cause of action arose against the defendant on 12th August 2014, the date by which the defendant had stipulated to execute and sign a conveyance of sale in favor of the plaintiff.

    5. That the agreement was signed at Karachi and the property to question is also situate in Karachi, the Civil Court at Karachi has, therefore, jurisdiction to try the suit.

    6. That the value of the subject-matter of the suit for the purposes of Court-fee and jurisdiction is Rs. 12,755.00.

                                It is, therefore, respectfully prayed that a decree for possession 
                                through specific performance of House No.48, Gulshan Colony, 
                                Karachi, be passed in favor of the plaintiff against defendant 
                                And the defendant be ordered to perform the agreement                 
                                specially And do all such acts as may be necessary to put the 
                                plaintiff in full Possession of the did property and to pay the                 
                                costs of suit.
                                Dated: 4th January 2015.

                                                                                                              Syed Noor Ali
                                                                                                                   Through
                                                                                                    Hafeez ul Rahman Advocate.

    Verification
    Verified at Karachi, this 4th day of January, 2015, that the contents of plaint are true to the best of my knowledge and beliefs.  
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    Item Reviewed: Draft of Suit for Specific Performance Rating: 5 Reviewed By: Usman Ali
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