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    In The Court of Senior Civil Judge, Lahore

    Uploaded by

    Amina Aamer
    The plaintiff Jan Muhammad Malik filed a suit against the defendant Qazi Wajid Khoso for specific performance of an agreement for the sale of property. According to the agreement, the defendant agreed to sell his house to the plaintiff for Rs. 1,000,000, with Rs. 100,000 paid as earnest money. The defendant failed to execute a registered sale deed and transfer the property to the plaintiff by the target date of November 1, 2001 as stated in the agreement. The plaintiff is seeking a court order for the defendant to transfer ownership of the property in exchange for the remaining Rs. 900,000 owed.

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    In The Court of Senior Civil Judge, Lahore

    Uploaded by

    Amina Aamer
    33 views2 pages
    The plaintiff Jan Muhammad Malik filed a suit against the defendant Qazi Wajid Khoso for specific performance of an agreement for the sale of property. According to the agreement, the defendant agreed to sell his house to the plaintiff for Rs. 1,000,000, with Rs. 100,000 paid as earnest money. The defendant failed to execute a registered sale deed and transfer the property to the plaintiff by the target date of November 1, 2001 as stated in the agreement. The plaintiff is seeking a court order for the defendant to transfer ownership of the property in exchange for the remaining Rs. 900,000 owed.

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    plaint (2)

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    The plaintiff Jan Muhammad Malik filed a suit against the defendant Qazi Wajid Khoso for specific performance of an agreement for the sale of property. According to the agreement, the defendant agreed to sell his house to the plaintiff for Rs. 1,000,000, with Rs. 100,000 paid as earnest money. The defendant failed to execute a registered sale deed and transfer the property to the plaintiff by the target date of November 1, 2001 as stated in the agreement. The plaintiff is seeking a court order for the defendant to transfer ownership of the property in exchange for the remaining Rs. 900,000 owed.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    33 views2 pages

    In The Court of Senior Civil Judge, Lahore

    Uploaded by

    Amina Aamer
    The plaintiff Jan Muhammad Malik filed a suit against the defendant Qazi Wajid Khoso for specific performance of an agreement for the sale of property. According to the agreement, the defendant agreed to sell his house to the plaintiff for Rs. 1,000,000, with Rs. 100,000 paid as earnest money. The defendant failed to execute a registered sale deed and transfer the property to the plaintiff by the target date of November 1, 2001 as stated in the agreement. The plaintiff is seeking a court order for the defendant to transfer ownership of the property in exchange for the remaining Rs. 900,000 owed.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    In the Court of Senior Civil Judge, 

    Lahore
     

         
    Ticket
     
     
    Jan Muhammad Malik S/o.  
    Qazi Wajid S/o. Auyb
    Jamsheed Zafar, resident of  
    Khoso, resident of 9 –
    18 – Shadman Versus
    Shadman Colony, Lahore
    Colony, Lahore  
    (The Defendant) 
    (The Plaintiff)   

    Suit: For Specific Performance of the Agreement

    Respectfully submitted as under:---

    1.      That the Plaintiff and the Defendant entered into an agreement mutually wherein the
    Defendant agreed to transact the sale bargain of his property number 45 – Shadman Colony,
    Lahore, owned and possessed by him, the detail of which is given hereunder:---

    a)      South:             House owned by Ms. Sana Begum (Advocate).


    b)      East:                Clinic owned by Dr. Reema Shan (Government Servant).
    c)      West:               House owned by Madam Fareeha Pervaiz (Mill Owner).
    d)     North:             A thoroughfare.

    A copy of the agreement for sale of the house in question is attached.

    2.      That as per terms and conditions of the aforementioned agreement the total sale price of the
    house in question was fixed at Rs. 1,000,000/- (Rupees one million only) out of which a sum
    of Rs. 100,000/- (Rupees one hundred thousand only) was received by the Defendant as
    earnest money from the Plaintiff, a receipt of which is attached. According to the agreement
    the Defendant was bound to accept and receive the balance amount of Rs. 900,000/- (Rupees
    nine hundred thousand only) from the Plaintiff and to execute a sale deed duly registered in
    favour of the Plaintiff on the target date, i.e., November 01, 2001, which was written in the
    agreement before the Sub-Registrar, Lahore.

    3.      That the Defendant failed to perform his part of the contract to execute a registered sale
    deed in favour of the Plaintiff by accepting the balance payment of the total consideration
    money by the Plaintiff despite many requests made in that behalf, but the Defendant
    miserably failed to do so whereas the Plaintiff is ready and willing to perform his part of
    contract.

    4.      That a copy of the registered notice dated November 01, 2002, requesting the Defendant to
    deliver the possession of the house in question after payment of the full price from the
    Plaintiff and execute a registered instrument.
    5.      That the Plaintiff has been left with no remedy except to institute the present suit against the
    Defendant.

    6.      That the cause of action accrued in favour of the Plaintiff against the Defendant firstly on
    November 01, 2001, when the agreement to sell was struck between the parties and secondly
    on December 01, 2001, when the Defendant failed to execute a registered sale deed on the
    basis of the said agreement and to deliver the vacant possession of the demised property.

    7.      That the disputed property is situated at Lahore, the parties also reside at Lahore and the
    agreement to sell was executed at Lahore, therefore, this Honorable Court has got the
    Jurisdiction to entertain and proceed this suit.

    8.      That the value of the suit for the purpose of Court Fee and Jurisdiction has been fixed at Rs.
    1,000,000/- (Rupees one million only) on which the maximum Court Fee worth Rs. 15,000/-
    (Rupees fifteen thousand only) has been paid.

    It is, therefore, respectfully prayed that a decree for possession through specific performance of
    the house, the description of which is detailed above may kindly be passed in favour of the
    Plaintiff against the Defendant with the payment of Rs. 900,000/- (Rupees nine hundred
    thousand only) payable as such by the Plaintiff in full and final satisfaction of the sale price with
    cost.

    Plaintiff
    through
    Mustafa Qureshi
    Advocate
      Wahdat Road, Lahore
     
    Verification: Verified at Lahore today the 8th day of January 2002, that the contents of
    Paragraphs 1 to 5 are correct and true in the best of my knowledge and the remaining
    Paragraphs from 6 to 8 are believed by me to be true and correct.

     
      Plaintiff’s Signature

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