02 June 2010
first you have to describe about the property. 2) Defendant agreed to sell the property to the plaintiff for Rs. for his family necessity. By agreeing to the plaintiff's conditions he executed the(regd/unregd) agreement of sale in the name of the defendant by taking token money of Rs. out of total sale consideration of Rs.... 3) Defendant failed to exeucte the regd., sale deed in favour of the plaintiff as agreed, inspite of several requests defendant failed to exeucte the regd., sale deed in favour of the plalintiff. As such plaintiff issued a legal notice to the defendant that he was and is ready and willing to purchase the suit property by paying balance amount of Rs.....9 this the body of the plaint) As usual regarding court fee, jurisdiction, etc., are to averred in the plaint. Prayer : For the reasons stated about plaintiff most humbly prays: i) suit may kindly be decreed in favour of the plaintiff directing the defendant to exeucte the regd., sale deed in his name by taking the balance amount of Rs.''' ii) If the court comes to the conclusion that specific performance cannot be granted then defendant may kindly be directed to pay the earnest money with an interest.
This is the consized format of plaint. You can add according to your facts.