A.B., the above named plaintiff, states as follows:–
1. On the …… day of …… 20….., the plaintiff and defendant entered into an agreement, in writing, and the
original document is hereto annexed. The defendant was absolutely entitled to the immovable property
described in the agreement.
2. On the …… day of ….. 20….., the plaintiff tendered …… rupees to the defendant, and demanded a transfer
of the said property by a sufficient instrument.
3. On the …… day of ….. 19…., the plaintiff again demanded such transfer. [Or the defendant refused to
transfer the same to the plaintiff.]
4. The defendant has not executed any instrument of transfer.
5. The plaintiff is still ready and willing to pay the purchase-money of the said property to the defendant.
[As in paras 4 and 5 of Form No. 1.]
8. The plaintiff claims–
(1) that the defendant transfers the said property to the plaintiff by a sufficient instrument [following the
terms of the agreement];
(2) …… rupees compensation for withholding the same.