Plaint to enforce an agreement to sell immovable property, seeking execution of the sale deed and delivery of possession, with readiness and willingness pleaded.
When to use this draft
Use where an agreement to sell exists, the buyer is ready and willing to perform, and the seller refuses to execute the sale deed.
Essential contents
- Agreement to sell with date, consideration and payment schedule
- Payment already made with receipts and witnesses
- Continuous readiness and willingness of the buyer
- Notice calling upon the seller to perform
- Prayer for execution of sale deed and possession, alternatively refund
Drafting notes
- Readiness and willingness must be pleaded from the date of agreement to the date of suit - not just at filing.
- Deposit the balance consideration in court to demonstrate bona fides.
- Plead in the alternative for recovery of earnest money with damages.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.