How to draft a suit for a specific performance using AI

In this article, you will learn a systematic approach to drafting a suit for specific performance using AI that can protect your clients’ most valuable contracts. Whether you are starting out or are a seasoned lawyer, understanding how to leverage AI for comprehensive legal drafting will revolutionise your practice.

Introduction

The moment my sir walked into the office that afternoon, I knew something was wrong. His usual confidence was replaced by worry on his face, which told a story before he even spoke.

“Beta, come to my cabin. We need to talk about something serious.” 

I have been working with him for over six years, long enough to know when he was genuinely concerned about something or that something was bothering him. 

He started by saying, “You remember that agreement for sale we signed with our landlord six months ago? The one where he agreed to sell this entire building to all of us tenants?”.

Of course, I remembered.

I was part of the discussions and negotiations that took place in our conference room. I remember my sir being excited about finally owning a workspace instead of just renting it. 

All the tenants in the building had come together and worked out a deal to buy the property from the landlord. Everything was signed and even agreed upon. The agreement clearly stated that he would transfer the building to our proposed society within three months.

“So what is the problem, sir?”

His face darkened. “Instead of taking steps towards complying with the terms of the agreement, he has filed eviction suits against the tenants of this building. He claimed that he needed the property back for redevelopment, completely ignoring our valid and subsisting sale agreement.”

My heart sank. This was not just an office, it was the place where I learnt everything about practicing law, where we celebrated our wins, where my sir had patiently taught me how to draft my first petition.

“But can he do that legally? I mean, we have a signed agreement, right?”

“Exactly the point,” my sir said, leaning forward. “He thinks he can just tear up our agreement and sell the entire building to some developer for much more money. But I will not let that happen.”

“So what do we do, sir?”

“We fight for specific performance”, he said firmly. I do not want any compensation; I want him to honor his promise and transfer this building to us as agreed. Money cannot replace this exact location, this office where I have built my practice for over 50 years.”

And that is precisely what specific performance does: it forces people to keep their word, not just pay for breaking it.

I asked my sir if I could draft the plaint. He immediately said yes. 

That evening, as I sat down to draft our plaint.

I realised something had changed in how we approach legal drafting. The AI tools on my laptop are no longer just fancy word processors; they have become sophisticated legal assistants. 

With the right prompts and guidance, AI could help me structure the plaint, ensuring I did not miss out on any essential averments. 

However, there is a catch: It could help me draft faster and more comprehensively, but it cannot replace the legal acumen needed to craft a watertight case. 

The real skill lies in knowing how to guide the AI, what questions to ask it, and most importantly, how to verify and refine its output to meet the specific requirements of Indian courts.

Today, in this article, you will learn how I combined my traditional legal knowledge with AI assistance to create a well drafted plaint that is both legally sound and strategically compelling.

Are you excited to learn more about it? 

Before we dive into the nitty-gritty of drafting, you must understand what you are working with.

What is the legal framework that governs a suit for specific performance of a contract?

That conversation with my sir got me thinking about the legal foundation that would support our fight. 

The primary legal framework that governs specific performance is the Specific Relief Act, 1963

Let us look at some important provisions of the Act.

Section 10: When can you get specific performance?

Think of it like this, sometimes just getting your money back is not enough to fix the problem. The court will step in and force someone to keep their promise when you are dealing with something unique that cannot be replaced with money.

For example, if you wanted to buy your grandmother’s ring that has been passed down through generations (since it has irreplaceable sentimental value and family history), the court might force the seller to actually sell it to you instead of just returning your money. But they will only do this if it seems fair and reasonable.

Section 12: Can you get part of the contract enforced?

Let us say someone was supposed to do a big job for you, but they only messed up a small part of it. The court can say, “Okay, keep the good work they did, and we will make them pay you money for the part they did not do properly.”

But here is the catch: if the part they messed up is really important and you cannot separate it from the rest of the work, then the court might throw up their hands and say, “This is too complicated, we cannot help.”

Section 14: When can you not get specific performance?

The court will basically tell you “no way” if:

• Money can actually solve your problem
• You are trying to force someone to do personal work (like making someone sing at your wedding or paint you a picture)
• The contract is so unclear that nobody knows what it really means
• The court would have to constantly watch over and supervise the work (like babysitting a long-term project)
• The contract, which is in its nature determinable.

Section 15: Who can ask for specific performance?

It is not just the person who signed the contract.

The following people can ask the court to force someone to keep their promise:

• The person who actually signed the contract
• Their representative (like a lawyer acting for them)
• Someone who benefits from the contract even if they did not sign it (like if you are a beneficiary of a trust)

Section 16:When specific performance cannot be enforced:

Specific performance cannot be enforced in favor of a person who:

• Has obtained substituted performance of the contract under section 20; or
• Has become incapable of performing, or violates any essential term of the contract that remains to be performed by him, or acts in fraud of the contract, or willfully acts at variance with or in subversion of the relation intended by the contract; or
• Fails to prove that he has performed or has always been ready and willing to perform the essential terms of the contract, which are to be performed by him (except terms prevented or waived by the defendant).

Note: For money contracts, the plaintiff does not need to actually tender money unless directed by the court, but must prove performance or readiness to perform according to the contract’s true construction.

Section 21: Can you get money and specific performance?

Yes, but only if you specifically ask for compensation in your lawsuit along with specific performance. You must keep the following points in mind:

• You can claim both specific performance and compensation for breach in the same suit.
• If the court refuses specific performance but finds a breach, it can award compensation.
• If the court grants specific performance, but it is not enough, it can also award additional compensation
• But you must claim compensation in your original suit as per Section 21(5). If you do not ask for it initially, you cannot file a fresh suit later just for compensation. However, the court can allow you to amend your plaint to include a compensation claim at any stage of the proceedings.

I have prepared an infographic for a brief overview of the legal framework:

Now that you have understood the legal framework that governs specific performance, we will learn how to draft a suit for specific performance using AI.

You can refer to my article on how to draft a plaint using AI to understand what the essential elements are in a plaint.

How to draft a suit for specific performance using AI?

I will teach you to draft a complete specific performance suit by building it step-by-step with AI. 

Step 1: Creating the title and party structure

Instead of asking AI to write the entire plaint (which leads to generic, incomplete drafts), you will construct it methodically.

So I give the following prompt to ChatGPT:

“Create a title page template for a specific performance suit in Bombay High Court. Include:

• Full court heading: ‘IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION’
• Suit number blank for 2025
• Plaintiff section: 15 parties total – show first three as examples (Metro Holdings Pvt. Ltd registered under the Companies Act,2013 at Office Premises No.201, Sunrise Engineering Co. P Ltd registered under the Companies Act,2013 at Office Premises No.202, Rajesh Kumar Sharma CA at Office Premises No.203, all in Green Tower building, 45/47 Business Street, Andheri East, Mumbai. Then write ‘[Continue pattern for remaining 12 plaintiffs with Premises No.204-215]’
• Defendant section: ABC Realty Partners (partnership firm) having an address at Office at 15/16, Silver Complex, Linking Road, Bandra (West), Mumbai-400 050.  Suresh Patel, Ajit Patel, and Meena Patel as individual partners, all having an address at 22/24, Palm Avenue, Bandra (West), Mumbai-400 050.  
• Use proper legal formatting with closing brackets and designations
• End with ‘THE PLAINTIFFS ABOVENAMED STATE AS UNDER‘”

This is the result generated by ChatGPT

“IN THE HIGH COURT OF JUDICATURE AT BOMBAY

    ORDINARY ORIGINAL CIVIL JURISDICTION

    SUIT NO._______ OF 2025

1] Metro Holdings Pvt. Ltd        

a company duly registered         

under the Companies Act, 2013     

having its office at Office      

Premises No.201, 2nd Floor,       

Green Tower, 45/47 Business       

Street, Andheri (East),          

Mumbai-400 069.                   

2] Sunrise Engineering Co. P Ltd, 

A company duly registered under

the Companies Act, 2013 and          

having its office at Office     

Premises No.202, 2nd Floor,      

Green Tower, 45/47 Business      

Street, Andheri (East),          

Mumbai-400 069.                   

3] Rajesh Kumar Sharma,          

a Chartered Accountant           

of Mumbai Indian Inhabitant      

Having his office     

at Office Premises No.203,       

2nd Floor, Green Tower,          

45/47 Business Street,           

Andheri (East), Mumbai-400 069.  

[Continue pattern for the remaining 12 plaintiffs 

V/s

1] M/s ABC Realty Partners       

A Partnership firm having its    

Office at 15/16, Silver         

Complex, Linking Road,           

Bandra (West), Mumbai-400 050.  

2] Suresh Chandrakant Patel      

3] Ajit Ramesh Patel            

4] Meena Suresh Patel           

All of Mumbai Indian            

Inhabitants, being the          

partners of Defendant No.1      

and having their address        

at 22/24, Palm Avenue,          

 THE PLAINTIFFS ABOVENAMED STATE AS UNDER:”

This is your legal skeleton, like building the frame of a house before adding walls. You are creating the formal structure that courts expect to see. 

By showing the first few examples with actual names and details, you get a clear pattern to follow for the remaining parties while still maintaining efficiency.

Why this approach works:

• You get the tedious formatting done perfectly without thinking about facts yet
• Creates a reusable template for any multi-party commercial dispute
• AI handles the boring work while you focus on strategy

Step 2: Opening factual foundation

You are now laying the legal foundation with actual details that make sense. 

This creates a realistic case scenario while teaching the structure. 

The specific details (Green Tower, Survey No.456, family relationships) make it feel like a real case rather than a template.

So I give the following prompt:

“Create the first 5 paragraphs after ‘THE PLAINTIFFS ABOVENAMED STATE AS UNDER’ for a specific performance suit. Use these details:

Paragraph 1: Plaintiffs are monthly tenants of defendants in Green Tower building on 800 sq mtrs land, Survey No.456 of Andheri Division, at 45/47 Business Street Andheri East Mumbai-400069, with exhibit references A for the property and B for each premises. Paragraph 2: Defendant No.1 ABC Realty Partners is landlord, Defendants 2-4 are partners, Defendant No.3 Ajit Patel is Managing Partner, Defendant No.2 Suresh is father of Ajit, Defendant No.4 Meena is wife of Ajit, engaged in real estate business Paragraph 3: Suit is for specific performance of sale agreement, not landlord-tenant dispute, background provides context Paragraph 4: Plaintiffs constrained to file due to defendants’ mala fide conduct reneging on concluded contract for sale to proposed co-operative society. Paragraph 5: Relevant facts leading to filing are articulated hereinafter.

Use formal legal language.”

This is the result generated by ChatGPT:

“1. The Plaintiffs are the monthly tenants of the Defendants occupying different premises as set out in the title of the Plaint in respect of the building known as “Green Tower” (hereinafter referred to as “the said building”) constructed on a plot of land admeasuring about 800 sq. mtrs. and bearing Survey No.456 of Andheri Division and being lying and situate at 45/47, Business Street, Andheri (East), Mumbai-400 069, (hereinafter referred to as “the said property”) and more particularly described in EXHIBIT “A” hereto. A tabular chart setting out the details of the premises occupied by each of the Plaintiffs is annexed hereto as EXHIBIT “B”.

2. The Defendant No.1 is a Partnership Firm with its office at the address set out in the cause title hereinabove. The Defendant No.1 is the present landlord of the said property. The Defendant Nos. 2 to 4 are the partners of the Defendant No.1. The Defendant No.3 Ajit Ramesh Patel is the Managing Partner of the Defendant No.1. The Defendant No.2 Suresh Chandrakant Patel is the father of the Defendant No.3 and the Defendant No.4 Meena Suresh Patel is the wife of the Defendant No.3. The Defendants are engaged in the business of real estate including buying and selling of lands and buildings.

3. The present suit has not been filed on the basis of the landlord-tenant relationship between the parties but the suit is for specific performance of the Agreement for Sale (as more particularly set out hereinafter) between the parties in their capacity as Purchasers/Vendors. The facts relating to the landlord-tenant relationship are set out to give narration of the background in which the suit transaction took place.

4. The Plaintiffs have been constrained to file the present proceedings (in their capacity as Purchasers) due to the mala fide conduct of the Defendants (Vendors) who are inter alia seeking to renege on a valid, binding and concluded contract arrived at between the parties apropos the suit property whereunder the Defendants had agreed to sell and convey the said property to the Plaintiffs/Co-operative society of occupants proposed to be formed. In the aforesaid circumstances, the Plaintiffs have been compelled to file the present proceedings inter alia seeking a declaration and specific performance of the valid, binding and concluded contract arrived at between the parties.

5. The relevant facts that have culminated in the filing of the present proceedings are briefly articulated hereinafter.”

Why this approach works:

• Establishes a credible factual foundation that courts expect
• Shows proper legal relationship descriptions
• Sets up a clear contract vs landlord-tenant distinction
• Creates a sympathetic plaintiff narrative

Step 3: Chronological narrative and agreement formation

Now you are building the chronological story with realistic details and proper legal formatting. 

It is essential to structure complex factual narratives effectively by providing specific dates and names, thereby making the narrative feel more genuine.

So I give the following prompt to ChatGPT:

“Create paragraphs 6-12 covering how the sale agreement was formed. Use these details and structure with proper sub-points:

Para 6: Facts about property acquisition

• Prior to 15th March 2020, the landlady of the suit property was Mrs. Kavita Reddy.
• Plaintiffs were tenants under her.
• She died on 15th March 2020 in Mumbai.
• Under her Will, her sons Mr. Ravi Reddy and Mr. Sunil Reddy were appointed Executors.
• The Executors sold the property to the Defendants for ₹3.5 crore via a registered Deed of Conveyance dated 10th July 2022.
• From that date, Defendants became the landlords.
• Plaintiffs crave leave to refer to and rely upon the said Deed as and when produced.

Para 7: Proposal for sale to Plaintiffs

• After acquisition, Defendant No.3 (Ajit Ramesh Patel, Managing Partner) approached the Plaintiffs with a proposal to sell the building to them.

Para 8: Negotiations and revised structure

• Initially, it was proposed that each Plaintiff would purchase their own premises.
• Later, it was agreed that:
  (i) Plaintiffs would enter into a joint agreement to purchase the entire property.
  (ii) A cooperative housing society would be formed.
  (iii) Defendants would execute a Deed of Conveyance in favour of that society.

Para 9: Final agreement

• Several meetings occurred between Defendant No.3 and Plaintiffs.
• On 5th April 2023, a valid and binding agreement was entered into during a meeting at Plaintiff No.3’s office.
• Defendant No.1 addressed a writing dated 5th April 2023 to the Plaintiffs recording this agreement.
• Plaintiffs counter-signed the same.

Para 10: Binding language in agreement

• The agreement stated that until a formal MoU was executed, the terms would remain binding on both parties. Annex it as Exhibit C.
• Include the following extract:
  “On the basis of the aforesaid terms which constitutes a binding contract we will execute with you a MOU on appropriate stamp paper in due course of time and till that time the terms agreed herein will remain the terms of the contract binding with both parties.”

Para 11: Plaintiffs prepare MoU and cheques

• Plaintiffs prepared a draft MoU elaborating on agreed terms.
• Cheques aggregating 10% of the consideration were also prepared as earnest money.

Para 12: Defendants send final MoU

• On 15th May 2023, Defendant No.3 emailed the final MoU to Plaintiff No.3 and others.
• The MoU has the same terms of the written contract dated 5th April 2023..
• Plaintiffs accepted the MoU and agreed to execute it at a mutually convenient date. Annex email and attachment as Exhibit D and E.

Include proper exhibit references and formal language.”

This is the result generated by ChatGPT:

“6. The relevant facts pertaining to the acquisition of the suit property by the Defendants are as under:

(i) Prior to 15th March 2020, the late Mrs. Kavita Reddy was the landlady of the building standing on the said property. The Plaintiffs were occupying their respective premises for several years as the tenants of the aforesaid Mrs. Kavita Reddy.

(ii) The aforesaid Mrs. Kavita Reddy died at Mumbai on or about 15th March 2020 leaving behind her Last Will and Testament wherein she appointed her sons Mr. Ravi Reddy and Mr. Sunil Reddy as Executors of her estate.

(iii) The aforesaid Executors by and under a registered Deed of Conveyance dated 10th July 2022 sold, transferred and assigned unto the Defendants the said property for a consideration of Rs.3,50,00,000/- (Rupees Three Crores Fifty Lakhs Only) on the terms and conditions more particularly contained therein. The Plaintiffs crave leave to refer to the said Deed of Conveyance as and when produced.

(iv) In the circumstances as aforesaid, on and from 10th July 2022 the Defendants became the landlords of the said property.

7. After acquiring the said property, Defendant No.3 Ajit Ramesh Patel as Managing Partner and on behalf of the Defendants approached the Plaintiffs hereto with a proposal to sell and transfer the said building and said property to the Plaintiffs.

8. Initially, the negotiations proceeded on the basis that each of the Plaintiffs would purchase the premises in their respective occupation from the Defendants and a condominium of the purchasers would be formed. However since the same was not feasible, it was agreed between the parties herein that:

(i) the Plaintiffs would enter into an agreement with the Defendants to purchase the said property from the Defendants,

(ii) the Plaintiffs would form a co-operative housing society,

(iii) A Deed of Conveyance would be executed by the Defendants of the said property in favour of the said proposed Society to be formed by the Plaintiffs.

9. Several meetings were held between the Plaintiffs and Defendant No.3 (representing all the Defendants). On or about 5th April 2023 in a meeting held in the office of Plaintiff No.3 a valid, legally binding and concluded agreement was arrived and a writing dated 5th April 2023 was addressed by the Defendant No.1 to the Plaintiffs recording the valid, binding and concluded agreement arrived at by and between the parties. The same was also countersigned by and/or on behalf of the Plaintiffs.

10. A copy of the aforesaid valid, binding and concluded contract as recorded in a writing dated 5th April 2023 addressed by the Defendants to the Plaintiffs and duly confirmed by all the Plaintiffs is annexed hereto as EXHIBIT “C”. The aforesaid agreement clearly provided that the terms recorded therein were a binding contract and that the terms would be binding on both parties. The relevant portion reads thus:

“On the basis of the aforesaid terms which constitutes a binding contract we will execute with you a MOU on appropriate stamp paper in due course of time and till that time the terms agreed herein will remain the terms of the contract binding with both parties.”

11. The parties had thus arrived at a valid, binding and concluded contract containing all the essential terms of the contract and had envisaged the preparation and execution of a formal Agreement on the aforesaid terms to give the contract a formal shape. In terms of the aforesaid contract arrived at between the parties, the Plaintiffs prepared a draft Memorandum of Understanding on the basis of the aforesaid valid, concluded and binding contract and included a few elaborations of the terms agreed therein.

12. The Defendant No.3 by his email dated 15th May 2023 forwarded to the Plaintiff No.3 and other representatives the final Memorandum of Understanding to be executed by the parties in terms of the written contract dated 5th April 2023 (“the said final Memorandum of Understanding”). A copy of the email dated 15th May 2023 along with its attachment is annexed hereto as EXHIBITS “D” and “E” respectively. The Plaintiffs accepted the final Memorandum of Understanding emailed by the Defendants and agreed to execute the same at a mutually agreed time and date.”

Why this narrative works: Shows a clear progression from property acquisition to serious negotiations to binding agreement, with written evidence at each step.

Step 4: Breach and defendants’ bad faith conduct

This section builds the “bad faith” case with specific details and proper legal formatting. 

So I give the following prompt to ChatGPT:

“Create paragraphs 13-20 covering the defendants’ breach. Use these details with proper formatting:

Para 13:

• On or around 20th June 2023, a meeting took place between Plaintiff No.3, Plaintiff No.8, and Defendant No.3.
• Defendant No.3 demanded that Rs.50,000/- for transfer of property in the revenue records be paid by Plaintiffs.
• This demand was contrary to the agreement.
• Plaintiffs objected, stating:
  (i) The agreement clearly made the Defendants responsible for such charges.
  (ii) It is standard practice in Mumbai that sellers bear such charges.
  (iii) Defendants were already making a significant profit (purchase in 2022: ₹3.5 crore; resale in 2023: ₹8 crore+) while retaining valuable commercial premises.
  (iv) Such nominal demands should not derail a valid agreement.

Para 14:

• Plaintiffs issued a legal notice dated 25th June 2023 calling upon Defendants to perform the agreement.
• Defendants replied via letter dated 30th June 2023 stating the matter had been referred to legal advisors.
• These letters should be referred to as Exhibits “F” and “G” respectively.

Para 15:

• Following this, Defendant No.3 called Plaintiff No.3 and expressed displeasure over the legal notice.
• Plaintiffs replied through their Advocates by letter dated 5th July 2023, explaining why notice was necessary due to Defendants’ conduct.
• Plaintiffs affirmed they did not intend to damage relations.
• Refer to this letter as Exhibit “H”.

Para 16:

• Defendants responded through their Advocates by letter dated 20th July 2023, falsely alleging:
  (i) That the letter dated 5th April 2023 was only an expression of intent;
  (ii) That no final terms were settled;
  (iii) That measurements of the property were unclear;
  (iv) That they no longer wished to sell.
• This letter is Exhibit “I”.

Para 17:

• Plaintiffs replied through Advocates by letter dated 25th July 2023, denying all allegations and reaffirming the existence of a binding agreement.
• This letter is Exhibit “J”.

Para 18:

• Plaintiffs again called upon Defendants to perform the concluded contract via letter dated 15th August 2023, failing which they would initiate proceedings.
• Refer to this as Exhibit “K”.

Para 19:

• The Defendants’ conduct shows lack of bona fides and intention to evade obligations.
• Their allegations are contradicted by their own prior actions:
  (i) Defendant No.3 had inspected all premises before the agreement;
  (ii) An architect, Mr. Rohit Gandhi, was appointed to measure areas;
  (iii) The agreement included a detailed formula to compute price per carpet area;
  (iv) Plaintiffs had kept 10% earnest money (₹80 lakhs) ready as per agreement terms.

Para 20:

• The Defendants’ claims in their letter dated 20th July 2023 are false, afterthoughts, and intended to avoid the valid, binding and concluded contract.”

This is the result generated by ChatGPT:

“13. Subsequently, on or around 20th June 2023, at the behest of the Defendant No.3, a meeting was held, which was attended by the Plaintiff No.3 and Plaintiff No.8 on behalf of the Plaintiffs and the Defendant No.3 on behalf of the Defendants. During the course of the said meeting, the Defendant No.3 insisted that the charges of approximately Rs.50,000/- for transfer of property in the name of the Defendants in the revenue records should be borne and paid by the Plaintiffs. The Defendant No.3’s aforesaid demand was not only contrary to, but also in breach of the valid, concluded and binding contract and in light of the same, the Plaintiffs inter alia pointed out the following:

(i) The demand was contrary to the terms of the agreement under which such charges were to be borne by the Defendants alone;

(ii) It was usual practice in Mumbai that such charges for making a complete title are borne by owners before conveying property;

(iii) Against the purchase price of Rs.3,50,00,000/- paid in 2022, the Defendants were selling for an excess of Rs.8,00,00,000/- while retaining valuable ground floor commercial premises;

(iv) The Defendants should not go against agreed terms merely for nominal transfer charges.

14. In the circumstances aforesaid, the Plaintiffs were compelled to address a legal notice dated 25th June 2023 through their Advocates inter alia recording the relevant facts and calling upon the Defendants to specifically perform the said agreement. The Defendants by their letter dated 30th June 2023 acknowledged receipt and stated they had given it to their legal adviser who would reply within 2-3 weeks. Copies of the aforesaid letters are annexed hereto as EXHIBITS “F” and “G” respectively.

15. Immediately thereafter, Defendant No.3 telephoned Plaintiff No.3 and expressed displeasure at the legal notice, stating plaintiffs should have called for a discussion instead of issuing notice. The Plaintiffs by their Advocates’ letter dated 5th July 2023 explained why the notice became essential due to the defendants’ extreme stand of illegally cancelling the concluded contract and that the Plaintiffs had no intention of spoiling relations. A copy of the letter is annexed hereto as EXHIBIT “H”.

16. Instead of specifically performing their obligations, the Defendants through their Advocates’ letter dated 20th July 2023 sought to raise false, baseless and irrelevant claims for the first time. It was claimed that the letter dated 5th April 2023 recorded only some terms for future discussion, that the terms were not finalized, that the writing did not show the actual area in possession, and that the defendants did not want to sell the property. A copy of the letter is annexed hereto as EXHIBIT “I”.

17. The Plaintiffs by their Advocates’ reply dated 25th July 2023 denied all false allegations and put the correct facts on record. The Plaintiffs hereby repeat and confirm all statements contained in the said letter and deny allegations contrary thereto. A copy of the letter is annexed hereto as EXHIBIT “J”.

18. The Plaintiffs by their Advocates’ letter dated 15th August 2023 called upon the Defendants to specifically perform the concluded agreement and informed that failure to do so would result in legal proceedings. A copy of the letter is annexed hereto as EXHIBIT “K”.

19. The conduct of the Defendants is grossly lacking in bona fides and is a dishonest attempt to back out of a valid, binding agreement. The allegations raised by Defendants are belied by their contemporaneous conduct, illustratively:

(i) Prior to the agreement, Defendant No.3 had inspected all premises and appointed Mr. Rohit Gandhi, an architect, to measure areas;

(ii) After knowing all facts and measurements, the agreement dated 5th April 2023 and the final MOU were entered into.

(iii) The agreement contained a complete formula for determining the purchase price based on carpet area measurements;

(iv) 10% earnest money totaling Rs.80,00,000/- was prepared by all tenants as per the agreement terms.

20. It is clear that the defendants’ claims in their letter dated 20th July 2023 are false and nothing but an afterthought with a view to avoiding and rescinding the valid, concluded and binding contract.”

Why this approach works: It shows a clear pattern of defendants trying to escape their obligations through shifting excuses and unreasonable demands.

Step 5: Legal claims and prayer clause

This final section converts your story into specific legal demands with realistic monetary claims. 

I give the following prompt to ChatGPT:

“Create paragraphs 21-31 covering legal arguments and reliefs.Maintain the following structure and content:

Para 21:
State that the writing dated 5th April 2023, read with the final Memorandum of Understanding, constitutes a valid, binding, and enforceable contract between Plaintiffs and Defendants. Mention that Plaintiffs are and have always been ready and willing to perform their obligations.

Para 22:
Assert that the Defendants are bound to sell the property described in Exhibit A to the proposed co-operative society through the Plaintiffs acting as promoters, and are liable to specifically perform the said contract.

Para 23:
Repeat readiness and willingness on part of the Plaintiffs. State that the Defendants have refused, neglected, and failed to comply.

Para 24:
Plead entitlement to specific performance, emphasizing that the contract concerns immovable property and that damages are not an adequate remedy.

Para 25:
State that, without prejudice to the above and in the alternative, if specific performance is not granted, Plaintiffs are entitled to ₹5,00,00,000/- as damages for breach, with interest at 18% p.a. from date of suit till realization, against all Defendants jointly and severally.

Para 26:
Plead a separate claim of ₹2,00,00,000/- for mental agony, trauma, and damage to business and personal life, with interest at 18% p.a., payable by Defendants jointly and severally, whether or not specific performance is granted.

Para 27:
Seek a temporary injunction restraining Defendants from dealing with, alienating, encumbering, or creating third-party rights in respect of the suit property, pending disposal of the suit, to prevent grave and irreparable harm.

Para 28:
State that the suit is valued at ₹7,00,00,000/- (₹5 crore for breach and ₹2 crore for mental agony). Maximum court fee of ₹3,00,000/- is paid.

Para 29:
State that the suit is within limitation. Property is in Mumbai. Agreement was executed in Mumbai. Cause of action arose in Mumbai. Hence, Bombay High Court has jurisdiction.

Para 30:
Plaintiffs will rely upon documents, and a list of documents is annexed.

Para 31: Prayer clause (in sub-paragraphs):
(a) Declaration of valid contract (b) Specific performance decree with detailed requirements (c) Alternative damages Rs.5,00,00,000 (d) Mental agony damages Rs.2,00,00,000
(e) Interim injunction against property dealings (f) Costs (g) Other reliefs

Use formal legal language and proper formatting.”

This is the result generated by ChatGPT:

“21. The Plaintiffs submit that the writing dated 5th April 2023 read with the final Memorandum of Understanding constitutes a valid, binding and concluded contract as well as a complete, binding and enforceable agreement for sale between the Plaintiffs and Defendants. The Plaintiffs are ready and willing and have at all times been ready and willing to perform their obligations under the said agreement.

22. In the premise aforesaid, the Plaintiffs submit that there is a valid, binding, concluded and enforceable agreement under which the Defendants are bound and liable to sell the said property described in Exhibit A hereto to the proposed society through the Plaintiffs acting as promoters and the Defendants are bound to specifically perform the said agreement.

23. The Plaintiffs submit that they have always been and are ready and willing to comply with their obligations under the valid, binding contract recorded in the writing dated 5th April 2023. The Defendants have refused, neglected and failed to perform their obligations under the said contract.

24. The Plaintiffs are entitled to specific performance of the concluded contract in terms of the agreement dated 5th April 2023 read with the final Memorandum of Understanding as the agreement relates to immovable property and is of such nature that breach cannot be adequately compensated in terms of money.

25. Without prejudice to the aforesaid and in the alternative, if specific performance cannot be granted for any reason whatsoever, this Hon’ble Court be pleased to pass decree against the Defendants to jointly and severally pay Rs.5,00,00,000/- (Rupees Five Crores Only) alongwith interest at 18% per annum from the date hereof till realization as damages for breach of the agreement.

26. The actions of Defendants have caused loss, mental agony and trauma to Plaintiffs affecting their business and personal lives. Plaintiffs are entitled to damages presently quantified at Rs.2,00,00,000/- (Rupees Two Crores Only) alongwith interest at 18% per annum from the date hereof, payable jointly and severally by Defendants irrespective of whether specific performance is awarded or refused.

27. It is absolutely necessary and in the interest of justice that pending hearing and disposal of the suit, this Hon’ble Court restrain Defendants from dealing with, disposing of, alienating, encumbering or creating any third party rights in respect of the said property as grave irreparable loss will be caused to Plaintiffs if such injunction is not granted.

28. For purposes of court fees and jurisdiction, Plaintiffs value the suit at Rs.5,00,00,000/- being alternative damages plus Rs.2,00,00,000/- being mental agony damages, aggregating Rs.7,00,00,000/- and pay maximum court fees of Rs.3,00,000/-.

29. The suit is filed within time and is not barred by limitation. The suit property is situated in Mumbai, the Defendants carry on business in Mumbai, the agreement was entered into in Mumbai and the entire cause of action arose in Mumbai. This Hon’ble Court therefore has jurisdiction to entertain and try the suit.

30. The Plaintiffs will rely upon documents, a list whereof is annexed hereto.

31. The Plaintiffs, therefore, pray that:

(a) This Hon’ble Court be pleased to declare that there exists a valid, binding, subsisting and enforceable agreement for sale between Plaintiffs and Defendants in respect of the said property described in Exhibit A hereto on the terms set out in the writing dated 5th April 2023, read with the final Memorandum of Understanding;    

(b) The Defendants be ordered and decreed to specifically perform the said contract by executing the final Memorandum of Understanding, transferring the property in Defendant No.1’s name in revenue records, executing registered conveyance deed in favour of the proposed society, delivering all title documents, and doing all acts necessary to give effect to the agreement;

(c) In the alternative to prayer (b), Defendants be decreed to jointly and severally pay Rs.5,00,00,000/- alongwith interest at 18% per annum as damages for breach of agreement;

(d) Defendants be decreed to jointly and severally pay Rs.2,00,00,000/- towards mental agony and loss alongwith interest at 18% per annum;

(e) Pending hearing and disposal of the suit, temporary injunction restraining Defendants from dealing with, disposing of, alienating or encumbering the said property or creating any third party rights therein;

(f) Costs of the present suit;

(g) Such other and further relief as this Hon’ble Court may deem fit in the facts and circumstances of the case.”

Finally, you can ask ChatGPT to collate all results and share the final draft with you.

This is the final draft generated by ChatGPT.

Once the draft is generated, you can make manual edits as per your requirements and finalise it.

This is the final draft with manual edits made in red.

Conclusion

When my senior first shared his concerns about the broken agreement that threatened eviction from his workplace, I knew we needed to act decisively to protect it.

Within hours, we had transformed his anxiety into action with a meticulously crafted suit that left no room for the defendants to escape their obligations.

The secret was not just using AI, it was using it the right way.

Instead of asking AI to write everything at once, we broke it down into small, clear steps. This turned AI from a basic template maker into a smart assistant that helped us cover every important legal point without missing anything.

AI does not replace lawyers, but it makes us much better at our job. You still need to understand the law, check the facts, and plan your strategy. But AI takes care of the boring, repetitive work, so you can focus on winning the case for your client.

Whether this is your first contract case or you have handled hundreds, this step-by-step method will save you time, help you avoid mistakes, and build stronger cases that protect your clients’ rights.

Frequently asked questions (FAQ’s)

1. Can students or junior lawyers use this AI-assisted approach?

Yes, but with supervision. AI helps ensure comprehensive coverage and proper legal formatting, making it an excellent learning tool. However, review by a senior is essential for legal strategy, local court practices, and case-specific nuances that AI cannot capture.

2. How do I prove “readiness and willingness to perform” as required under Section 16(c) of the Specific Relief Act,1963?

Document every step showing your client’s preparedness: arranging finances, preparing earnest money, engaging professionals (architects, lawyers), responding promptly to communications, and attempting performance despite the defendant’s refusal. AI can help systematically present this evidence.

3. Can AI really help draft a legally sound, specific performance suit?

Yes, but with proper guidance. AI excels at structuring legal arguments, ensuring comprehensive coverage of essential averments, and maintaining consistent legal language. However, you must provide clear prompts, verify legal accuracy, and apply strategic thinking that only human legal expertise can provide.

4. What are the essential elements I must prove for specific performance?

You must establish: (1) A valid binding contract with all essential elements, (2) your readiness and willingness to perform, (3) the defendant’s breach or refusal to perform, (4) the inadequacy of monetary compensation, and (5) clean hands doctrine compliance.