This being a complaint, there is no need to incorporate the para relating to the grounds. The complaint being against the Partnership firm for its failure to construct the building as per agreement, the pleadings are required to be restricted to the deficiency of service on the part of the Firm, and as such the opposite parties should be the Firm and the partners of the firm. There is an0ther problem u may have to take care. what u have purchased is an undivided portion of a larger extent of land. Unless the land sold to u is demarcated and subdivided with clear boundaries, the construction part of the agreement may not be implementable. The opposite party may raise this as a defence against ur claim of deficiency in service. The reliefs prayed in the compalint shold be more specific. Ur claim for damages should be quantified. Limitation to file the compalint is two years from the date the first cause has arisen.I feel u should discuss with ur advocate and finalise the complaint.