Cause of Action, for order 7 rule 11 application

If you have already engaged an advocate to fight your case, follow his advice.  Though it may be true that the court cases may drag to decades, I have seen in cases, wherein the Judge himself  on his own appoints Advocate Commissioner with directions to record the evidence within a month and closes hearing only one defendant and plaintiff and states that Judgment is reserved without hearing any of the other defendants.  Then if the appeal goes to higher court, they drag the case to decades.

What is the reply by you for his notice.

In our reply to their notice, we stated that (i) as per MOU, it was their obligation to submit to us a DRAFT agreement for our approval which they never did, hence, there is no draft for us to approve and execute, and (ii) without prejudice to that, duration of MOU had already expired and we were prepared to execute sale deed against full payment immediately, and (iii) as regards their massive claim for damages due to our non-execution of agreement, we offered to move court or arbitration to decide their claim for compensation and our claim for interest on delays in payment.

After such reply, they just filed suit. During cross examination, they admitted in court that they had received our offer to execute sale deed and even to treat MOU as Agreement, 3 times which they could not accept because they did not have money available. They also admitted that they never asked us for additional time to arrange for these funds.