तोडगा करार (सर्वसाधारण विवाद)

SETTLEMENT AGREEMENT This SETTLEMENT AGREEMENT is made on [agreement_date] between [first_party], of [first_party_address] (the "First Party"), and [second_party], of [second_party_address] (the "Second Party"). RECITALS A. Disputes and differences have arisen between the parties, as follows: [dispute_background] B. The parties, being desirous of avoiding the expense, delay and uncertainty of litigation, and of preserving cordial relations, have agreed to settle all disputes between them on the terms recorded below. C. The parties have entered into this Agreement freely and voluntarily, after understanding its terms and having had the opportunity to take independent advice. NOW IT IS AGREED AS FOLLOWS: 1. SETTLEMENT TERMS [settlement_terms] 2. SETTLEMENT AMOUNT 2.1 Where an amount is stated below, it shall be paid in full and final settlement of all claims: Amount : Rs. [settlement_amount] Payable by : [amount_payer] If no amount is stated, no money is payable under this clause and the settlement terms in clause 1 apply. 2.2 Payment schedule: [payment_schedule] 2.3 Payment shall be made by traceable banking channel, and a receipt shall be issued for each payment. 3. FULL AND FINAL SETTLEMENT 3.1 The parties agree that the terms recorded above are in FULL AND FINAL SETTLEMENT of all claims, demands, disputes and causes of action between them arising out of or connected with the matters described in Recital A, whether known or unknown, present or future. 3.2 On performance of these terms, neither party shall have any claim of any nature against the other in respect of the said matters. 4. MUTUAL RELEASE Each party hereby releases and forever discharges the other, and the other's family members, employees, officers and representatives, from all claims, actions, proceedings and demands arising out of the matters settled by this Agreement. 5. WITHDRAWAL OF PROCEEDINGS Each party shall, on compliance with the terms above, withdraw or cause to be withdrawn any complaint, case, notice or proceeding filed against the other in respect of the matters settled, and shall render all cooperation necessary for their disposal. 6. NO ADMISSION OF LIABILITY This Agreement is entered into by way of compromise. Nothing in it shall be construed as an admission of liability, wrongdoing or the correctness of any allegation by either party. 7. CONFIDENTIALITY The parties shall keep the terms of this Agreement confidential, and shall not disclose them to any third party save where required by law or to their professional advisers. 8. NON-DISPARAGEMENT Neither party shall make any statement, oral or written, disparaging the other in relation to the matters settled by this Agreement. 9. BREACH If either party fails to comply with the terms of this Agreement, the other shall be entitled to enforce it, and the defaulting party shall bear the costs of enforcement. 10. ENTIRE AGREEMENT AND GOVERNING LAW 10.1 This Agreement records the entire understanding between the parties on its subject matter and supersedes all prior discussions. 10.2 No variation is effective unless in writing and signed by both parties. 10.3 This Agreement is governed by the laws of India. IN WITNESS WHEREOF the parties have executed this Agreement on the date first written above. FIRST PARTY SECOND PARTY [first_party] [second_party] WITNESSES 1. Name: ______________________ Signature: ______________ 2. Name: ______________________ Signature: ______________