Free Breach of Contract Legal Advice

I entered into a collaboration agreement with a builder in 2016 for construction of 4 flats on my property out of which 2 were mine and 2 his. The agreement was renewed in 2017 and when work was still not completed, i filed a complaint with delhi mediation center in december 2018 deadline of which he agreed was april 2019. till now work is not yet completed and I want to send him a legal notice giving him a final deadline failing which he has to forgo his 2 flats which I will sell and use the money to complete my flats and claim as compensation. i am unemployed and in a very bad financial situation because of this delay.

Offence under section 491, IPC , since the insurance company, despite being contracted to cover hospital bills, has refused to pay – meaning breach of the service contract – by invoking an exclusion clause under a head which is dissimilar to the head describing the nature of the medical procedure performed on the person insured.

Dear Sir / Ma’am, Greetings from Company Vakil !! In

We are site owners of 357 Sq.yards given to development to builder. we entered GPA cum Development agreement 1-03-2017. In that agreement mentioned 21 months to complete handover to our share on that such date. But still he has not complete the construction what is the remedy

Can the insurer company be accused of the breach and be brought to face the criminal complaint under S. 491, IPC?
Jaykumar