AGAINST A FRAUDULENT PURCHASER AND HIS TRANSFEREE WITH NOTICE
IN THE COURT OF_____________ (add detail court)
_________________ (suppose A.B.)(add description and residence).
__________________ (suppose C.D.)(add description and residence) . . .
A. B., the above-named plaintiff, states as follows :-
- On the __________day of _______19 _______, the defendant D., for the purpose of including the plaintiff to sell him certain goods, represented to the plaintiff that [he was solvent, and worth _______ rupees over all his liabilities].
- The plaintiff was thereby induced to sell and deliver to D. [one hundred boxes of tea], the estimated value of which is __________ rupees.
- The said representations were false, and were then known by D. to be so [or at the time of making the said representations, C.D. was insolvent, and knew himself to be so].
- D. afterwards transferred the said goods to the defendant E.F. without consideration [or who had notice of the falsity of the representation].
- [Facts showing when the cause of action arose and that the Court has jurisdiction.]
- The value of the subject-matter of the suit for the purpose of jurisdiction is _________ rupees and for the purpose of court-fees is _______ rupees.
- The plaintiff claims:-
- delivery of the said goods, or __________ rupees, in case delivery cannot be had;
- __________ rupees compensation for the detention thereof.