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  • Petitions & Pleadings / AGAINST-A-FRAUDULENT-PURCHASER-AND-HIS-TRANSFEREE-WITH-NOTICE

Petitions & Pleadings

AGAINST A FRAUDULENT PURCHASER AND HIS TRANSFEREE WITH NOTICE

 

IN THE COURT OF_____________ (add detail court)

Suit no.____/20____

_________________ (suppose A.B.)(add description and residence).

Plaintiff

against

__________________ (suppose C.D.)(add description and residence) . . .

Defendant

A. B., the above-named plaintiff, states as follows :-

  1. 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].
  2. The plaintiff was thereby induced to sell and deliver to D. [one hundred boxes of tea], the estimated value of which is __________ rupees.
  3. 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].
  4. D. afterwards transferred the said goods to the defendant E.F. without consideration [or who had notice of the falsity of the representation].
  5. [Facts showing when the cause of action arose and that the Court has jurisdiction.]
  6. 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.
  7. The plaintiff claims:-
    1. delivery of the said goods, or __________ rupees, in case delivery cannot be had;
    2. __________ rupees compensation for the detention thereof.

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