SUIT FOR DELIVERY OF GOODS
FOR COMPENSATION AGAINST A FRAUDULENT
PURCHASER AND HIS TRANSFEREE WITH NOTICE [CD1]
IN THE COURT OF THE....................
Suit No..................... of 19....................
C.
D.................................................................... Plaintiff
versus
C.
F................................................................. Defendant
The abovenamed
plaintiff most respectfully submits as under: —
1.
On the.................... day
of..................... the defendant C. F., for the purpose of inducing 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 C. F. ( ........................................
) the estimated value of which is.................... rupees.
3.
The said representations were
false, and were then known by C. F. to be so (or at the time of making the said
representations C. F. insolvent and knew himself to be so).
4.
C. F. afterwards transferred
the said goods to the defendant E. F. without consideration (or who had notice
of the falsity of the representation).
5.
Cause of action arose within
the jurisdiction of this Court on.................... 19....................
when the defendant C. F. got the goods from the plaintiff by misrepresentation
and on.................... against E. F. when C. F. transferred the goods to E.
F.
6.
The suit is valued at
Rs..................... the approximate price of the goods delivered under
fraud to C. F. and later on to E. F. transferred by C. F. and court fee is paid
thereon for recovery of the price of the goods and for issuing mandatory
injunction to deliver the goods back to the plaintiff. RELIEFS CLAIMED:
The plaintiff
claims—
(1) delivery of the said goods, or.................... rupees, in case
delivery cannot be had.
(2) .................... rupees compensation for the detention there of.
Plaintiff
Through Advocate
I, abovenamed
plaintiff, do hereby verify that the contents of paras ....................
to.................... of the plaint are true to my personal knowledge and
those of paras.................... and.................... thereof are based on
legal advice which I believe to be true.
Verified on
this................. day of.................... 19....................
at....................
Plaintiff
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