SUIT FOR DELIVERY OF GOODS FOR COMPENSATION AGAINST A FRAUDULENT PURCHASER AND HIS TRANSFEREE WITH NOTICE
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
VERIFICATION
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