Procuring Property by fraud

Mr..............................., the above-named plaintiff, states as follows :

1.	On the ……………… day of ………… 20…….. the defendant, for the purpose of including the plaintiff to sell him certain goods, represented to the plaintiff that [he, the defendant, was solvent, and worth rupees over all his liabilities].

2.	The plaintiff was thereby induced to sell [and deliver] to defendant [dry goods] of the value of rupees.

3.	The said representations were false [or state the particular falsehoods] and where then known by the defendant to be so.

4.	The defendant has not paid for the goods. [Or, if the goods were not delivered]. The plaintiff, in preparing the shipping the goods and procuring their restoration, expended ……… rupees.