Polluting the water  under the plaintiff’s land

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

1.	The plaintiff is, and at all the times hereinafter mentioned was, possessed of certain land called …………….. and situate in ………….and of a well therein, and of water in the well, and was entitled to the use and benefit of the well and of the water therein, and to have certain spring and streams of water which flowed and ran into the well to supply the same to flow or run without being fouled or polluted.

2.	On the ……………. day of…….. 20……. The defendant wrongfully fouled and polluted the well and the water therein and the springs and streams of water which flowed into the well.

3.	In consequence the water in the well became impure and  unfit for domestic and other necessary purposes, and the plaintiff and his family are deprived of the use and benefit of the well and water.