Against a Fraudulent purchaser and his transferee with notice

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 was solvent, and worth …………………. rupees over all his liabilities].

2.	The plaintiff was thereby induced to sell and deliver to ……………….. [one hundred boxes of tea] the estimated value of which is ………… rupees.

3.	The said representations were false, and were then known by ……………. to be  so [or at the time of making the said representations ……………was insolvent and knew himself to be so].

4.	…………………….. afterwards transferred the said goods to the defendant ……………. without consideration [or who had notice of the falsely of the representation].

1.	The plaintiff claims -

a.	delivery of the said goods, or…………….rupees, in case delivery cannot be had :

b.	…………….. rupees compensation for the detention thereof.