Carrying On Noxious Manufacture - Legal Draft

A.B.,

the above-named plaintiff states as follows:-The

plaintiff is, and at all the times hereinafter mentioned was, possessed of

certain lands called............, situate in.........................Ever

since the........... day of.......... 19..........., the defendant has

wrongfully caused to issue from certain smelting works carried on by the

defendant large qualities of offensive and unwholesome smoke and other vapors

and noxious matter, which spread themselves over and upon the said lands, and

corrupted the air, and settled on the surface of the lands.Thereby

the trees, hedges, herbage and crops of the plaintiff growing on the lands were

damaged and deteriorated in value, and the cattle and live-stock of the

plaintiff on the lands became unhealthy, and, many of them were poisoned and

died.The

plaintiff was unable to graze the lands with cattle and sheep as he otherwise

might have done, and was obliged to remove his cattle sheep and farming-stock

there from, and has been prevented from having so beneficial and healthy a use

and occupation of the lands as he otherwise would have had.[As

in paras.4 and 5 of Form No.1, and Relief claimed.]