Defence in suits for relating to nuisances
1. The plaintiff’s lights are not ancient [or deny his other alleged prescriptive rights]
2. The plaintiff’s lights will not be materially interfered with by the defendant’s buildings.
3. The defendant denies that he or his servants pollute the water or do what is complained of.
If the defendant claims the right by prescription or otherwise to do what is complained of, he must say so, and must state the grounds of the claim, i.e. whether by prescription, grant or what.
4. The plaintiff has bee guilty of laches of which the following are particulars :
1870, plaintiff’s mill began to work
1871, plaintiff came into possession.
1883, First complaint.