Against A Fraudulent Purchaser And His Transferee With Notice Drafting Plaints 875 - Legal Draft

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.