Against a Fraudulent Purchaser and his Transferee with Notice

(Title)

A.B., the above-named plaintiff, states as follows:-

On the …….day of ………19………., the defendant C.D., for the purpose of inducing the plaintiff to sell him certain goods, represented to the plaintiff that [he was solvent, and worth rupees over all his liabilities ].

The plaintiff was thereby induced to sell and deliver to C.D.[ One hundred boxes of tea ], the estimated value of which is ………….rupees.

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

C.D. afterwards transferred the said goods to the defendant E.F. without consideration [ or who had notice of the falsity of the representation ].[ As in paras.4 and 5 of Form No.1.]

The plaintiff claims-

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

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