No. 39
RESTORATION OF MOVABLE PROPERTY THREATENED WITH
DESTRUCTION, AND FOR AN INJUNCTION
(Title)
A.B., the above named plaintiff, states as follows:–
- Plaintiff is, and at all times hereinafter mentioned was, the owner of [a portrait of his grandfather which was executed by an eminent painter], and of which no duplicate exists [or state any facts showing that the property is of a kind that cannot be replaced by money].
- On the ……. day of …… 20….., he deposited the same for safe-keeping with the defendant.
- On the …… day of ….. 19…., he demanded the same from the defendant and offered to pay all reasonable charges for the storage of the same.
- The defendant refuses to deliver the same to the plaintiff and threatens to conceal, dispose of, cut or inure the same if required to deliver it up.
- No pecuniary compensation would be an adequate compensation to the plaintiff for the loss of the [painting].
[As in paras 4 and 5 of Form No. 1.] - The plaintiff claims–
(1) that the defendant be restrained by injunction from disposing of, injuring or concealing the said [painting];
(2) that he be compelled to deliver the same to the plaintiff.