No. 33 Against a Fraudulent Purchaser and His Transferee with Notice.
A. B., the above-named plaintiff, states as follows:-
1. On the …… day of…… 19… , the defendant C.D., 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 C.D. [one hundred boxes of tea], the estimated value of which is …… rupees.
3. 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].
4. 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]
7. The plaintiff claims-
(1) delivery of the said goods, or…… rupees, in case delivery cannot be had;