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3. That on the day of

18

[a judgment

was recovered against the plaintiff and defendant by one E. F., in the
High Court of Judicature at
, upon a debt due from the said
18 1 the

firm to the said E. F., and on the day of
plaintiff paid
rupees [in satisfaction of the same.]

4. That the defendant has not paid the same to the plaintiff.

[Demand of Judgment.]

No. 70.

BY SHIP-OWNER AGAINST FREIGHT OR FOR NOT LOADING.

(Title.)

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

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plaintiff and defendant entered into an agreement, a copy of which is

hereto annexed.

[Or, 1. That on

at

the plaintiff and defendant agreed by charter party that the defendant should deliver to the plaintiff's ship

should carry to

for loading, required, at

18

at

on the day of five hundred tons of merchandise, which she and there deliver, on payment of

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freight; and that the defendant should have days days for discharge, and days for demurrage, if

rupees per day.]

2. That at the time fixed by the said agreement the plaintiff was ready and willing and offered to receive [the said merchandise, or, the merchandise mentioned in the said agreement] from the defendant.

3. That the period allowed for loading and demurrage has elapsed, but the defendant has not delivered the said merchandise to the said vessel.

Wherefore, the plaintiff demands judgment for for demurrage and

rupees additional for compensation. [Demand of Judgment.]

C-PLAINTS FOR COMPENSATION UPON WRONGS.

No. 71.

FOR TRESPASS ON LAND.

(Title.)

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

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defendant entered upon certain land of the plaintiff, known as

[and depastured the same with cattle, trod down the

grass, cut the timber, and otherwise injured the same.]

[Demand of Judgment.]

No. 72.

FOR TRESPASS IN ENTERING A DWELLING-HOUSE.

(Title.)

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

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1. That the defendant entered a dwelling-house of the plaintiff called and made a noise and disturbance therein for a long time, and broke open the doors of the said dwelling-house, and removed, took and carried away the fixtures and goods of the plaintiff therein, and disposed of the same to the defendant's own use, and expelled the plaintiff and his family from the possession of the said dwelling-house, and kept them so expelled for a long time.

2. That the plaintiff was thereby prevented from carrying on his business, and incurred expense in procuring another dwelling-house for himself and family.

[Demand of Judgment.]

No. 73.

FOR TRESPASS ON MOVEABLES.

(Title.)

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

18

at

the

1. That on the day of defendant broke open ten barrels of rum belonging to the plaintiff, and emptied their contents into the street [or seized and took the plaintiff's goods, that is to say, iron, rice and household furniture, or as the case may be], and carried away the same and disposed of them to his own

use:

[or, seized and took the plaintiff's cows and bullocks, and impounded them and kept them impounded for a long time.]

2. That the plaintiff was thereby deprived of the use of the cows and bullocks during that time, and incurred expense in feeding them and in getting them restored to him; and was also prevented from selling them at fair, as he otherwise would have done, and the said cows and bullocks are diminished in value to the plaintiff [otherwise state the injury according to the facts.]

[Demand of Judgment.]

No. 74.

FOR THE CONVERSION OF MOVEABLE PROPERTY.

(Title.)

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

day of

1. That on the 18 plaintiff was in possession of certain goods described in the schedule hereto annexed [or of one thousand barrels of flour.]

2. That on that day, at

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same to his own use, and wrongfully deprived the plaintiff of the use and possession of the same.

[Demand of Judgment.]

The Schedule.

No. 75.

AGAINST A WAREHOUSEMAN FOR REFUSAL TO DELIVER Goods.

(Title.)

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

day of

18

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at

1. That on the the defendant, in consideration of the payment to him of rupees [or,

rupees per barrel, per month, &c.], agreed to keep in his godown [one hundred barrels of flour], and to deliver the same to the plaintiff on payment of the said sum.

2. That thereupon the plaintiff deposited with the defendant the said [hundred barrels of flour.]

3. That on the

day of

18 the plaintiff requested

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the defendant to deliver the said goods, and tendered him rupees [or, the full amount of storage due thereon], but the defendant refused to deliver the same.

4. That the plaintiff was thereby prevented from selling the said goods to E. F., and the same are lost to the plaintiff.

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

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1. That on the defendant, for the purpose of inducing the plaintiff to sell him certain

goods, represented to the plaintiff that [he, the defendant, was solvent, and worth rupees over all his liabilities].

2. That the plaintiff was thereby induced to sell [and deliver] to the defendant [dry goods] of the value of

rupees.

3. That the said representations were false [or, state the particular falsehoods], and were then known by the defendant to be so.

4. That the defendant has not paid for the said goods. [Or, if the goods were not delivered]. That the plaintiff, in preparing and shipping the said goods and procuring their restoration, expended

[Demand of Judgment.]

rupees.

No. 77.

FOR FRAUDULENTLY PROCURing Credit to BE GIVEN TO ANOTHER

PERSON.

(Title.)

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

day of

18

at

1. That on the , the defendant represented to the plaintiff, that one E. F. was solvent and in good credit, and worth rupees over all his liabilities [or, that E. F. then held a responsible situation and was in good circumstances, and might safely be trusted with goods on credit].

2. That the plaintiff was thereby induced to sell to the said E. F. [rice] of the value of rupees [on month's credit].

3. That the said representations were false and were then known by the defendant to be so, and were made by him with intent to deceive and defraud the plaintiff [or, to deceive and injure the plaintiff].

4. That the said E. F. [did not pay for the said goods at the expiration of the credit aforesaid, or,] has not paid for the said rice, and the plaintiff has wholly lost the same by reason of the premises.

[Demand of Judgment.]

No. 78.

FOR POLLUTING THE WATER UNDER THE PLAINTIFF'S LAND.

(Title.)

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

and situate in

and of

1. That he is, and at all the times hereinafter mentioned was, possessed of certain land called a well therein, and of water in the said well, and was entitled to the

use and benefit of the said well and of the said water therein, and to have certain springs and streams of water which flowed and ran into the said well to supply the same to flow or run without being fouled or polluted.

18

2. That on the day of the defendant wrongfully fouled and polluted the said well and the said water therein and the said springs and streams of water which flowed into the said well.

3. That by reason of the premises the said water in the said well became impure and unfit for domestic and other necessary purposes, and the plaintiff and his family are deprived of the use and benefit of the said well and water.

[Demand of Judgment.]

No. 79.

FOR CARRYING ON A NOXIOUS MANUFACTURE.

(Title.)

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

1. That the plaintiff is, and at all the times hereinafter mentioned was, possessed of certain lands called

2. That ever since the 18

day of

situate in

the defendant has wrongfully caused to issue from certain smelting works carried on by the defendant large quantities of offensive and unwholesome smoke and other vapours and noxious matter, which spread themselves over and upon the said lands, and corrupted the air, and settled on the surface of the said lands.

3. That thereby the trees, hedges, herbage and crops of the plaintiff growing on the said lands were damaged and deteriorated in value, and the cattle and live stock of the plaintiff on the said lands became unhealthy, and divers of them were poisoned and died.

4. That by reason of the premises the plaintiff was unable to depasture the said lands with cattle and sheep, as he otherwise might have done, and was obliged to remove his cattle, sheep and farming stock therefrom, and has been prevented from having so beneficial and healthy a use and occupation of the said lands as he otherwise would have had.

[Demand of Judgment.]

No. 80.

FOR OBSTRUCTING A WAY.

(Title.)

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

1. That plaintiff is, and at the time hereafter mentioned was,

possessed of [a house in the town of

1.

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