Civil Pleadings Against A Fraudulent Purchaser And His Transferee With Notice

Against a Fraudulent Purchaser and

 His Transferee with Notice 



In the Court of ______________________________________



KK __________resI________ ____________________.. Plaintiff 



against 



GM_____________ resi_______ ____________________ Defendant 

KK________________________, the above-named plaintiff, states as follows:- 

1. On the ____________________ day of________________________ ______ , the defendant __________GM____________________, 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 GM_______________. [______ boxes of ____], the estimated value of which is _______ rupees. _____________

3. The said representations were false, and were then known by____________ GM___________ to be so [or at the time of making the said representations,____________ GM___________ was insolvent, and knew himself to be so]. 

4. GM_______________ afterwards transferred the said goods to the defendant__________ KM_______________. without consideration [or who had notice of the falsity of the representation]. 

[i. Facts showing when the cause of action arose and that the Court has jurisdiction. ] 

ii. The value of the subject-matter of the suit for the purpose of jurisdiction is ____________________rupees and for the purpose of court-fees is ___________________________________rupees. 

5. The plaintiff claims- 

(1) delivery of the said goods, or________________________________________.. rupees, in case delivery cannot be had; 

(2) _______________. rupees compensation for the detention thereof. 

Dated : 

Plaintiff 

Through, Advocate 



Verification:


I, ________________, do hereby verify that the contents from paras 1 to _____________________.._____ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein. 

Affirmed at  KALYAN this ______. 

Plaintiff