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Defence in Suits Relating to Nuisances

1.     The plaintiff's lights are not ancient [or deny his other alleged prescriptive rights].

2.     The plaintiffs lights will not be materially interfered with by the defendant's buildings.

3.     The defendant denies that he or his servants pollute the water [or do what is complained of ].

[If the defendant claims the right by prescription or otherwise to do what is complained of, he must say so, and must state the grounds of the claim, i.e., whether by prescription, grant or what.]

4.     The plaintiff has been guilty of laces of which the following are particulars:-- --

1870.Plaintiffs mill began to work.

1871.Plaintiff came into possession.

1883.First complaint.

5.     As to the plaintiff's claim for damages the defendant will rely on the above grounds of defence, and says that the acts complained of have not produced any damage to the plaintiff.[If other grounds are relied on, they must be stated, e.g., limitation as to past damage.]



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