Movables Wrongfully Detained

(Title)

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

On the ........day of .........19.........., plaintiff owned [ or state facts showing a right to the possessions] the goods mentioned in the schedule hereto annexed [or describe the goods ], the estimated value of which is............ rupees.

From that day until the commencement of this suit the defendant has detained the same from the plaintiff.

Before the commencement of the suit, to wit, on ........the day of............ 19, the plaintiff demanded the same from the defendant, but he refused to deliver them.