Procuring Properly by Fraud

(Title)

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

On the .........day of........... 19....., 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].

The plaintiff was thereby induced to sell [and deliver] to the defendant, [dry goods] of the value of ......... rupees.

The said representation were false [or state the particular falsehoods] and were then known by the defendant to be so.

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

[As in paras.4 and 5 of Form No.1, and Relief claimed.]