Restoration of Movable Property Threatened with Destruction, and for an Injunction

(Title)

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

1.      Plaintiff is, and at all times hereinafter mentioned was, the owner of [ aa portrait of his grand-father which was executed by an eminent painter], and of which no duplicate exists [ or state any facts showing that the property is of a kind that cannot be replaced by money].

2.      On the .......day of .........19...., he deposited the same for safe-keeping with the defendant.

3.      On the ..........day of ..........19............, he demanded the same from the defendant and offered to pay all reasonable charges for the storage of the same.

4.      The defendant refuses to deliver the same to the plaintiff and threatens to conceal, dispose of, cut or injure the same if required to deliver it up.

5.      No pecuniary compensation would be an adequate compensation to the plaintiff for the loss of the [ painting ].

[ As in paras.6 and 7 of Form No.1.]

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8.      The plaintiff claims-

1.      that the defendant be restrained by injunction from disposing of, injuring or concealing the said [ painting ];

2.      that he be compelled to deliver the same to the plaintiff.