Carrying on Noxious Manufacture


the above-named plaintiff states as follows:-

plaintiff is, and at all the times hereinafter mentioned was, possessed of
certain lands called…………, situate in…………………….

since the……….. day of………. 19……….., the defendant has
wrongfully caused to issue from certain smelting works carried on by the
defendant large qualities of offensive and unwholesome smoke and other vapors
and noxious matter, which spread themselves over and upon the said lands, and
corrupted the air, and settled on the surface of the lands.

the trees, hedges, herbage and crops of the plaintiff growing on the lands were
damaged and deteriorated in value, and the cattle and live-stock of the
plaintiff on the lands became unhealthy, and, many of them were poisoned and

plaintiff was unable to graze the lands with cattle and sheep as he otherwise
might have done, and was obliged to remove his cattle sheep and farming-stock
there from, and has been prevented from having so beneficial and healthy a use
and occupation of the lands as he otherwise would have had.

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

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