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.]

1.      

2.      

3.      

4.      

5.      

6.      

7.      

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.

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