A.B., the above named plaintiff, states as follows:–
1. Plaintiff is, and at all times hereinafter mentioned was, the owner of [a portrait of his grandfather 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 …… 20….., 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 inure
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 4 and 5 of Form No. 1.]
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.