A Statement of Claim:

(a)

shall state the basis on which it is claimed that the matter is within the original jurisdiction of the Court;

(b)

shall contain in a summary form a statement of all the material facts on which the plaintiff relies, but not the evidence by which those facts are to be proved;

(c)

where any claim arises by or under any Act, shall identify the specific provisions relied on; and

(d) shall contain the necessary particulars of any fact or matter pleaded, including:

(i)

all particulars necessary to enable the opposite party to plead or to define the questions for trial or to avoid surprise at trial; and

(ii)

particulars of any misrepresentation, fraud, breach of trust, wilful default, or like matter; and

(e)

shall state specifically the relief or remedy claimed.