What are the elements of a proper pleading for breach of contract?

The elements of a proper pleading for breach of contract are: (a) The events or circumstances giving rise to the contract; (b) The material terms of the contract; (c) The acts or omissions that constitute a breach of the contract; and (d) The damages suffered, and by whom, as a result of the breach of the contract. (See Cerqueira v. Ontario, [2010] ONSC 3954)

A motion for particulars usually will not be granted unless the moving party deposes that the particulars are not within his or her knowledge and that they are needed to plead; however, a supporting affidavit is not required if the allegations are so general and bald that it is clear that particulars of them are necessary (Pennyfeather v. Timminco Ltd., [2011] ONSC 4257).

Identification of a litigant’s position on material facts may be required by way of response to a Demand for Particulars (See Pillai v. Pillai, (July 21, 2015) Newmarket CV-15-0122633 (S.C.J.)).