The general rule of pleading is that a party must set up all the material facts on which he intends to rely at the trial; j otherwise he is not entitled to give any evidence of them at the trial. No averment must be omitted which is essential to success. Vide the remarks of Cotton, L.J., in Philipps v. Philipps (1879) 4 Q.B.D. 127, at 139, 48 L.J.Q.B. 135.
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