Explain the following: Important points which should be kept in mind while drafting pleadings.

The following points should be kept in mind while drafting a pleading: a) The names of persons and places should be accurately given and correctly spelt; spellings adopted at one place should be followed throughout the pleading. b) Facts should be stated in active and not in the passive voice omitting the nominative. c) All circumstances and paraphrases should be avoided. d) 'Terse', 'Short', 'Blunt' sentences should be used as far as possible. All 'its' and 'buts' should be avoided. e) Pronouns like "he" "she" or "that" should be avoided if possible. Anyway, such pronouns when used should clearly denote the person or the thing to which such pronouns refer. f) The plaintiff and the defendant should be referred not only by their names. It is better to use the word "plaintiff" or "defendant". g) Things should be mentioned by their correct names and the description of such things should be adhered to throughout. h) Where an action is found on some statute, the exact language of the statute should be used. i) In any pleading, the use of "if", "but" and "that" should be, as far as possible, avoided. Such words tend to take away the "certainty" and can cause ambiguity j) Necessary particulars of all facts should be given in the pleading. If such particulars are quite lengthy, then they can be given in the attached schedule, and a clear reference made in the pleading. Repetitions should be avoided in pleadings. k) Every pleading shall, when necessary, be divided into paragraphs, numbered consecutively, each allegation being, so far as is convenient, contained in a separate paragraph. The division of the pleading into paragraphs should be so done as to endure that each paragraph deals with one fact. At the same time, the entire pleading should appear a running and well-knit matter, must not look like isolated fact placed together. Inter-relations ships of paragraphs must seem to exist. All the relevant facts must be stated in strict chronological order. l) Dates, sums and numbers shall be expressed in a pleading in figures as well as in words.