12. (1) Where the plaintiff seeks relief in respect of several distinct claims or causes of complaint founded upon separate and distinct facts, they shall be stated, as far as may be, separately and distinctly. (2) The same rule shall apply where the defendant relies on several distinct grounds of set-off or counter-claim founded upon separate and distinct facts. (3) Every statement of claim shall state specifically the relief which the plaintiff claims, either simply or in the alternative and may also ask for general relief and the same rule shall apply to any counter-claim made or relief claimed by the defendant in his defence. 13. It shall not be sufficient to deny generally the facts alleged by the statement of claim, but the defendant shall deal specifically with them either admitting or denying the truth of each allegation of fact seriatim, as the truth or falsehood each is within his knowledge, or (as the case may be) stating that he does not know whether any given allegation is true or otherwise. 14. (1) When a party denies an allegation of fact he shall not do so evasively, but shall answer the point of substance. (2) And when a matter of fact is alleged with diverse circumstances it shall not be sufficient to deny it as alleged along with those circumstances, but a full and substantial answer shall be given. 15. The defence shall admit such material allegations in the statement of claim as the defendant knows to be true, or desires to be taken as established without proof thereof. 16. Where any defendant seeks to rely upon any facts as supporting a right of set-off or counter-claim, he shall, in his statement of defence, state specifically that he does so by way of set-off or counter-claim as the case may be and the particulars of the set off or counter-claim shall be given. 17. The defence of a defendant shall not debar him at the hearing from disproving any allegation of the plaintiff not admitted by the defence or from giving evidence in support of a defence not expressly set up by the defence, except where the defence is such as, in the opinion of the court, ought to have been expressly set up by the defence or is inconsistent with the statements thereof or is in the opinion of the Court, lately to take the plaintiff by surprise or to raise new issues not fairly arising out of the pleadings, as they stand and such as the plaintiff ought not to be then called upon to meet. 18. The Court, if it considers that the statement of claim and the defence filed in any suit insufficiently disclose and fix the real issues between the parties, may order such further pleadings to be filed as it! Nay consider necessary for the purpose of bringing the parties to an issue. 19. Where the court is of opinion that any allegations of fact denied not admitted by any pleading, ought to have been admitted, the court shall make such order as may be just with respect to costs. 20. The court may at any time, on the application of either party, strike out any pleading or any part thereof, on the ground that it discloses no cause of action or no defence to the action as the case may be or on the ground that it is embarrassing or scandalous or vexatious or an abuse of the process of the court; and the Court may either give leave to amend that pleading or may proceed to give judgment for the plaintiff or the defendant, as the case maybe or may make such other order and upon such terms and conditions, as may seem just. 21. When a contract, promise, or agreement is alleged in any pleading, a bare denial of it by the opposite party shall be construed only as a denial, in fact of the express contract, promise, or agreement alleged, or the matters of fact from which it may be implied by law and not as a denial of the legality or sufficiency in law, of the contract, promise or agreement, whether with reference to any statute or otherwise. 22. Wherever the content of any document is material, it shall be sufficient in any pleading to state the effect thereof as briefly as possible without setting out the whole or any part thereof, unless the precise words of the document or any part thereof are material. 23. (1) Wherever it is material to allege malice, fraudulent intention knowledge or other condition of the mind of any person, it shall be sufficient to allege it as a fact without setting out the circumstances from which it is to be inferred.