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Supreme Court Rules 2000
251Pleading to avoid surprise
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### 251 Pleading to avoid surprise
> In any pleading subsequent to a statement of claim, a party is to plead specifically any fact or matter that –
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> > > (a) is alleged to make any claim or defence of the opposite party not maintainable; and
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> > > (b) if not pleaded specifically, may take the opposite party by surprise; and
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> > > (c) raises a question of fact not arising out of the preceding pleading.