If a defendant fails to appear, or after appearance fails to answer the bill, the bill may be taken pro con-fesso. In some jurisdictions there must be a rule upon the defendant to answer before a bill can thus be taken pro confesso.1 The allegations of a bill taken pro con-fesso are to be strictly construed,2 and although "It is held that the bill, when taken as confessed by the default of the defendant, is taken to be true in all matters alleged with sufficient certainty; but in respect to matters not alleged with due certainty, or matters which, from their nature, and the course of the court, require an examination of details, the obligation to furnish proof rests on the complainant.3 It is purely a matter of discretion with the court whether it will require the complainant to make proof against defendants who fail to answer.4 A party against whom a bill has been taken for confessed cannot complain and assign for error that the proof does not sustain the allegations of the bill." 5 6