Perhaps the most important of all the parts of a bill in equity is the premises or stating part. Here the complainant must set out the statement of the facts upon which his cause of action depends.

"The statement must allege the existence of every fact necessary to entitle the complainant to equitable relief. It must be complete in itself, and cannot be aided or enlarged by reference to other parts of the bill."

In Smith vs. Wood, the court said: "No rule of equity pleading is better settled than that which declares that every material fact which is necessary for a complainant to prove to establish his right to the relief he asks must be alleged in the premises of his bill with reasonable fullness and particularity. A suitor who seeks relief on the ground of fraud must do something more than make a general charge of fraud. He must state the facts which constitute the fraud, so that the person against whom relief is sought may be afforded a full opportunity, not only to deny or explain the facts charged, but to disprove them. He has a right to know in advance just what he will be required to meet." 1

Much less formality is required in stating a case in a bill in equity than in a common law declaration.

The bill should not contain arguments mingled with facts in the premises.2