A bill in equity for the rescission of a contract should set forth with certainty and particularity the facts constituting the ground upon which rescission is demanded.108 The bill should allege the special circumstances founding a jurisdiction in equity and justifying an exercise of the discretionary power of the court, such as facts which make it appear with reasonable certainty that irreparable injury will result to the plaintiff if the relief asked is not granted; that he has no adequate remedy at law, or the reasons why he cannot obtain adequate relief by a suit or defense at law, though it is sufficient in this respect to plead the facts from which the inadequacy of any remedy at law can be clearly perceived.109 The bill of complaint should show that the plaintiff is free from any fault, breach of contract or fraud so that he has a good standing in equity.110 Averments must also be made which will show the particular acts or conduct on the part of the defendant which give rise to the action.111

In general, a bill for rescission or cancellation must plead the essential facts with clearness and certainty so that the defendant may be able to answer without confusion.112