A Statement of Claim:
(a) shall state the basis on which it is claimed that the matter is within the original jurisdiction of the Court;
(b) shall contain in a summary form a statement of all the material facts on which the plaintiff relies, but not the evidence by which those facts are to be proved;
(c) where any claim arises by or under any Act, shall identify the specific provisions relied on; and
(d) shall contain the necessary particulars of any fact or matter pleaded, including:
(i) all particulars necessary to enable the opposite party to plead or to define the questions for trial or to avoid surprise at trial; and
(ii) particulars of any misrepresentation, fraud, breach of trust, wilful default, or like matter; and
(e) shall state specifically the relief or remedy claimed.