“material” means “fundamental”, “vital”, “basic”, “cardinal”, “central”, “crucial”, “decisive", “essential”, “pivotal”, “indispensable”, “elementary”, or “primary” [Burton’s Legal Thesaurus (3rd Edition), p.349]. The phrase “material facts”, therefore, may be said to be those facts upon which a party relies for its claim or defence. In other words, “material facts” are facts upon which the plaintiff’s cause of action or the defendant’s defence depends. What particulars could be said to be material facts would depend upon the facts of each case and no rule of universal application can be laid down. It is, however, absolutely essential that all basic and primary facts which must be proved at the trial by the party to establish the existence of a cause of action or defence are material facts and must be stated in the pleading by the party. 18 (2005) 13 SCC 511 Civil Appeal No. ____ of 2024 Page 22 of 3051. A distinction between “material facts” and “particulars”, however, must not be