In District Court pleadings, 'material' in the requirement to plead material facts means material to the cause or causes of action relied upon. The requirement to state material facts does not exclude the allegation of legal categories such as duty of care, fiduciary duty, trust and contract. Where there is a danger of surprise arising from lack of precision and clarity, a plaintiff may be required to explicitly relate the facts pleaded to specified causes of action. District Court Rules Pt.5 r.6A(a) makes clear that the statement of material facts must be so presented as to amount also to a statement of causes of action.
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