ART. 16.] CHANCERY—PLEADING, PRACTICE, PROCESS. 179

Rule 23.

142. The defendant shall make answer to all the material
allegations of the bill, except as hereinafter provided; and the
answer shall be divided into paragraphs, numbered consecutively,
each paragraph containing, as near as may be, a separate and dis-
tinct averment. The rule, that if the defendant submits to
answer, he shall answer fully to all the matters of the bill, shall
not apply in cases where he might, by plea or demurrer, protect
himself from such answer and discovery. And the defendant
shall be entitled in all cases, by answer, to insist upon all matters
of defence in law or equity, to the merits of the bill, of which he
may be entitled to avail himself by a demurrer, or plea in bar;
and in such answer he shall not be compellable to answer any
other matters than he would be compellable to answer and dis-
cover, upon filing a demurrer or plea in bar, and an answer in
support of such plea, touching the matters set forth in the bill to
avoid or repel the bar or defence. Thus, for example, a bona

fide purchaser, for a valuable consideration, without notice, may
set up the defence by way of answer, instead of plea, and shall be
entitled to the same protection, and shall not be compellable to
make any further answer or discovery of his title than he would
be required to make in an answer in support of such plea.

Rule 24.

143. Special interrogatories to the defendant shall not be
incorporated in the bill or petition, but shall be appended thereto;
and they shall be divided as conveniently as may be, and num-
bered consecutively. And if there be more than one defendant,
and the interrogatories are not intended to be answered by all, it
shall be designated which defendant is required to answer the

several interrogatories. And in like manner and form, any de-
fendant shall be entitled to file interrogatories to any of the plain-
tiffs, after he shall have put in his answer to the bill; and such
interrogatories, either to plaintiff or defendant, and the answers

thereto, shall be deemed part of the pleadings in the cause.
Notice by service of copy, or otherwise, shall be given to the
party required to answer, who shall answer within thirty days
from the time of service, unless the time, for cause shown, be
extended by special order; and answers to such interrogatories
may be compelled by attachment.