The claimant must set forth in his particulars of claim, or in a witness statement in support of the claim, the mortgage contract and all the material facts, showing, if he is not the original mortgagor, how he derives his right to redeem; and he should also state briefly any special circumstances, such as that the defendant mortgagee has been in possession1. The mortgagee may deny the claimant's right to redeem2, or any of the allegations in the
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