 For instance, a lawsuit against a defendant had spoiled wine with salt water required an allegation that he had done so with bows and arrows.The ancient courts at common law developed trespass upon the case as an alternative pleading to causes of action which arose neither from force nor weapons.In modern times, the specific formalities of the distinction between the two have dropped in favor of notice pleading or code pleading and actions for negligence, battery, trespass to chattels, and conversion.