The bill must be in respect to the same title, in the same person as the original bill; Story, Eq. Pl. 339; and no relief can be had under it upon a cause of action, which did not exist when the original bill was filed ; Heffron v. Knickerbocker, 57 Ill. App. 339; Neubert v. Massman, 37 Fla. 91, 19 So. 625. If the original bill shows no title to relief, a supplemental bill cannot be filed based on facts afterwards occurring; but if the orig inal bill is well founded, a supplemental bill may be filed showing a further title to re lief ; New York S. & T. Co. v. R. Co., 74 Fed. 67 ; Putney v. Whitmire, 66 Fed. After a decree has been directed for com plainant, a stranger will not be permitted to file a supplemental bill based on his pur chase of the cause of action, until a decree is actually entered in the original cause ; Hazleton Tripod-Boiler Co. v. R. Co., 72 Fed. 325. A bill by a surviving partner, to settle the partnership affairs, • is separate, and dis tinct from a bill-to subject real estate of the deceased partner to firm debts, and the stat ute of limitations cannot be avoided by styl ing the second suit a supplemental bill; White v. Joyce, 158 U. S. 128, 15 Sup. Ct. 788, 39
L. Ed. 921. When a patent was assigned to a stranger pending a suit for infringement, the assignee cannot obtain the benefit of the suit brought by the assignor, by a supple mental bill, but he may do it by an original bill in the nature of a supplemental bill ; Ross v. Ft. Wayne, 58 Fed. 404. In a suit to remove a cloud from a title, where there is a decree establishing such title in the com plainant, which carries a right to possession, a supplemental bill may be filed to enforce that right ; Root v. Woolworth, 150 U. S. 401, 14 Sup. Ct. 136, 37 L. Ed. 1123.
It must state the original bill, and the proceedings thereon ; and, when it is occa sioned by an event which has occurred subse quently to the original bill, it must state that event and the consequent alteration with re gard to the parties. In general, the supple mental bill must pray that all defendants appear and answer the charges it contains; Story, Eq. Pl. § 343. But the supreme court equity rules (Feb. 1, 1913) provide that the statements in the original suit need not be set forth unless the circumstances of the case may require it.