ERVIN, Justice.
It is a basic rule of pleading that a complaint must allege every material fact necessary to sustain the right of the plaintiff to the relief which he seeks. Potter v. National Supply Co., 230 N.C. 1, 51 S.E.2d 908. In consequence, we confront this primary question at the threshold of this appeal: Where a stockholder applies for a writ of mandamus to compel the directors of a corporation to declare and pay a dividend, must he allege in his complaint...
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