What is the test for making a declaration of fraud?

In Bowen v. Matheson, 14 Allen, 499, the court had before it on demurrer a declaration in an action where the defendants' business had been practically broken up, and it said: In order to be good, the declaration must allege against the defendants the commission of illegal acts. Its allegations must be analyzed to ascertain whether they contain a sufficient statement of such acts. This was followed by an interesting analysis, which resulted in disclosing that no illegal act was alleged, notwithstanding the liberal use of such extravagant words and phrases as maliciously conspiring together, and fellow conspirators as aforesaid in pursuance of their conspiracy as aforesaid, whereupon the demurrer was sustained, [170 N.Y. 326]and a precedent created which should be followed in this case.