It is settled law in this state that it is generally sufficient to describe a statutory crime in the words of the statute. State v. Goodwin, 101 N.H. 252, 253; State v. Yell, 104 N.H. 87, 88; State v. Panichas, 107 N.H. 359, 362. There are exceptions to this rule which occur more often in felony cases than in misdemeanor cases.
Generally an indictment is sufficient if it uses the words of the proper section of the applicable statute. State v. Yell, 104 N.H. 87. The test of its sufficiency remains always the same: whether it gives the defendant enough information so that he can prepare for trial. State v. Rousten, 84 N.H. 140, 143. Our statute (RSA 583, section 12) does not appear to have ever been construed here and authorities elsewhere under similar provisions are not uniform. Annot. 103 A.L.R. 1309.
In indictments or complaints created by statute it is in general sufficient to describe the offense in the words of the statute. State v. Yell, 104 N.H. 87. But a complaint so drawn does not always meet the constitutional requirements that a fair and full description of the offense must be alleged. State v. Gilbert, 89 N.H. 134.
147 S.W.2d at 465. See also, State v. Yell, 104 N.H. 87, 178 A.2d 289 (1962). In State v. Harris, 313 S.W.2d 664 (Mo. 1958), the Supreme Court of Missouri held that the words "feloniously and fraudulently" were not of similar import to the statutory term "intent to defraud."