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CPC PRAYING FOR GRANT OF EXPARTE AD-INTERIM INJUCTIVE ORDER. Suit Format of Consequential Relief Permanent Injunction In the court of Hon’ble Civil Judge, Senior Division, ____. _________ Versus __________ Suit for Declaration with a Consequential Relief Permanent Injunction APPLICATION UNDER ORDER RULE  C.P.C. READ WITH SECTION ___  CPC PRAYING FOR GRANT OF EXPARTE AD-INTERIM INJUCTIVE ORDER. Respectfully showeth: 1- That the applicant/plaintiff has this day instituted the above captioned case before this Hon’ble court, the contents of which may kindly be read as part and parcel of this application for the sake of brevity and avoidance of repetition. 2- That succinctly stated that the applicant has very good prim-facie case to succeed, balance of convenience heavily tilts in his favour, and plaintiff will suffer irreparable loss and incalculable injury if the stay sought for is not granted. 3- That on the basis of the false, illegal, and unlawful the judgement and decree dated ____ defendant/respondent wants to dispossess the applicant/plaintiff from the suit land which is mentioned in Para No.1 of the plaint illegally, forcibly and wants to take the possession of the suit land from the applicant/plaintiff illegally, forcibly and unlawfully for which the defendant has no right title and interest to do so. In case respondents/defendant will succeed in her illegal motives in that event the applicant/plaintiff shall only suffer an irreparable loss and incalculable injuries PRAYER: It is, therefore, prayed that an ex-parte ad interim injunction order restraining the defendant/respondent from dispossessing the applicant/plaintiff from the suit land and from interfering into the peaceful possession of the applicant/plaintiff over the suit and also from taking the forcible possession of the suit land from the plaintiff which is mentioned in Para No.1 of the plain, forcibly illegally and in any coercive manner whatsoever may kindly be passed in favour of the applicant/plaintiff and against the respondent/defendant till the final decision of the suit. Dated Applicant/Plaintiff Through counsel _____ Advocate, ____. Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

Written statement of the defendant-tenant in an eviction suit IN THE COURT OF THE SMALL CAUSES JUDGE,                                          Civil Suit No./----------------- 200_ Shri __L N D        _       Plaintiff                                                 Versus Shri   T N T _        Defendant A WRITTEN STATEMENT OF THE DEFENDANT The defendant above-named submits this statement, praying to state as follows: That the contents of para 1 of the plaint are true and correct, and hence, admitted by this defendant. That the contents of para 2 of the plaint are likewise true and correct, and hence, call for no comments. That the contents of para 3 of the plaint are partially true and partially false, and the defendant submits that the said amount of rent is Rs, 150/- is inclusive of all other charges and taxes. That the contents of para 4 of the plaint are baseless, false and frivolous, and while denying the same, this defendant submits that the defendant time and again offered the amounts of rent to the plaintiff, but it was the plaintiff alone who refused to accept the same. That with respect to the remaining contents of the said para 4 of the plaint, this defendant also submits for the kind consideration of this Hon'ble Court that the defendant has so far sent to the plaintiff as many as six money orders which were refused by the plaintiff, and hence, the defendant committed no default on that count. That the contents of para 5 of the plaint are denied by this defendant, and this defendant submits that the plaintiff be put to the strict proof of the same. That the contents of para 6 of the plaint amount to a sheer piece of fabrication on the part of the plaintiff, and this defendant brings to the kind notice of this Hon'ble Court that it is the plaintiff alone, and not this defendant, who has constructed a big bungalow at Kothrud, and since he himself shifted his own residence there for the last more than three years, he has never turned up even to collect the rent of the suit property or to pay a visit to the premises in his own possession there,   and,  thus,  the plaintiff does not require any premises, much the less the suit premises. That the contents of para 7 of the plaint are misleading, and the particulars of money claim are wrongly calculated.  That the contents of para 8 of the plaint to the effect that the suit premises were taken for the purpose of running dispensary but subsequently, the defendant changed the user thereof by converting the same for residence of his family are wrong and misleading, and this defendant submits that the said premises were taken only for the purpose of residence and no other use. That the defendant furthermore submits that there was no cause of action for the plaintiff to file the present suit against the defendant. That the defendant also submits for the kind and sympathetic consideration of this Hon'ble Court the very fact that the plaintiff has malicious plans and designs to make money by disposing of the suit property, and hence, he has been trying to make out a false case. That the defendant, therefore, prays that - (A)The suit of the plaintiff be kindly dismissed with costs; (B)The costs of this defendant, be awarded from the plaintiff; and (C)Any other orders in the interest of justice be kindly passed. Mumbai,                                                                                           Sd/- TNTDated: ..                                                                                DEFENDANT Sd/- xXx      ADVOCATE FOR DEFENDANT VERIFICATION I, Shri TNT, the present opponent, do hereby state on solemn affirmation that the contents of this statement in paras 1 to 11 are true and correct to the best of my knowledge and belief, so I have signed hereunder. Sd/- TNT DEFENDANT Download Word Document In English. (Rs.30/-)

On a Foreign Judgment In the Court of ...................................... KK…………………………………………………………… resi………. ...................... Plaintiff  against GM…………………………………..…………………. Resi………………. .................... Defendant KK…………………………………………………………………..., the above-named plaintiff, states as follows:- 1. On the ……………….... day of……………..... /… ………... , at…………. , in the State of the ...... Court of that State in a suit therein pending between the plaintiff and the defendant, duly adjudged that the defendant should pay to the plaintiff ....................... .rupees, with interest from the said date. 2. The defendant has not paid the money. [i. Facts showing when the cause of action arose and that the Court has jurisdiction. ] ii. The value of the subject-matter of the suit for the purpose of jurisdiction is …................rupees and for the purpose of court-fees is .....................................rupees., and Relief claimed.] Dated : Plaintiff Through, Advocate  Verification: I , _____________________________, do hereby verify that the contents from paras 1 to ______ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein.  Affirmed at………………..this ___________.  Plaintiff  Download Word Document In English. (Rs.15/-) Download PDF Document In Marathi. (Rs.15/-)

Bail Petition before a Magistrate in a Pending Case under section 437, Cr PC In the Court of Bombay ............................The State              versus ...........................Accused AB son of TZ, Village: Thana In the matter of petition for bail of accused AB The humble petition of AB the accused in the above case MOST RESPECTFULLY SHEWETH: 1. That your petitioner was arrested by the police on 5th April 2010 on suspicion. That he was not named in the FIR nor was he identified by any inmate of the house, where the burglary is said to have taken place during the identification parade by Mr. JM, a Judicial Magistrate. 2. That nothing incriminating was found in the house on search by the police. 3. That your petitioner is a family man and is not likely to abscond. 4. Your petitioner be granted bail inasmuch as there is no valid ground for continued detention and the trial is not likely to be completed within the near future. Prayer Your petitioner prays that after issuing the notice to the State and hearing both sides Your Honour may be pleased to pass Order for releasing your petitioner on bail. And your petitioner as in duty bound, shall ever pray. Advocate AB Verification I, AB, son of MN, aged about 30 years, by occupation business, residing at....................do hereby solemnly affirm and say as follows: 1. I am the petitioner above-named and I know the facts and circumstances of this case. 2. The statements in paragraphs 1 to 4 in the foregoing petition are true and correct to the best of my knowledge and belief. 3. I sign this verification on this 20th day of June 2010. Solemnly affirmed by the said AB on 20th day of June 2010 at the Court House at Mumbai  AB Before me Notary/Magistrate Download Word Document In English. (Rs.20/-) Download PDF Document In Hindi. (Rs.20/-)

Application for condonation of delay in filing the application for Revision before the Hon'ble High Court Court/Sessions Court IN THE HIGH COURT OF JUDICATURE AT ………………… Criminal Misc.  Application No. …………….. of ……….. (Under Section 5 of the Indian Limitation Act) In Criminal Revision No. ………….of  20………… District………………………………… ………….....   …Applicant/Accused Versus State of……………………………. …………….. … Opposite Party To The Hon'ble Chief justice and his companion Judges of the aforesaid Court. The humble application on behalf of the applicant most respectfully showeth as under: 1. That on facts stated in the accompanying affidavit it is just and expedient in the interest of justice that the Hon'ble Court may be pleased to condone the delay in filing the present Revision. PRAYER It is, therefore, most respectfully prayed that this Hon’ble Court nay be pleased to condone the delay in filing the present revision and may also be pleased to pass such other and further orders as it deems fit in the circumstances of the case. Date………. Advocate for the Applicant Download Word Document In English. (Rs.15/-) Download PDF Document In Hindi. (Rs.15/-)

FORM NO. 50 WARRANT OF ATTACHMENT AGAINST A SURETY ( See  Section 446) To, ...................of...................... Whereas (name, description and address) has bound himself as surety for the appearance of (mention the condition of the bond) and the said (name) has made default, and thereby forfeited to Government the sum of rupees (the penalty in the bond); This is to authorise and require you to attach any movable property of the said (name) which you may find within the district of                   , by seizure and detention ; and, if the said amount be not paid within            days to sell the property so attached, or so much of it as may be sufficient to realise the amount aforesaid, and make return of what you have done under this warrant immediately upon its execution. Dated, this ............................. day of ..................., 20...   (Signature) (Seal of the Court) Download Word Document In English. (Rs.15/-)

FORM NO. 35 WARRANT OF IMPRISONMENT ON FAILURE TO PAY  COMPENSATION ( See  Section 250) To, The Officer in charge of the Jail  At…………………………………. Whereas (name and description) has brought against (name and description of the accused person) the complaint that (mention it concisely) and the same has been dismissed on the ground that there was no reasonable ground for making the accusation against the said (name) and the order of dismissal awards payment by the said (name of complainant) of the sum of rupees as compensation ; and whereas the said sum has not been paid and an order has been made for his simple imprisonment in Jail for the period of................... days, unless the aforesaid sum be sooner paid ; This is to authorise and require you to receive the said (name) into your custody ; together with this warrant, and to keep him safely in the said Jail for the said period of (term of imprisonment), subject to the provisions of Section 69 of the Indian Penal Code, unless the said sum be sooner paid, and on the receipt thereof, forthwith to set him at liberty, returning this warrant with an endorsement certifying the manner of its execution. Dated, this ............................. day of ..................., 20...   (Signature) (Seal of the Court) Download Word Document In English. (Rs.15/-)

MODEL FORM OF COMPLAINT Annexure-III Model Form of Complaint  TITLE OF COMPLAINTS IN THE CONSUMER DISPUTES REDRESSAL COMMISSION AT.................... Consumer Complaint No..................... of 19.................... A. B. (add description and residence)............................. Complainant/Complainants versus  C. D. (add description and residence)..................... Opposite Party/Opposite Parties To The Hon’ble President and his companion members of the State Commission.  Sirs, The Complainant/Complainants named above respectfully submits/submit as follows: 1. All facts relating to the complaint, particulars, place, date etc. are to be stated. 2. 3. 4. Details regarding cause of action at the place where the complaint is being filed. 5. Details relating to jurisdiction and value of goods/services and compensation claim are to be given. 6. Prayer clause with details of relief/reliefs being claimed are to be stated. Place.................... Complainant/Complainants Date.................... In person or through Counsel VERIFICATION I/We.................... (Complainant/Complainants) son/sons of.................... resident of.................... do hereby solemnly declare and state that the contents/ particulars of the complaint stated above are true to the best of knowledge and belief. Nothing stated therein is false and nothing has been mis-stated/concealed therein. Verified at.................... this................. day of.................... 19.................... Deponent  Annexures 1. ........................ 2. ........................ Download Word Document In English. (Rs.15/-) Download PDF Document In Hindi. (Rs.15/-) Download PDF Document In Marathi. (Rs.15/-)

REPLY OF RESPONDENT TO THE COMPLAINT FILED BY THE COMPLAINANT BEFORE THE CONSUMER DISPUTES REDRESSAL FORUM.................... Case No..................... of 19.................... C. D............................................................ Complainant versus  C. F........................................... Respondent/Opp. Party MOST RESPECTFULLY SHOWETH: The Respondent company most respectfully submits as under: —  Parawise reply 1. Para 1 of the complaint is admitted to the extent as is borne out from the advertisement of respondent company. 2. Para 2 of the complaint is wrong and denied. The respondent company respectfully submits that it has not so far received any complaint from any of its customers/users. The respondent company further submits that the product in question is meant for repelling the mosquitoes, cockroaches, bedbugs, ticks and houseflies. The word ‘repelling’ means to drive back, to force away, discourage, to check, the advance of, to repulse, to create aversion or distate in. (The Lexicon Webster Dictionary Vol. II1986 Edition). It is further submitted that there is a method for repelling, that is, when the repelling is done in a room, it has to be kept closed for atleast half an hour and only thereafter the said room is to be used. The product, it is submitted, does not contain any poisonous element which may cause vomiting, giddiness, headache and nausea. It is also submitted that the complainant has not repelled the product as per the instructions indicated on the repeller, as hereinbefore indicated. Since the product does not contain any element of poison, the allegation of the complainant, that the complainant himself and his family had to suffer from vomiting, giddiness, headache and nausea from the use of the repeller and also to be hospitalised is totally wrong and baseless and the said allegations have been made just to defame the respondent company’s product. 3. Para 3 of the complaint is admitted to the extent as is borne out from the records. It is submitted that on receipt of the complaint, the complainant was requested to send the repeller and take back the cost of the repeller. The allegation of the complainant that the company did not respond to the letter of the complainant is wrong and denied. It is submitted that the respondent company has not indulged in any unfair trade practice and the product sold by the respondent company is not effectless if the same is used as per the instructions on the repeller. 4. The contents of para 4 are wrong and denied. It is submitted that the product of the respondent company does not suffer from any detect or it is effectless. Furthermore the respondent company has not made any misrepresentation but has clearly indicated thereon the method of use of the repeller and is in no way cheating its customers/users. The respondent company has not so far received any complaint from any of its customers/users. It is submitted that the respondent company is still willing to refund the price of the repeller on the complainant returning the repeller to the respondent company. The prayer clause is totally misconceived. The respondent company, it is submitted, is not at all responsible as the repeller has not been used by the complainant as per the instructions on the repeller. The respondent company is pot at all indulging in any unfair trade practice as the product of the company is neither defective nor health hazardous as the same does not contain any element of poison. The product of the company is only a repeller to drive back, to force away, check the advance of mosquitoes cockroaches, bedbugs etc. in case it is repelled in the room as per instructions on the repeller. It is submitted that the complaint of the complainant being based on baseless allegations deserves to be dismissed. It is therefore prayed accordingly. Place.................... Advocate for the Respondent Dated.................... CASE-LAW  DEFICIENCY IN COURIER SERVICE — NON-DELIVERY OF COVER. Where there is carriage of the invoice with limited liability in the event of non-delivery of the cover thereof liability of the courier is limited to the amount undertaken in the contract entered into by the parties. 1 Statutory body is not outside the purview of the Consumer Protection Act.2 Allottee of a flat by builder is a consumer.3 Order of granting connection cannot be passed under Section 14 of the COPRA.4 Ss. 2(l)(d) and 2(l)(o) of COPRA Payment of tax is not a consideration for service rendered by Government and a complaint about any deficiency in such service cannot be entertained by Redressal Forum under the Act.5 The person who presents a document for registration and pays the stamps duty on it or the registration fee does not become a consumer nor do the officers appointed to implement the provisions of the two acts render any service within the meaning of Consumer Protection Act.6 The exclusionary clause in Section 2(l)(d)(i) of COPRA shows that the intention of the legislature appears to be that when the goods are exchanged between a buyer and the seller for, commercial purpose or for re-sale, such a commercial transaction is excluded from the purview of the Act. Instead the legislature intended to confine the redressal to the service contracted or undertaken between the seller and the consumer defined under the Act.7 S. 16(l)(a) For appointment to the office of the President of the State Consumer Disputes Redressal Commission the opinion of the Chief Justice of the High Court and the requirement of consultation with him must have the same status as that of the chief Justice in the appointment of a High Court Judge under Article 217 of the Constitution of India and it is for the Chief Justice of the High Court to initiate the proposal and to mention the name approved by him for appointment instead of the Chief Justice only approving the name suggested by the State Government.8 APPLICATION UNDER SECTION 27 OF THE CONSUMER PROTECTION ACT, 1986 FOR EXECUTION OF ORDER BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL FORUM AT.................... Execution application No..................... of 200 In the Matter of: - AB............................................ Applicant/Complainant versus CD....................................................... Opposite Parties APPLICATION UNDER SECTION 27 OF THE CONSUMER PROTECTION ACT, 1986 FOR EXECUTION OF ORDER DATED .................... PASSED BY HON’BLE DISTRICT CONSUMER DISPUTES REDRESSAL FORUM Most Respectfully Showeth: - 1. That the applicant-complainant filed complaint for refund of original booking amount alongwith interest, cost and compensation of.................... car booked vide Form No..................... dated.......................... against the opposite parties. 2. That the Hon’ble District Consumer Disputes Redressal Forum vide its order dated the.................... allowed the complaint and directed the opposite parties to (set out gist of order). The said order of the Forum is annexed hereto and marked as annexure-1. 3. The applicant-complainant sent a copy of the said order of the Forum to the opposite party through his Advocate on the.................... for compliance under certificate of posting but the opposite party has failed and neglected to comply with the said order of the Forum till the filing of this execution application. A photocopy each of the letter and the certificate of posting is annexed hereto and marked as Annexure-II. PRAYER It is therefore most respectfully prayed that this Hon’ble Forum may in the interest of justice order execution of the said order by invoking powers vested in the Forum under section 25 of the Consumer Protection Act, 1986 against the opposite party. And to pass such order or orders as this Hon’ble Forum may deem fit and proper in the circumstances of the case. Applicant-complainant  Through Advocate  Place:.................... Dated:.................... CASE LAW Where action is taken under section 27 of the Consumer Protection Act, a notice should be issued to the person sought to be proceeded against and before punishment and imposition of sentence he should be heard.1 1. Bharathi Knitting Company v. DHL Worldwide Express Courier Division Airfreight Ltd., 1996 (5) Supreme 439. 2. Municipal Corporation v. Jaibhagwan Suganchand Jain, 1991 (I) C. P. R. 509. 3. Prem Sajanani v. M/s. Rekha Developers, 1993 (I) C. P. R. 607. 4. Gujarat Electricity Board v. Suleman Mithabhai, 1993 (2) C. P. R. 294. 5. S. M. N. Consumer Protection Council v. Chief Engineer Highways and Rural Works, 1992 (1) C. P. R. 107. 6. S. P. Goel v. Collector of Stamps, 1996 (1) C. C. C. 17 (S. C. ). 7. Rajeev Metal Works v. The Mineral & Metal Trading Corporation of India Ltd., 1996 (1) C. C. C. 26 (S. C. ). 8. Ashish Handa v. Hon’ble the Chief Justice of High Court of Punjab and Haryana, 1996 (1) C. C. C. 375 (S. C. ). 1. Union of India v. Madras Provincial Consumer Association 1986-1995 Consumer 1200 (National Commission). Download Word Document In English. (Rs.40/-) Download PDF Document In Hindi. (Rs.40/) Download PDF Document In Marathi. (Rs.30/-)

Written statement to be denied on behalf of the bank in the above complaint BEFORE THE HON'BLE DISTRICT CONSUMER FORUM, MEERUT Consumer Complaint No. 176 of 2010 XYZ …………….Complainant V ABC Bank Ltd. ........... …………….Opposite Party   Sir,   The above Opposite Party submits reply as under:   (1)That the contents of paragraph 1 to 5 of the complaint are admitted.   (2)That the contents of paragraph 6 of the complaint are denied that the cheque No …………….dated …………….for Rs. 25,000 drawn in favour of Shri  …………….was not issued by the Complainant. It is submitted that the said cheque was issued by the Complainant himself and the cheque No …………….has been issued to the Complainant on alongwith 9 (nine) other cheques. The Complainant used 9 cheques out of the said cheque book and got another cheque book issued on …………….and the 10th cheque has been issued now which is in dispute.   (3)That with reference to para 7 of the complaint, it is admitted that the Complainant approached the Branch Manager of the Opposite Party and wanted to see the cheque, dated …………….for Rs. 25,000 and the Branch Manager shown the said cheque to the Complainant. Rest of the allegations made in the said paragraph are denied.   (4)That the contents of para 8 of the complaint is admitted to the extent that the Complainant sent notice, dated  …………….through his Advocate Shri ……………. It is denied that no reply was given to the said notice. The said notice was replied to Shri   …………….Advocate vide Shri ..........................Advocate, Bank's Advocate. The copy of the reply sent by Bank's Advocate Shri …………….is enclosed herewith to this reply and marked as Annexure 1.   (5)That the contents of para 9 of the complaint are denied. There is no deficiency on the part of the bank. The specimen signatures of the complainant recorded with the bank were compared with the signature on the cheque and the signature on the cheque No  …………….dated …………….for Rs. 25,000 drawn in favour of Shri …………….resembled with the signature kept on record. There is no negligence on the part of the bank. It is also denied that the Complainant has incurred a loss of Rs.25,000 due to deficiency in service by the bank.   (6)That with reference to para 10 of the complaint, it is denied that any cause of action has arisen to file this complaint against the bank   (7)That the contents of para 11 of the complaint are denied. The complainant is not entitled to any compensation from this opposite party. The claim is misconceived, frivolous, vexatious and filed for ulterior motive. The claim made by the Complainant is not maintainable and liable to be dismissed with costs.   (8)That the contents of para 12 of the complaint are strongly denied. It is denied that the complainant is entitled to the loss and compensation from this opposite party. This Opposite Party does not admit the claims made by the Complainant or any part of the same. It is submitted that the claims of the Complainant are liable to be dismissed with cost as being misconceived, frivolous, vexatious and filed for ulterior motives.   (9)That with reference to para 13 of the complaint, it is denied that any cause of action has arisen to file this complaint and this Forum has the jurisdiction to try this complaint against this Opposite party.   (10)That with reference to para 14 of the complaint, it is denied that any cause of action has arisen to file this complaint and therefore there is no question of filing this complaint within the limitation period.   (11)That with reference to para 15 of the complaint, it is denied that the Complainant is entitled to the reliefs as claimed or any other relief from this Forum. The complaint is liable to be dismissed with costs.   It is therefore prayed that the complaint be dismissed with costs.   For ABC Bank Ltd.,  Opposite Party Place By the hands of ……………. Dated Authorised Signatory Through ........................................ Advocate   Verification   I …………….s/o …………….Working as Branch Manager, ABC Bank Ltd  …………….Branch ……………. And the principal officer and authorized attorney of the Opposite Party Bank hereby state on solemn affirmation that the contents of para 1 to …………….of this reply are true to my personal knowledge and belief and on the basis of records which I believe to be true, the contents of para …………….to …………….are based on legal advice which I believe to be true and the contents of para …………….are my submissions to this Hon'ble Forum.   Verified on this …………….day of …………….2010 Signed at …………….on this …………….day of 2010.   Principal Officer Download Word Document In English. (Rs.30/-) Download PDF Document In Hindi. (Rs.30/-) Download PDF Document In Marathi. (Rs.30/-)

Applications for deficiency of service defective washing machine In the District Consumer Disputes Redressal Forum Dahod Collectorate, Dahod Consumer Complaint No……………of 2010............ In the matter of: A complaint under sections 11 and 12 of the Consumer Protection Act 1986 and the Rules made thereunder And………………                                                                                                    Mr. X residing at Complainant versus……………… Machinery Company Limited, a company incorporated under the Companies Act 1956 and carrying on business at………………………............. Respondent To The Hon'ble President and His Companion Member of the District Consumer Disputes Redressal Forum The complainant above-named most respectfully Sheweth: 1. The respondent is a manufacturer of electrical goods including Washing Machines and carries on business in...................... 2. The claim of compensation and/or redressal of grievances of the complainant does not exceed Rs. 5 lakhs. 3. The complaint relates to the malfunctioning of the Washing Machine purchased by the complainant from the respondent about 18 months ago. This Application is being made within 2 years from the date of cause of action for making this application. 4. On 15th June 1998 the complainant purchased one Automatic Washing Machine from the respondent at Rs. 20, 000. 5. The complainant paid the price, took delivery of the machine and the respondent issued a cash memo and a Guarantee/Warranty Card guaranteeing the proper functioning of the machine. The guarantee was valid for 3 years. 6. After about 7 days of running the said machine in accordance with the printed instructions given by the respondent the machine did not work properly. The complainant by his letter dated 25th June 1998 complained to the respondent setting out the malfunctioning of the Washing Machine including the non-working of the spinning mechanism. 7. The respondent sent its mechanic who apparently repaired the defect. But after some time again there was the malfunctioning of the machine since its water pump was not properly functioning. Its spinning mechanism also did not work. 8. After several reminders the respondent sent its mechanic who tried to repair the machine and ultimately made the machine workable but stated that the defect was a manufacturing one and therefore the same could not be fully repaired. 9. The complainant requested the respondent by a letter dated 10th December 1998 to replace the said machine as there was a manufacturing defect and in spite of best efforts the respondent's mechanic could not repair the defects. The respondent received the said letter but neither replaced the machine nor repaired the defect nor replied to the said complaint. A copy of letter and copy of the receipt are annexed hereto marked "A" and "A-1. 10. Copies of the Cash Memo and the Guarantee Card are annexed hereto marked "B" and "C" respectively. 11. Copies of the previous complaints are annexed hereto marked "D". 12. By reasons of the breach of the agreement, breach of the Warranty and negligence of the respondent, the complainant has suffered loss and damages which the complainant assesses at Rs. 35, 000. 13. In the facts and circumstances of the case the complainant prays for the following reliefs: (a)Refund of Rs. 20,000 paid to the respondent for the purchase of the said Washing Machine; (b)Interest from date of purchase on Rs. 20,000 at 18% per annum; (c)Damages for harassment, physical injury and mental agony assessed at Rs. 35,000; (d)Costs of the present proceeding; (e)Further and other reliefs as the complainant is entitled to And the complainant as in duty bound shall ever pray. Place:............ Date:………………………………………Signature of Complainant Verification I, Mr. X............son of Mr. Y. residing at............Dahod, Bihar do hereby solemnly declare and state that the statements contained in the preceding paragraphs of this complaint are true to the best of my knowledge and belief and nothing stated herein is false and I have not suppressed any material fact. Verified at............Collectorate on this........day of 2010 Deponent Identified by me ………………………….. Advocate Annexure: 1 Cash Memo 2 Guarantee Card 3 Letters of complaint Download Word Document In English. (Rs.30/-) Download PDF Document In Hindi. (Rs.30/-) Download PDF Document In Marathi. (Rs.20/-)

APPEAL UNDER SECTION 19 OF CONSUMER PROTECTION ACT IN THE STATE CONSUMER DISPUTES REDRESSAL COMMISSION AT.................... Appeal No..................... of 19.................... Appeal under Section 19 of the Consumer Protection Act against the order of District Forum.................... (mention place) A. B. (add description and residence)....................................... Appellant/Appellants versus  C. D. (add description and residence)................................. Respondent/Respondents To The Hon’ble President and his companion members of National Commission.  Sirs, The Appellant/Appellants most respectfully showeth: 1. This is in appeal under Section 19 against the Order of the State Commission.................... (name of place) dated.................... in Appeal No. .................... of 19.................... 2. That the appeal is being filed within a period of 30 days from the date of Order as per the provisions of Section 19 of the Consumer Protection Act.  OR That this appeal is being filed after the expiry of period of 30 days as it could not be filed within the prescribed period for the reasons mentioned in the application filed along with this appeal for condonation of delay. The said application is being disputed by an Affidavit. 3. Grounds of objections to the order appealed against may be set forth concisely and under distinct heads without any argument or narrative; such grounds are to be numbered consecutively. 4. Prayer clause with details of relief/reliefs being claimed are to be stated. Place.................... Appellant/Appellants Date..................... In person or through Counsel Download Word Document In English. (Rs.15/-) Download PDF Document In Hindi. (Rs.15/-) Download PDF Document In Marathi. (Rs.15/-)