STATE CONSUMER DISPUTES REDRESSAL COMMISSION
OF TELANGANA AT HYDERABAD
CC NO.186 OF 2015
Between :
1) Mrs.Bhanumati Durbha
W/o late Madhav Mohan Durbha,
aged about 59 years, Occ: United Nations Official
2) Shankar Durbha S/o late Sh.Madhav
Mohan Durbha, aged about 30 years,
Occ: Entertainment Media Professional,
3) Vijay Durbha S/o late Madhav Mohan
Durbha, aged about 28 years,
Occ: Sound Engineer/Radio Producer,
All are resident of # 105, Lantana,
Nahar Amrit Shakti, Chandivali,
Andheri East, Mumbai – 400 072.
Maharashtra State.
…Complainants
AND
1) M/s Aliens Developers (P) Ltd.,
Aliens Space Station, Gachibowli,
Tellapur, Hyderabad – 502 032.
2) M/s Aliens Developers Pvt., Ltd.,
Rep. by N.Ashok Kumar
S/o Nageshwar Rao, Asst. Manager (B.D. Finance)
Aliens Space Station, Gachibowli,
Tellapur, Hyderabad – 502 032.
3) M/s Aliens Developers Pvt., Ltd.,
Rep. by Ravi Murali Krishna
S/o Ramesh Ravi, Manager (Finance & Accounts)
Aliens Space Station, Gachibowli,
Tellapur, Hyderabad – 502 032.
4) Chilakamarri Mukund Reddy,
R/o Thellapur (v), R.C. Puram mandal,
Medak district – 502 032.
5) Maddikunta Suvarna W/o Ananth Reddy,
R/o Kollur (v), R.C. Puram (M),
Medak district – 502 032.
6) Koulagari Aruna W/o K.Sudershan Reddy,
R/o BHEL, R.C. Puram (M),
Medak district – 502 032.
7) Chilakamarri Venkateshwar Reddy
R/o Thellapur (v), R.C. Puram (M),
Medak district – 502 032.
8) Chilakamarri Prabhakar Reddy
R/o Thellapur (v), R.C. Puram (M),
Medak district – 502 032.
9) Chilakamarri Veera Reddy,
R/o Thellapur (v), R.C. Puram (M),
Medak district – 502 032.
10) P.Sakhu Bai W/o P.Madhava Reddy,
R/o Evathbarpally (v), Moinabad (M),
Ranga Reddy district – 501 504.
11) K.Vanaja W/o K.Janardhan Reddy,
R/o Patancheru (v), R.C. Puram (M),
Medak district – 502 032.
12) Bandla Veeroja W/o D.Pratap Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
13) Dhadi Indira W/o D.Madhusudhan Reddy,
R/o BHEL, R.C. Puram (M),
Medak district – 502 032.
14) R.Soundarya W/o R.Krishna Reddy,
R/o Mulugu village & Mandal,
Medak district – 502 032.
15) Chilkamarri Ananth Reddy
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
16) Akunapuram Suneetha
W/o Narsimha Reddy,
R/o Langerhouse, Hyderabad – 8.
17) Sheri Vijaya Nirmal
W/o Sudhakar Reddy,
R/o Hyderguda, Hyderabad – 500 048.
18) Dhadi Manjula W/o Madhusudhan Reddy,
R/o Yellareddyguda, Hyderabad – 45.
19) Patel Surekha W/o Naveen Kumar,
R/o Gangaram village, R.R. district.
20) Taduri Radhika W/o Manohar Reddy,
R/o Miyapur, Ranga Reddy district-49.
21) Chilakamarri Usha Rani D/o C.Ananth Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
22) Chilakamarri Rajender Reddy
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
23) Chilakamarri Vinay S/o C.Rajender Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
24) Chilakamarri Vamshi S/o C.Rajender Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
25) Chilakamarri Ranga Reddy
S/o Venkat Reddy, R/o 2-1-339/1,
Nallakunta, Hyderabad – 500 044.
26) Gillela Niveditha W/o G.V.V.Reddy,
R/o Flat No.101, Keerthi Apartments,
Tilak Nagar, Hyderabad – 500 013.
27) Patlolla Sukanya W/o P.Venkat Reddy,
R/o 2-1-340/3/201, Nallakunta,
Hyderabad – 500 044.
28) Chilakamarri Hanumanth Reddy
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
29) Chilakamarri Venkat Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
30) Chilakamarri Gopal Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
31) L.Puthli W/o L.Narayan Reddy,
R/o H.No.22326, Ordinance Factory Estate,
Eddumailaram (v), Patancheru (M),
Medak district – 502 319.
32) C.Nandini Srilatha D/o C.Hanumanth
Reddy, R/o Thellapur (v),
R.C. Puram (M), Medak district-502 032.
33) M.Bharathamma W/o late M.Malla Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
34) M.prabhakar Reddy W/o late M.Malla Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
35) Dhadi Mahalaxmi @ Bhagyavathi
W/o Madhusudhan Reddy,
R/o Musheerabad, Hyderabad – 500 020.
36) Sidhenki Sunitha W/o S.Venkat Reddy,
R/o Pedda Amberpet, Hayathnagar mandal,
Ranga Reddy district – 501 505.
37) Mandada Sudhakar Reddy
S/o late M.Reddy, R/o Thellapur (v),
R.C. Puram (M), Medak district – 502 032.
38) Mandada Narender Reddy
S/o M.Ranga Reddy, R/o Thellapur (v),
R.C. Puram (M), Medak district – 502 032.
39) M.Chandrashekar Reddy
S/o M.Ranga Reddy, R/o Thellapur (v),
R.C. Puram (M), Medak district – 502 032.
40) Mandada Srinivas Reddy
S/o M.Ranga Reddy, R/o Thellapur (v),
R.C. Puram (M), Medak district – 502 032.
41) M.Janardhan Reddy S/o late Janga Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
42) G.Mamtha W/o G.Amarender Reddy,
R/o Kanapur village, Rangareddy district.
43) Mandada Raji Reddy
S/o M.Janardhan Reddy,
R/o Thellapur (v), R.C.Puram (M),
Medak district – 502 032.
(Complaint against Ops No.4 to 43 is not
pressed by the counsel for complainants on 05.12.2016).
… Opposite Parties
Counsel for the Complainants : Sri Jabez Samuel
Counsel for the Opp. parties : M/s Alluri Krishnam Raju & G.Dinesh Kumar
Coram :
Hon’ble Sri Justice B.N.Rao Nalla … President
and
Sri Patil Vithal Rao … Member
Thursday, the Nineteenth day of January
Two thousand Seventeen
Oral Order : (per Hon’ble Sri Justice B.N.Rao Nalla, Hon’ble President)
***
This is a complaint filed under Section 17(1)(a)(i) of the Consumer Protection Act, 1986 by the Complainants seeking to direct the Opposite parties jointly and severally to handover the flat forthwith on completion in all aspects besides obtaining of Occupancy Certificate and registration in favour of the Complainant; alternatively pay back the sale consideration of Rs.20,24,007/- along with interest @ 24% p.a. from the respective dates of payment to till realization; to pay compensation towards rent on investment; to pay penalty and costs of the complaint.
2. The case of the Complainants, in brief, is that the Opposite party No.1 company represented to them that they are engaged in the business of constructing multistoried apartments and entered into development agreement with the owners of the land comprised in survey nos. 384, 385 and 426/A situate at Tellapur village, Ramchandrapur Mandal, Medak district to construct high rise apartments under the name and style of ‘Aliens Space Station’ and obtained permission bearing No.HUDA/621/P4/PLG/HUDA/2008 and they would provide all amenities therefor, would give possession by the end of November, 2013 with a grace period of 6 months and on such representation of the opposite parties, the complainants entered into agreement of sale on 14.02.2012 for purchase of flat bearing No.1246(B) on 12th (B) Floor in Station-8, having super built-up area of 2150 sft with one car parking along with undivided share of land of 46.23 sq.yds., in the Aliens Space Station-1 situated at Tellapur village, Ramachandrapuram mandal, Medak district.
3. In pursuance of the agreement of sale, the Complainants paid the sale consideration amount on various dates, altogether amounting to Rs.33,62,007/- as against the agreed amount of Rs.69,92,763/-.
4. The Opposite parties had not commenced construction of the flats even after the stipulated period is expired. There is no possibility of the construction of the flat as also the Opposite parties had not responded to the repeated requests of the Complainants. As such, complainants are living in a rented house and their precious savings are blocked with the Ops. They being aged and sick persons are made to visit Hyderabad all the way from Mumbai. The Ops in collusion with the bank personnel have got released the loan instalment, against the provisions of Section 4 and 5 of the A.P. Apartments (promotion of construction and Ownership) Act. There was no response to the mails addressed by the Complainants to the Ops as to the progress of the project.
5. The Ops agreed to complete the construction of the flat by November 2013 with a grace period of 6 months. Though much considerable time had elapsed, there is no progress in the construction activity. The Complainants got issued notice dated 03.09.2015 seeking refund of the amount, to which, Ops gave reply on 11.09.2015 shifting its burden. These acts of the Ops amount to deficiency in service, as a result of which, Complainants suffered agony and pain. Due to non-completion of the flat, complainants are living in a rented house paying huge rents. The very purpose of owning a house is defeated on account of deficiency in service on the part of the Ops. The Complainants are paying monthly instalments and interest on the amount obtained by way of home loan besides rent for the house where they are staying at present. Due to the fraudulent actions on the part of the Ops, complainants suffered with mental agony, escalation of cost and physically. Hence, the complaint.
6. The opposite parties no.1 and 3 resisted the claim on the premise that the complaint alleging deficiency of service on the part of Ops relating to the sale transaction entered between them is not maintainable either under law and also in view of the facts of the case and hence liable to be dismissed in limine and also in view of the fact that the Complainants did not approach them before filing the complaint either for refund of money or for cancellation or with any request, hence, cannot attribute any deficiency of service, hence, does not fall under the purview of the C.P. Act.
7. The opposite parties submitted that on their application for conversion of agricultural land into non-agricultural land and FTL clearance, permission was granted for conversion of agricultural land into non-agricultural land on 14.04.2007 and FTL clearance was granted on 30.12.2006 and thereafter HUDA earmarked the land as agricultural zone and the opposite parties have filed application for change of use of the land as commercial use zone. The Municipal Administration and Urban Development (I) Department notified the land in survey number 384 as residential use zone. The project could not be commenced in view of proposed road under Master Plan, until realignment of the proposed road without affecting the land in survey number 384 is made. Realignment of the proposed road was approved on 03.04.2008 and the permission was accorded approving the building plan on 11.04.2008. The opposite parties have obtained NOC from the AP Fire Services Department on 15.12.2007 and permission was granted in respect of the building with height of 90.40 meters. The opposite parties obtained NOC from Airport Authority on 10.07.2009.
8. The opposite parties have submitted that HUDA accorded technical approval on 14.10.2009 for ground + 20 upper floors and release of building permission up to 29 floors is awaited. The opposite parties have taken all necessary steps to complete the project at the earliest and the project being massive and due to the reasons beyond the control of the opposite parties, they could not complete the project within the time frame. They informed the complainants about the delay in completion of the project due to delay in clearance from the authorities concerned. In view of arbitration clause, the complaint is not maintainable before this Commission. As per clause-18 of the agreement, the disputes shall have to be resolved by way of arbitration.
9. The opposite parties submitted that they agreed to pay Rs.3/- per sqft in terms of Clause VIII (g) of the Agreement for the delay caused in completing the project and adjust the amount towards dues payable by the complainants. Though the delay occurred for completion of the project is beyond their control, the Ops to maintain goodwill and relationship with the customers, willing to pay the compensation at agreed rate. But the Complainants filed the present complaint with an ulterior motive to defame and to gain. The complainants are put to strict proof of the payments made by producing the relevant receipts. The complainants have to pay admittedly the balance consideration and other charges, therefore, unless the complainants pay the balance consideration, asking for delivery of flat is illegal and arbitrary.
10. The reasons for delay is project required clearance from statutory bodies which are necessary for execution of the project. The said fact was informed to the Complainants and even mentioned in the agreement of sale under clause No.XIV and described as “force majeure”. The Complainants who paid the part of sale consideration want to take back the investment from Hyderabad due to the changed circumstances in Hyderabad market after bifurcation of the State, thereby sought for refund of the amount. As there is some delay on the part of the Ops in delivering the flat, the complainants taken advantage of the same and filed the present complaint to avoid cancellation charges. The complaint is not within the limitation as time prescribed under Section 24A of the C.P. Act, hence not maintainable. The complainants are not entitled for refund of amount and interest thereon and any compensation and costs. There is no cause of action for the present complaint. If the complainants want to cancel their booking, they can do so in conformity with terms of agreement only.
11. The complainants failed to pay balance sale consideration as per the terms of the Agreement. The opposite parties had taken every care as to the benefit of their customers and incorporated clause in the Agreement as to their liability to pay damages @Rs.3/- per sq.ft. which would show their fairness and the complainants are not entitled to any money or compensation. The Complainants are not entitled for any compensation and their claim is illegal. The delivery of the flat is subject to the balance payments and additional charges whatever liable to be paid for the flat and the common amenities and other certificates, etc., will be made available to the Complainants after completion of the project along with other residents. The complaint is barred by limitation and liable to be dismissed on this ground alone. There is no deficiency of service on the part of the Opposite parties. Hence, prayed for dismissal of the complaint.
12. The Complainants got filed the affidavit of Complainant No.1 as evidence and the documents Ex.A1 to A16 and on behalf of the opposite parties, the Managing Director of the Opposite party no.1 by name Hari Challa filed his affidavit, however, no documents.
13. Heard both sides. The counsel for the Complainants and the Opposite parties had advanced their arguments reiterating the contents of the complaint and the written version.
14. The points for consideration are :
i) Whether the complaint is maintainable in view of arbitration clause in the agreement of sale ?
ii) Whether the complaint is not a ‘consumer dispute’?
iii) Whether there is any deficiency in service on the part of the Opposite parties?
iv) To what relief ?
15. POINT NO.1 : The Complainants entered into “Agreement of Sale” with the Opposite parties on 14.02.2012 for purchase of the subject flat, for the consideration and paid the monies for the flat proposed to be constructed by the Opposite parties, which is not in dispute. The agreement of sale was entered into between the Complainants and the Opposite parties in respect of the above stated flat as long back on 14.02.2012. Thereafter, the Complainants paid the substantial amount of consideration as per the pricing pattern of the flat issued by the Ops, on various dates. The agreement of sale provides for reference to arbitration. The learned counsel for the opposite parties had contended that in view of the arbitration clause in the agreement, the Complainants cannot maintain the complaint before this Commission.
16. However, remedy provided under the provisions of Consumer Protection Act is an additional remedy and in the light of law laid in “National Seeds Corporation Ltd., Vs. M.Madhusudhan Reddy reported in (2012) 2 SCC 506 wherein the maintainability of the complaint before consumer forum prior to the complainants having exhausted the other remedy was considered as under:
“The remedy of arbitration is not the only remedy available to a grower. Rather, it is an optional remedy. He can either seek reference to an arbitrator or file a complaint under the Consumer Act. If the grower opts for the remedy of arbitration, then it may be possible to say that he cannot, subsequently, file complaint under the Consumer Act. However, if he chooses to file a complaint in the first instance before the competent Consumer Forum, then he cannot be denied relief by invoking Section 8 of the Arbitration and Conciliation Act, 1996 Act. Moreover, the plain language of Section 3 of the Consumer Act makes it clear that the remedy available in that Act is in addition to and not in derogation of the provisions of any other law for the time being in force.”
Thus, in view of the ratio laid in aforementioned decision, the consumer has two options, either to proceed for arbitration process or to invoke the provisions of the Consumer Protection Act. As such, it cannot be said that the complaint is not maintainable before this Commission in view of the arbitration clause in the agreement. For the above reasons, the Point No.1 is answered in favour of the Complainants and against the Opposite parties.
17. In the arguments, counsel for Complainants reiterated the same facts as averred in the complaint besides stating that the Opposite parties ought to have acted in accordance with the provisions of the Andhra Pradesh (Promotion of Construction and Ownership) Act & Rules, 1987 while undertaking such agreements and hence pleading ‘force majeure’ does not arise. They relied on Section 72 of Indian Contract Act supported by the Judgment of Hon’ble Apex Court in Brij Pal Sharma Vs. Ghaziabad Development Authority reported in III (2005) CPJ 43 (SC) and submitted that the Apex Court opined that grant of interest @ 18% p.a. by way of damages and compensation is justified. He further relied on decision in Ghaziabad Development Authority Vs.Balbir Singh reported in II (2004) CPJ 12 wherein it is stated “in our view, irrespective of whether there was genuine reason to cancel or not, the monies must be returned with interest @ 18%.” This Commission perused the said Judgments. In Ghaziabad Development Authority versus Balbir Singh, the Hon’ble Supreme Court further observed that the interest shall be payable from the dates of deposit of the amounts till the date of repayment.
18. On the other hand, the counsel for the Opposite parties in the arguments submitted that as per agreement, if the Complainants want to cancel the booking of the flat, they shall forego 20% of the total flat cost as charges which is agreed by them and in that regard, relied on Judgment reported in 2009 (2) CPR 197 (NC) : II (2009) CPJ 276 (NC) in Punjab Urban Planning and Development Authority and another Vs. Shyam Sunder Tiwari and others, wherein, it is held that “courts cannot add anything or improve upon the terms of contract between the parties.” However, this Commission perused the said order. The facts of the said case and facts of the case on hand are different. In the said case, the Petitioner Authority withdrew the scheme and there was provision for refund of earnest money. In the case on hand, there is no provision for refund of earnest money. Admittedly, on failure to comply with terms and conditions agreed by the Opposite parties, the Complainants sought for refund of the amount. Hence, this Commission does not find any merit in the contention put forth by the learned counsel for Ops.
19. POINTS No.2 & 3 : The Opposite parties 1 to 3 entered into Development Agreement with the land owners of the land admeasuring Ac.19.26 guntas in survey numbers 383, 385 and 426/A situate at Tellapur village of Ramachandrapuram mandal, Medak district and they agreed to deliver the residential flat to the Complainants in accordance with the terms and conditions agreed upon and consented thereto and as per specifications given therein. The Development Agreement is not merely an agreement and in fact, it is “Development Agreement-cum-Power of Attorney”.
20. In pursuance of the development agreement, the opposite parties have obtained permission for construction of the residential building on the land and admittedly there has been abnormal delay in completion of the project. The opposite parties have attributed the delay to the authorities concerned in granting permission and No Objection Certificate, bifurcation of the State etc., as to the cause for delay in completion of the project. The opposite parties would contend that the cause for delay is beyond their control which is ‘force majeure’.
21. The ‘force majeure’ clause in the Agreement of sale does not include within its ambit the delay caused in granting permission, NOC etc., The Opposite parties failed to explain how they could take shelter under the cover of “force majeure”. We may state that the delay caused in obtaining permission or NOC etc., cannot be considered as ‘force majeure’. It is quite not understandable how the bifurcation of State can be attributed to be cause for delay in completion of the project. The opposite parties ought to have informed the complainants about the delay likely to be caused in obtaining the permission which they failed to. For that matter, the Opposite parties cannot receive any sale consideration from any person in respect of any flat unless they have obtained permission from HUDA or HMDA.
22. The complainants have submitted that owing to failure of the opposite parties in completing the construction of the subject flat, they opted for cancellation of the agreement of sale of flat and the opposite parties have contended that in order to maintain cordial relations with the complainants, they agreed to pay compensation in terms of the agreement which they entered into in normal course with other customers. The complainants got issued a notice to the Opposite parties on 14.02.2012 and thereafter made e-mail communication on 14.07.2014 with the Ops setting forth series of events of delay and negligence and false promises made by the Opposite parties seeking for refund of the amount on the premise of inaction on the part of the opposite parties. However, the Opposite parties considered the demand of the complainants and made refund of Rs.12,00,000/- which is also not in dispute.
23. The opposite parties have promised to complete construction of the flat and hand over its possession to the complainants within the stipulated time with a grace period of six months and on their failure to perform their part of contract, the opposite parties have proposed to pay rents but failed to pay the same. However, there is no communication from the side of the opposite parties in this regard and the opposite parties have not filed a piece of paper to show their readiness to pay compensation and adjust the same towards the dues payable by the complainants. Having received the part sale consideration amount, the Opposite parties failed to commence the construction work of the building.
24. Not keeping-up promise to complete construction of the building and failure to deliver possession of the flat constitutes deficiency in service on the part of the opposite parties. The complainants have two options left for recovery of the amount, either by filing suit in court of law or by way of filing complaint before State Consumer Disputes Redressal Commission in view of the amount claimed falling within the pecuniary jurisdiction of this commission. The contention of the opposite parties that the complaint is not maintainable is not sustainable.
25. The Opposite parties can only receive such amount of sale consideration which would be in accordance with the payment schedule and correspond to the stage of construction of the flat. However, the Opposite parties had received the sale consideration in excess of what was to be received from the complainants particularly when the construction of the building was not yet commenced. Not keeping-up the promise to complete construction of the building and failure to deliver possession of the flat as also not keeping-up promise to refund the amount as per the terms of the repayment schedule constitutes deficiency in service on the part of the Opposite parties.
26. The complainants claimed possession of flat duly completed in all aspects along with Occupancy Certificate and in the alternate, claimed refund of amount paid together with interest besides claim for damages. However, during the course of arguments, the learned counsel for Complainants opted for refund of the amount. The complainants cannot be said to have acquiesced to the delay in construction of the project. Though the complainants have not disputed that the opposite parties have informed them about the cause for delay in obtaining permission and NOC etc., which does not disentitle them from claiming compensation. The complainants are entitled to interest @ 12% p.a. on the amount paid from the last date of payment till realization. For the reasons stated supra, the Points No.2 and 3 are answered in favour of the Complainants and against the Opposite parties.
27. POINT No.4 : In the result, the complaint is allowed directing the Opposite parties 1 to 3 to pay an amount of Rs.20,24,007/- with interest @ 12% per annum from the date of last payment till payment and a sum of Rs.1,00,000/- towards compensation together with costs of Rs.5,000/-. In case sale deed was executed, the complainants shall re-convey the same to the developer on compliance of above directions. The registration charges and stamp duty etc., shall be borne by the developer OP No.1. Time for compliance: four weeks.
PRESIDENT MEMBER
Dated : 19.01.2017
APPENDIX OF EVIDENCE
WITNESSES EXAMINED
For Complainants : For Opposite parties :
Affidavit evidence of Bhanumathi Affidavit evidence of Hari
Durbha, complainant No.1 Challa (on behalf of Ops 1 to 3)
EXHIBITS MARKED
For Complainants :
Ex.A1 is the copy of receipt bearing No.08840, dated 15.12.2014 for Rs.2,50,000/-.
Ex.A2 is the copy of receipt bearing No.09462, dated 31.12.2011 for Rs.10,94,803/-.
Ex.A3 is the copy of Agreement of sale, dated 14.02.2012 executed by the OP No.1 in favour of the Complainants.
Ex.A4 is copy of allotment letter dated 16.02.2012 addressed by OP No.1 to the Complainants allotting flat No.1246(B).
Ex.A5 is copy of possession letter dated 16.02.2012 addressed by OP No.1 to the Complainants.
Ex.A6 is copy of receipt bearing No.09861, dated 17.02.2012 for Rs.20,17,204/-.
Ex.A7 is copy of Mermorandum of Understanding, dated 03.03.2012 executed by OP No.1 in favour of the Complainants.
Ex.A8 is copy of letter of confirmation on cancellation and payment of refund, dated 01.08.2013 addressed by OP No.1 to the Complainant No.1.
Ex.A9 is copy of the letter dt.15.11.2013 addressed by OP No.1 to Complainant No.1.
Ex.A10 is copy of statement of account of the Complainant’s No.1 account for the period from 01.01.2014 to 31.12.2014.
Ex.A11 is the copy of representation of Complainant No.1 to the Ops, dt.11.08.2015.
Ex.A12 is office copy of the legal notice dated 31.08.2015 got issued by the Complainants to the Opposite parties.
Ex.A13 are the original postal receipts.
Ex.A14 are the original returned postal acknowledgements.
Ex.A15 are the original returned postal covers.
Ex.A16 are the reply notice dated 11.09.2015 got issued by the Ops 19 to 24.
PRESIDENT MEMBER
Dated : 19.01.2017
