Chandigarh

StateCommission

CC/176/2019

Arti Arya - Complainant(s)

Versus

m/s Omaxe Chandigarh Extension Developers Pvt. Ltd. - Opp.Party(s)

Atul Nehra Adv.

19 Apr 2021

ORDER

 STATE CONSUMER DISPUTES REDRESSAL COMMISSION,

U.T., CHANDIGARH

 

Complaint case No.	:	176 of 2019
Date of Institution	:	05.08.2019
Date of Decision	:	19.04.2021

 

Arti Arya R/o H.No.2146, Sector 15-C,  Chandigarh.

•  

Versus

 

M/s Omaxe Chandigarh Extension Developers Pvt. Ltd., through its Managing Director/Directors, Zonal Office India Trade Tower, New Chandigarh, Mullanpur, District SAS Nagar, Mohali, Punjab-140901 (earlier Regional Office was at SCO 143-144, Sector 8-C, Chandigarh)

…..Opposite Party

BEFORE:            JUSTICE RAJ SHEKHAR ATTRI, PRESIDENT.

                          MRS. PADMA PANDEY, MEMBER.

                          MR.RAJESH K. ARYA, MEMBER.

 

Present through Video Conferencing:-    

                  

                   None for the complainant.

Sh.Gazi Mohd. Umair, Advocate for opposite party

 

JUSTICE RAJ SHEKHAR ATTRI, PRESIDENT

                    This complaint has been filed by the complainant seeking directions to the opposite party to pay compensation by way of interest on the deposited amount for the period of delay in delivery of possession of the plot purchased by her in it project; compensation for mental agony and harassment; litigation expenses etc. It is the case of the complainant that despite the fact that she had paid substantial amount of Rs.29,77,724/- against total sale consideration of Rs.31,72,345.98ps. for the period from 10.12.2010 to 06.01.2012, towards plot no.921, measuring 321 square yards, located at Phase-2, Omaxe, New Chandigarh, SAS Nagar, Mohali, possession whereof was to be delivered within a total period of 24 months i.e. 18 months plus 6 months extended period as envisaged under condition no.24 (a) of the allotment letter/agreement dated 07.02.2012, Annexure C-5 i.e. on or before 06.02.2014, yet, it miserably failed to do so. Number of requests made in the matter did not yield any result. Thereafter, vide letter dated 25.01.2018, Annexure C-6 i.e. after a delay of more than 7 years, the opposite party informed the complainant that due to certain changes in allotment plan, she is relocated to plot no.562 P24 measuring 289.27 square yards. It has been stated that since the complainant was not happy with the said relocation, as such, she requested the opposite party to refund the amount paid by her but it refused to do so. It has been pleaded that during the period intervening, the opposite party offered relocation to plot no.423B measuring 302.52 square yards and when she left with no choice, accepted the same, it was told that the same has been sold to somebody else. Ultimately, she was relocated to plot no.OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh and possession thereof has been taken over by her on 29.03.2019, Annexure C-10. It has been stated that she has been relocated to a project in Phase 3 against her wish and the relocation to plot no.OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh was accepted by her as she was having no other alternative. Hence this complaint.

2.           Her claim has been contested by the opposite party, on numerous grounds, inter alia, that in the face of provisions of arbitration clause contained in the agreement to settle disputes between the parties, this Commission is not competent to decide this complaint; that the complainant did not fall under the definition of consumer, as she is a speculator; that this Commission did not vest with pecuniary and territorial jurisdiction to entertain this complaint; that this complaint is bad for misjoinder of necessary party as there is no Managing Director in the company; that complicated questions of fact and law are involved in this complaint as such only the civil court has power to adjudicate the same and not this Commission; that since the present case relates to an immovable property, as such, time was not to be considered as essence of the contract; that in the allotment letter/agreement, it was mentioned that the company shall make its best efforts to deliver possession of the plot within a total period of 24 months from the date of execution of allotment letter/agreement as such no definite period was given for the same; that since it has been mentioned in the allotment letter/agreement that allotment of plot was tentative and also the fact that she was given provisional allotment letter dated 12.12.2011 in respect of plot no.921, measuring 321 square yards, as such, the opposite  party had right to relocate the complainant on account of change in tentative allotment plan; that since the complainant was eager for possession as such she was  offered relocation and ultimately relocated to plot no. OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh, possession whereof has also been taken over by her; that partial completion certificate dated 28.04.2017 in respect of the project in question has also been obtained by the opposite party; that since the plot which has been delivered to the complainant was preferentially located as such she was liable to pay PLC; that excess amount towards the decrease in area of plot no.OCE/II/187O, has already been refunded to the complainant; and that even the delayed payment interest has also been waived off by the opposite party.
3.           On merits, purchase of the plot bearing no.921 in the first instance by the complainant; making payment by her to the tune of Rs.29,77,724/- against total sale consideration of Rs.31,72,345.98ps. for the period from 10.12.2010 to 06.01.2012, in respect of the same; non delivery of possession thereof by the committed date or even thereafter; offer of relocation to another plots; and delivery of possession of plot no. OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh on 29.03.2019, have not been disputed. Remaining averments have been denied being wrong. Prayer has been made to dismiss the complaint with costs.
4.           In the rejoinder filed, the complainant reiterated all the averments contained in the complaint and controverted those contained in the joint written reply filed by the opposite party.
5.           This Commission has afforded adequate opportunities to the parties to adduce evidence in support of their respective contentions, by way of filing affidavit. In pursuance thereof, the parties have adduced evidence by way of affidavits and also produced numerous documents including filing of written arguments by them.
6.           None put in appearance on behalf of the complainant on the date when this complaint was fixed for arguments. Accordingly, we have heard Counsel for the opposite party and have also gone through the entire record of the case, including the rejoinder as well as written arguments filed by parties, very carefully.
7.           First of all, coming to the objection raised with regard to jurisdiction of this Commission with regard to settlement of this case through an Arbitrator, in the face of provisions contained in the allotment  letter/agreement, it may be stated here that this issue has already been dealt with by the larger Bench of the Hon’ble National Commission in a case titled as Aftab Singh Vs. Emaar MGF Land Limited & Anr., Consumer Case No.701 of 2015, wherein, vide order dated 13.07.2017, it has been held that an Arbitration Clause in the Agreements between the complainant and the Builder cannot circumscribe the jurisdiction of a Consumer Fora notwithstanding the amendments made to Section 8 of the Arbitration Act. Feeling aggrieved against the said findings, the builder filed Civil Appeal bearing No.23512-23513 of 2017 before the Hon’ble Supreme Court of India, which was dismissed vide order dated 13.02.2018. Even the Review Petition (C) Nos. 2629-2630 of 2018 filed by the builder in Civil Appeal Nos.23512-23513 of 2017 against order dated 13.02.2018, was dismissed by the Hon’ble Supreme Court of India, vide order dated 10.12.2018. As such, objection raised by opposite party, in this regard, stands rejected.
8.           Now we will deal with the objection taken by the opposite party regarding pecuniary jurisdiction, it may be stated here that this complaint has been filed under the Consumer Protection Act, 1986, under which, for determining pecuniary jurisdiction, this Commission is required to take into consideration the value of the goods and compensation claimed if any. In the present case, if total value of the plot purchased by the complainant  and compensation claimed are clubbed together, the same exceeds Rs.20 lacs and fell below Rs.1 crore. Thus, this Commission has got pecuniary Jurisdiction to entertain and decide this complaint filed under CPA 1986. Objection taken in this regard stands rejected.
9.           Now coming to the objection raised with regard to territorial jurisdiction, it may be stated here that it is settled law that even an infinitesimal fraction of a cause of action will be part of the cause of action and confer jurisdiction on the Court/Tribunal/Fora within the territorial limits of which that occurs. In the instant case, record reveals that following documents have been issued by the opposite party in favour of the complainant, from its office located at SCO No.143-144, First Floor, Sector 8C, Madhya Marg, Chandigarh, meaning thereby that the Company was actually and voluntarily residing and carrying on business from its Office at Chandigarh and personally works for gain thereat:-
   1. Payment receipt dated 10.12.2010, Annexure C-1
   2. Letter of invitation dated 25.05.2011, Annexure C-2.
   3. Letter dated 19.11.2011, Annexure C-3
   4. Provisional allotment letter dated 12.12.2011, Annexure C-4
   5. and Payment receipt dated 06.01.2012, Annexure C-4A

 

Thus, it is held that this Commission at Chandigarh has got territorial jurisdiction to entertain and decide this complaint.

                    Furthermore, the mere fact that in condition no.44 (c) of the allotment letter it was mentioned that courts at Punjab and Delhi shall have jurisdiction in connection with the disputes, if any, alone cannot by itself over-ride the statutory right of the complainant, conferred by the provisions of the CPA 1986 and failure to adopt the same, will defeat the purpose and object of the Act, 1986. Our this view is supported by the observations made by the Hon’ble National Commission in the case of Neha Singhal Vs. Unitech Limited and Abhishek Singhal vs. Unitech Limited, II (2011) CPJ 88 (NC), relevant part whereof is reproduced hereunder:-

" 3. ….In a similar case (FA No. 425 of 2010 Munish Sahgal vs DLF Home Developers Limited), the State Commission had taken the same view. The above-mentioned appeal was allowed by this Commission, vide order dated 9th February 2011, based on the decision dated 11th April 2002 of a 3 Member Bench of this Commission in FA No. 142 of 2001 (Smt Shanti vs M/s. Ansal Housing and Construction Ltd.) The only point of some relevance in this case is that the housing property in question is located in NOIDA, Gautam Buddha Nagar, Uttar Pradesh. However, that fact alone cannot suffice to oust the territorial jurisdiction of the (Delhi) State Commission to adjudicate upon the complaint, in view of the specific provisions of section 11 (2) (b) of the Consumer Protection Act, 1986 (the Act). To emphasise, the clause relating to jurisdiction of courts in the agreement between the parties cannot by itself over-ride the statutory right of the appellant/ complainant conferred by the above-mentioned provision of the Act that would defeat the purpose and object of the Act. This view is also in accord with the provisions of section 28 of the Indian Contract Act, 1872 (as amended with effect from 8th January 1997).

                    Further, in Ethiopian Airlines Vs Ganesh Narain Saboo, IV (2011) CPJ 43 (SC)=VII (2011) SLT 371,  the principle  of law laid down was  that the restriction of jurisdiction to a particular Court need not be given any importance in the facts and circumstances of the case.  

                    In  Cosmos Infra Engineering  India  Ltd. Vs Sameer Saksena & another I (2013) CPJ31 (NC) and  Radiant Infosystem Pvt. Ltd. & Others Vs D. Adhilakshmi & Anr. I (2013) CPJ 169 (NC) the  agreements were executed, between the parties, incorporating therein, a condition, excluding the jurisdiction of any other Court/Forum,  in case of dispute, arising under the same, and limiting the jurisdiction of the Courts/Forums at Delhi and Hyderabad.  The Hon’ble National Commission in the aforesaid cases held that such a condition incorporated in the agreements, executed between the parties, excluding the jurisdiction of a particular Court/Forum and limiting the jurisdiction of a particular Court/Forum, could not be given any importance and the complaint could be filed, at a place, where a part of cause of action arose, according to Section 11/17 of the Act. As such, objection taken with regard to territorial jurisdiction of this Commission, under the territory of which, numerous part of cause of action accrued to the complainant, stands rejected.

10.           As far as objection taken to the effect that the complainant did not fall within the definition of ‘consumer’, it may be stated here that the objection raised is not supported by any documentary evidence and as such the onus shifts to the opposite party to establish that the complainant has purchased the plot in question to indulge in ‘purchase and sale of plots/units’ as was held by the Hon’ble National  Commission in Kavit Ahuja vs. Shipra Estates I (2016) CPJ 31 but since it failed to discharge its onus, hence we hold that the complainant is a consumer as defined under the Act. In this view of the matter, objection taken in this regard stands rejected. 
11.           There is no dispute with regard to fact that, in the first instance, plot bearing no.921, measuring 321 square yards was purchased by the complainant in the project of the opposite party in Phase-2, for which she had paid Rs.29,77,724/- against total sale consideration of Rs.31,72,345.98ps. for the period from 10.12.2010 to 06.01.2012. It is also an admitted fact that possession of plot no.921 was not delivered by 06.02.2014 i.e. within a total period of 24 months (18 months plus 6 months) as envisaged under condition no.24 (a) of the allotment letter/agreement dated 07.02.2012, Annexure C-5 or even thereafter. It is also an admitted fact that thereafter, it was for the first time vide letter dated 25.01.2018, Annexure C-6 that instead of offering possession of plot no.921, the complainant was offered relocation to another plot on account of change in the allotment plan and ultimately after so many offers given for relocation, she was handed over possession of plot no. OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh on 29.03.2019.
12.           The complainant in her complaint has specifically averred that it was only under compelling circumstances that she took over possession of plot no. OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh, as despite making request for refund of the amount paid, the opposite party refused to do so. It has also been averred by her that still various amenities like club etc. have not been provided in Phase-3 where the said relocated plot no. OCE/II/187O is located. It has been further stated that even the PLC have been arbitrarily deducted by the opposite party, out of the deposited amount, yet, no such choice for preferentially located plot was ever given by her.

                    On the other hand, Counsel for the opposite party  stated that since the complainant was eager for possession of the plot as such she was given various offers for relocation and was ultimately relocated to plot no. OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh and she is in possession thereof. However, he failed to convince this Commission, as to why, possession of plot no.921, against which the company had already received more than 95% of the consideration, was not delivered to her. To wriggle out of the situation, he stated that since the allotment made in respect of plot no.921 was provisional, as such, the complainant was relocated on account of change in the allotment plans.

13.           It may be stated here that perusal of record of this case, reveals that deficiency in providing service and adoption of unfair trade practice on the part of the opposite party is writ large. It is evident that on receipt of booking amount of Rs.5.50 lacs vide receipt dated 10.12.2010, the complainant was invited for allotment of plot measuring 300 square yards. Thereafter, vide provisional allotment letter dated 12.12.2011, Annexure C-4, she was allotted plot no.921 measuring 321 square yards.  Thereafter, another amount was received by the opposite party towards price of plot no.921 and by 06.01.2012 an amount of Rs.29,77,724/- against total sale consideration of Rs.31,72,345.98ps. stood received from her by the opposite party. Allotment letter/agreement dated 07.02.2012, Annexure C-5 was also executed between the parties, in respect of plot no.921 and vide clause 24(a) thereof, commitment was made to deliver possession within a period of 18 months or latest by the extended period of 6 months i.e. total 24 months which comes to 06.02.2014. At this stage, it is very pertinent to mention here that possession of plot no.921 was neither offered by the committed date nor thereafter, for which no reasons have been given by the opposite party. During pendency of this complaint, sensing some malafide intentions on the part of the opposite  party in that regard, this Commission vide order dated 24.01.2020 directed it to place on record following documents, to apprise as to whether, plot no.921 existed at the project site or not and as to whether, the opposite party was competent to sell the same in the year 2010 or not:-

1. Registration Certificate of the project with the competent authority.
2. Copy of requisite Licence issued by the Competent Authority under Punjab Apartment and Property Regulation Act 1995.
3. Change of Land Use (CLU) pertaining to the project in question.
4. Letter of Intent (LOI).
5. Copy of approved site plan of the project.
6. Completion Certificate of the project.
7. Latest photographs of the site/unit in dispute.
8. Current list of Managing Director/Director(s) of the Company.
9. Detail of Bank Accounts of the Company.
10. List of properties both moveable and immoveable of the company and its Managing Director/Director(s) which can be attached in execution of the decree. 

It is significant to mention here that despite the fact that number of opportunities were available with the opposite party to place on record the said documents, but it  did not do so, for the reasons best known to it. Not only as above, even in the written reply filed by the opposite party, not even a single reason has been given as to why possession of the plot no.921 was not delivered to the complainant. At the time of arguments also, Counsel for the opposite party failed to give any answer to it. It was only stated that since the allotment of plot no.921 was provisional, as such, the opposite party was right in relocating the complainant to another plot on account of change in allotment plans. We do not agree with the submissions made. It may be stated here that once the opposite party had executed agreement in respect of plot no.921 and had received more than 95% of the total sale consideration towards the same and retained it for a long period till January 2018, as such, now it is stopped from taking such a stand of change in allotment plan. Not even a single evidence in the shape of changed layout plan showing any revision/change therein, in the year 2018, has been placed on record by the opposite party. Even otherwise, it is settled law that before selling the units/plots in a project, the builder/developer is liable to get the final layout/zoning plans approved from the competent authorities and in case it fails to do so, any loss arising thereout has to be borne out by it and not the buyers/allottees. In our considered opinion, the opposite party should not even have accepted the booking without final sanction of the layout/allotment plans.  If the opposite party chose to accept booking on the basis of provisional sanction of the layout/allotment plans by the competent authorities, it is to blame to only itself.  The complainant, who had nothing to do with the sanction of the layout/allotment plan, cannot be penalized, by postponing the possession or registration of the plot.  Our this view is supported by the observations made by the Hon’ble National Commission in M/s. Narne Constructions Pvt. Ltd. Vs. Dr. Devendra Sharma & 4 Ors., Revision Petition No. 4620 of 2013, decided on 17 Dec 2015. Relevant part of the said order reads as under:-

 

“…..As far as final sanction of layout by HUDA is concerned, in my view, the petitioner cannot penalize the complainants/respondents for the delay in the aforesaid sanction since delay cannot be attributed to any act or omission on the part of the complainants/respondents.  In fact, in my opinion, the petitioner should not even have accepted the booking without final sanction of the layout by HUDA.  If the petitioner chose to accept booking on the basis of provisional sanction of the layout by HUDA, it is to blame to only itself for the delay, if any, on the part of the HUDA in issuing the final sanction of the layout.  The purchaser of the plot, who had nothing to do with the sanction of the layout by HUDA cannot be penalized, by postponing the possession or registration of the plot and therefore any escalation in the registration charges on account of delay in final sanction of layout by HUDA must necessarily be borne by the builder and not by the allottee of the plot…..”

 

It has thus been proved that money has been collected from the complainant  in respect of plot no.921 starting from 2010 itself without obtaining statutory approvals and also the said plot did not exist in the project in question. Collecting money from the perspective buyers and selling the project, without obtaining the required permissions/approvals and without getting the final layout plans/zoning plans approved is an unfair trade practice on the part of the project proponent. It was also so said by the Hon’ble National Commission, in a case titled as M/s Ittina Properties Pvt. Ltd. & 3 Ors. Vs. Vidya Raghupathi & Anr., First Appeal No. 1787 of 2016, decided on 31 May 2018. Relevant part of the said order reads as under:-

“…………….This Commission in Brig. (Retd.) Kamal Sood Vs. M/s. DLF Universal Ltd., (2007) SCC Online NCDRC 28, has observed that it is unfair trade practice on the part of the Builder to collect money from the perspective buyers without obtaining the required permission and that it is duty of the Builder to first obtain the requisite permissions and sanctions and only thereafter collect the consideration money from the purchasers.

It is an admitted fact that the sale deeds were executed in the year 2006 and by 2009 the completion certificate was not issued. The Occupancy Certificate was issued only on 25.09.2017 during the pendency of these Appeals before this Commission. Allotting Plots or Apartments before procuring the relevant sanctions and approvals is per se deficiency…………”

 

14.           At the time of arguments also, Counsel for the opposite party failed to apprise this Commission, as to why the opposite party was in a hurry to sell the project in the absence of statutory approvals or final approvals of layout/allotment plans aforesaid and also why the company failed to deliver possession of plot no.921 by the committed date or even thereafter. However, salt was added to the miseries of the complainant, when she was charged PLC for plot no. OCE/II/187O, possession whereof was delivered against her wish as she was interested for a plot in phase 2 and not phase 3, which is admittedly around 2 kms  away and that too other basic amenities such as club house etc. are still not made available there. It is therefore held that the opposite party is deficient in providing service and adopted unfair trade practice on this count. The complainant is entitled to get refund of the amount of PLC deducted by the opposite party while making refund of excess amount towards decrease in area of relocated plot no.OCE/II/1870.
15.           At the same time, it is also held that the objection taken by the opposite party to the effect that time was not the essence of contract is devoid of merit, in the face of its candid commitment made vide clause 24(a) of the letter/agreement dated 07.02.2012, Annexure C-5, whereby commitment was made to deliver possession of the plot within a period of 18 months or latest by the extended period of 6 months i.e. total 24 months which comes to 06.02.2014. It is well settled law that date of delivery of possession has to be reckoned from the conditions agreed to between the parties, by way of allotment letter/agreement only. It is therefore held that in the face of condition of 24 (a) of the allotment letter/agreement, time was unequivocally made the essence of contract. Objection taken by the opposite party in this regard stands rejected.
16.           Furthermore, it is a simple case of deficiency in providing service and adoption of unfair trade practice on the part of the opposite party as it failed to deliver possession of plot no.931 by the committed date, against which it has received more than 95% of the sale consideration, as the same was not even in existence at the project site and on the other hand, utilized the amount for more than 7 years and thereafter instead of refunding the same with interest,  forced the complainant to take over possession of plot in some other Phase. The entire record speaks about the malafide intentions of the opposite party. Under these circumstances, this Commission is competent to decide this complaint as no complicated questions of fact and law are involved therein. As such, objection taken in this regard, stands rejected.  
17.           Since, admittedly, the complainant has taken over possession of relocated plot no.OCE/II/187O, located in Phase-3, Omaxe Cassia, New Chandigarh on 29.03.2019, as such, under these circumstances, the only question which needs to be decided is, with regard to the quantum of compensation to be awarded to her. It may be stated here that plot was booked by the complainant as far as back in 2010. Had possession of the plot been delivered to the complainant by the stipulated date i.e. 06.02.2014, she would have started construction thereon and started living therein. However, on account of non delivery of possession till 2019, despite the fact that the same should have been delivered in 2014, the complainant has been caused double loss i.e. first the entire amount deposited with the opposite party by 2012, could not be used by her and on the other hand, utilized by the opposite party for its own use and secondly now she will have to bear escalation cost in building material also, while constructing house on plot no. OCE/II/187O. In our considered opinion if compensation by way of interest @9% p.a. on the deposited amount is granted to the complainant for the period of delay in handing over possession of the plot to her, that will meet the ends of justice.    
18.           As far as objection taken with regard to misjoinder of necessary party is concerned, it may be stated here that the opposite party was given opportunity during pendency of this complaint, to place on record names of the Managing Director/Directors of the company alongwith other necessary documents, which it failed to do so. Had there been no Managing Director in the company, they could have furnished an affidavit of responsible Officer of the company to that effect but that was also not done. Under these circumstances, bald objection taken in this regard has no value in the eyes of law and is accordingly rejected.  
19.           For the reasons recorded above, this complaint is partly accepted with costs and  the opposite party is directed:-
    1. To pay compensation by way of interest @9% p.a. to the complainant, on the entire amount deposited by her starting from 06.02.2014 (due date of possession) till 29.03.2019 (the date when possession was delivered), within a period of 30 days from the date of receipt of a certified copy of this order failing which thereafter the entire accumulated amount, as ordered to be paid, shall entail penal interest @12% p.a. from the date of default till realization.
    2. To refund the amount of PLC within a period of 30 days from the date of receipt of a certified copy of this order failing which the same shall carry interest @9% p.a. from the date of filing this complaint till realization.
    3. To pay compensation for causing mental agony and physical harassment; deficiency in providing service and adoption of unfair trade practice and also cost of litigation, in lumpsum, to the tune of Rs.50,000/- to the complainant within a period of 30 days from the date of receipt of a certified copy of this order, failing which, the said amount of Rs.50,000/-, shall carry interest @9% p.a. from the date of passing of this order, till realization.
    4. To complete the construction of the club house in Phase-3, Omaxe Cassia/other basic amenities and obtain completion certificate in respect of the project in question from the competent authorities. However, it is made clear that the opposite party shall not charge any maintenance charges etc. from the complainant till the time the said club house is constructed for use of the complainant and other similar located allottees and completion certificate in respect of the project in question is obtained from the competent authorities.  

 

20.           Certified Copies of this order be sent to the parties, free of charge.
21.           The file be consigned to Record Room, after completion.

 

Pronounced

19.04.2021

 

Sd/-

[JUSTICE RAJ SHEKHAR ATTRI]

PRESIDENT

 

 

Sd/-

(PADMA PANDEY)

         MEMBER

 

 

Sd/-

(RAJESH K. ARYA)

MEMBER

 

 

 

Rg.