ORDER

SRI.H.R. SRINIVAS.  PRESIDENT

1.     This is the Complaint filed by the Complainant against the Opposite Party (herein referred to as OP) under section 35 of the Consumer Protection Act, 2019 for the deficiency in service in repudiating the insurance claim in respect of the damages cause to his BMW  car 5 series bearing No. KA 51 MG 5555 and direct OP to pay Rs.63,00,000/- towards repair of car and Rs.2,50,000/- parking charges paid by him to the BMW service center along with interest 24% per annum on the said amount and further a sum of Rs.20,00,000/- as damages and compensation for causing loss of enjoying the benefit of the car negligence on the part of the OP and causing monetary loss mental piece and causing mental and physical strain and for such other reliefs as the Hon’ble District Commission deems fit.

2.     The brief facts of the complaint are that;  the complainant  is the owner of BMW car 5 series 520D registered in his name bearing No.KA-51 MG-5555 manufactured in the year 2013 the same was insured with OP by paying Rs.1,23,365/- as premium.  The IDV value of the vehicle is mentioned Rs.27,04,600/-. The Auto Secure Private Car Package Policy in respect of the said car which was inforce from 13.03.2019 to 12.03.2020.

3.     It is further contended that he had been to Chithradurga on 05.01.2020 in connection with business and left Challekere to Chithradura and Chithradurga to Bangalore at about 9.30 pm on 05.01.2020 the complainant was driving his car by following all the rules and regulations.  When he was reaching Bellaghatta Village around 9.30. pm all of a sudden a dog came across the road and in order to avoid the car hitting the dog he took a right turn and accidentally lost his control and the car dragged to the right went of the road and fell in to the pond. As the car began to sink into the water the electrical component and engine of the car went off and the windows began to open himself and his co-passenger one Nagabhushan Reddy with great difficulty came out of the car before the car sank into the water. 

4.     It is contended that the local police of Turavanur within his jurisdiction the accident took place intimated on 06.01.2020 the same was also intimated to the insurance company, the police held a mahazar of the spot of the accident and case was registered by the police by obtaining the permission from OP the said car was pulled out from the pond and was towed to Navnith Motors the repairing center of BMW car by paying Rs.1,500/- per day as parking charges by the help of Vishnu Towing Services.

5.     It is contended that the agent of OP contacted the police of Turavanur by obtaining all the details and completed the formalities in respect of the claim. The staff member of the OP and IRDA surveyor also made inspection of the vehicle at the place where the car was parked and also collected documents and intimated its staff to prepare the estimate. There was a second meeting fixed on 25.01.2020 and the surveyor requested for diagnostic report to his surprise and shock the BMW service requested complainant to pay Rs.4,00,000/- for coding to conduct diagnosis of the vehicle. The car was completely insured for cash less repair in case of accident and therefore he requested to OP to pay the amount and to release the said amount but the said request was turn down by OP and hence he had paid Rs.4,00,000/- to conduct diagnose report under protest and requested for approval by the insurance company and requested to release advance amount. There was several correspondences between the OP and after OP assuring that the case of the complainant would be consider and directed the complainant to pay a sum Rs.2,50,000/- and pay by the complainant. Though the OP was not negligent there were short of service.

6.     On 03.03.2020 the BMW service scheme diagnose and submitted report and the diagnose was conducted in the presence of OP and submitted a report with fresh estimation for Rs.63,00,000/-. In view of the surveyors report, OP found that the claim to be incorrect and due to misrepresentation of material fact and deliberate attempt in accident to take undue advantage of the insurance which amounts to violation of declaration clause as per the claim form and rejected the claim of the complainant. The same was never informed by the OP and also the stimulation conducted by OP by engaging ICS Assure Services Pvt Ltd., as investigator the said firm did not give any opportunity to the complainant to verify the antecedent of the said company.  After several correspondences made on 10.03.2020 OP rejected his claim stating that, the car was not in line with cause of accident mentioned by the complainant the said act repudiation amounts to deficiency in service.

7.     It is further contended that the police after the complaint has conducted a mahazar and panchanama and stated that the road on which the complainant was travelling was of 18 feet in width and on either side of the road where is 3.0 feet vide kacha road on the either side of the asphalted road on the northern side edge towards southern side at about 40 feet there is a pond filled with water and tyre mark is found on the road from the spot of the accident leading to the pond. Once the car fell into the water it got suspended the water and it turned director due to velocity and these aspect were not considered by the insurance company i.e. OP and only with an intention to only to defraud the complainant with a mala fide intention rejected the claim of the complainant. Hence there is deficiency in service on the part of OP. Due to the deficiency in service complainant was put to loss of Rs.2,00,00,000/- as on the date of the filing of the complaint towards loss of vehicle inconvenience caused for want of vehicle loss of paying diagnose amount parking charges and other expenses and have been deprived off enjoying the facility of the car. He was put to mental agony hardship inconvenience, and mental shock. The approach of the OP is very casual.  Since the date of purchase of the vehicle the vehicle is insured returned to insurance policy i.e. the insurance company is liable to pay the invoice value in case the damage to the vehicle exceeds 75% of the IDV as per IRDA to overcome contractual obligation OP has found novel way denying the claim of the complainant by making false and baseless allegation. Since the act of OP amounts to deficiency in service in not honouring the claim though the policy was in effect at the time accident and accident has taken place during the travel in a normal course there is deficiency in service on the part of OP in denying the insurance claim and hence prayed the commission to allow the complaint and direct the OP to pay the amount.

8.     Upon issuance of notice OP appeared before the commission and filed version contending that the averments made in the complaint are totally false, frivolous, vexatious and liable to be dismissed by imposing exemplary and punitive costs for filing of the complaint with mala-fide intention in order to get himself enrich by making false and frivolous claim. It has denied all the allegations made against it in each and every para of the complaint.

9.     It is further contended that by the OP that, the complainant obtained Private Car Insurance Policy from it for the period commencing from 13.03.2019 to 12.03.2020. It has also admitted the intimation received on 05.01.2020 regarding the accident that has taken place on 06.01.2020. It is further contended that upon the intimation received IRDA licensed, independent surveyor one  K.V.Pruthvish was appointed and deputed to conduct the survey and assess the loss. Based on the circumstances of the alleged accident they also deputed one M/s Daksha Consultation and Solution  for investigations in to the cause and nature of the accident. Since the entire accident was doubtful further got conducted stimulated accident report and the report submitted ICS Assure Services Pvt. Ltd a Mumbai based expert firm to verify and ascertain the cause and nature of loss with respect to the accident. As per the observation made by the surveyor and investigation experts, it is contended that the alleged accident manipulated in nature and created for undue benefit under the said policy which is taken on the basis written to invoice valuation noting the vehicle  six years old which clearly goes to show that the complainant is in the habit of trying to dispose of the vehicle to gain illegal profit of the same. The estimate given by the repairer before any diagnosis of the vehicle and surveyor requested the said repairer to justification on requirement of smart as per given estimate without prejudice. Meanwhile the complainant was pressing for advance payment required to conduct the diagnosis to arrive the extent of estimated loss and the same was suitable replied the vehicle was not dismantled at that time and the surveyor issued an independent survey report.

10.   It is further contended that earlier to the accident the complainant had made a claim in respect of the vehicle as it was stolen and later the same was withdrawn, which clearly goes to show the intention of the complainant to make unlawful gain. It is further contended that the complainant informed his office in respect of the theft of the vehicle that it was not stolen or loss whereas it was parked at his office premises by mistake and hence requested to cancel the claim and to do the needful with OP which clearly goes to show its intension to make the money. Further it is contended that as per the report submitted by M/s. ICS Assurance Services Pvt. Ltd who carried out accident reconstruction report that the accident and the claim of the complainant is false and baseless.  It is further contended that the complainant claimed that he was driving the vehicle at the speed of 80 kms and at that speed the complainant taken 90 degree turn to avoid hitting dog and the car ended up in the lake is highly impossible to believe as an expert as clearly mentioned that  at the speed the IV could not take a quick turn and would have travelled some further distance as shown in the said report.  Further quick turn at a higher speed cause rollover of the vehicle due to centrifugal force and during role over, there will be uniform scratch marks and dents present on the exterior of the vehicle, whereas there is no such damage to the vehicle. Further it is contended that the report has observed that the vehicle if could have reached the final seen position in the middle of the pond at a speed of 80 km which would have dashed to temple foundation with the corner, resulting with the impact damages to the vehicle as per 12 and 13, whereas no such damages was caused to the vehicle. The said report has been produced to the commission for perusal.  Further the vehicle would have been to final seen position inside the lake at a low speed by following the park indicated as shown from all these clearly make the intention of the complainant to make illegally profit by slowing taking the vehicle and immersed the same into the pond to make illegal profit.  This constitute violation declaration clause as per the claim form and hence the same was repudiated and communicated to the complainant.  The misrepresentation of the material facts and the cause of nature of accident the declaration and as such there is no deficiency of service of allegations. Hence denying all the other allegations prayed the commission to dismiss the complaint.

 11.  In order to prove the case, both the parties filed their affidavit evidence and produced documents. Arguments Heard. The following points arise for our consideration:-

1) Whether the complainant has proved deficiency in service on the part of the Opposite Party?

2) Whether the complainant is entitled to the relief prayed for in the complaint?

12.   Our answers to the above points are:-

POINT NO.1 :   In the Affirmative.

POINT NO.2 :   Partly in the Affirmative.

                        For the following.

REASONS

POINT No.1:-

13.   It is not in dispute that the complainant is the owner of BMW Car-5 series 520D bearing Registration No.KA-51 MG-5555 of 2013 model. It is also not in dispute that, as per the records produced by  either parties that the said vehicle was insured with the OP on 13.03.2019 till the mid night of 12.03.2020.  The said policy is Auto Secure Private Car Package policy. ID value of the vehicle is Rs.27,04,600/-.  On perusing Ex.P1 the policy it is mentioned that the total own damage premium has been collected at Rs.16,475.27 after deducting Rs.4,118.82 being the no-claim bonus. It shall be noted here that additional premium of Rs.79,681.48 has been received by the insurance company in respect “return on invoice”.  The total premium payable by the complainant in respect of own damage and the liability is Rs.1,23,365/-.  It is not in dispute that the said vehicle on the date of accident had insurance cover.

14.     It is to be noted here that the accident has taken place on at 9.30 pm on the night of 05.01.2020 when the complainant was driving the car from Challakere to Bangalore Via Chitradurga and when the vehicle was negotiating near Bellaghatta Village, all of a sudden a dog came across the road and in order to avoid hitting the dog, as natural reflection and instinct he turned to right and lost the control and vehicle dragged to the right and went into the pond which was with water and the car began sink in the pond the electrical components and  engine of the car went off, the window began to open and complainant and his friend and co-passenger Nagabhushanreddy came out of the car, whereas  the car sank in to the water. The same was reported the jurisdictional police Turavanur police station who registered a complaint and issued an acknowledgement and the same was informed to OP also and the police do a mahazar. The said vehicle was towed to Bangalore with the service of Sri Vishnu Towing Service Chintraduraga and car was parked Navnith motors Bangalore and the said vehicle was inspected by the loss assessor and surveyor appointed by the OP. Further the Mahazar was also drawn by the police at the accident spot and also the said vehicle and the accident spot was inspected by the surveyor/inspector of OP. The claim was made by the complainant for Rs.63,00,000/- being the repair charges and Rs.2,50,000/- being the parking charges, which was refuted by the OP after coming to the conclusion with the help of the surveyor opinion and the Motor Accident Reconstruction Report stating that the said accident is a planted accident, created accident which cannot happen in the manner the complainant has explained and complained. 

15.   As per the mahazar drawn by the police the vehicle was in the pond and the same was taken out and a mahazar was done.  Upon the complaint lodged by the complainant, in the mahazar drawn by the police it is mentioned that

“¤Ãj£À UÀÄArAiÀÄ ºÉÃj ¥ÀPÀÌzÀ°è ¤AwzÀÝ PÁgÀ£ÀÄß ¦gÁð¢ JªÀiï.±ÀgÀvïPÀĪÀiÁgïgÀªÀgÀÄ vÉÆÃj¹ EzÉà £À£Àß ¨Á§ÄÛ ¤Ãj£À UÀÄArUÉ ©¢ÝzÀÝ PÁgÉAzÀÄ w½¹zÀ ªÉÄÃgÉUÉ ¥ÀAZÀgÀ ¸ÀªÀÄPÀëªÀÄ CdªÀiÁ»¹£ÉÆÃr¯ÁV CzÀÄ ©.JA.qÀ§Æèöå 520r PÁgÁVzÀÄÝ, ©½§tÚ¢AzÀ PÀÆrgÀÄvÉÛ, PÁj£À »AzÉ PÉ.J. -51-JA.f.-5555 JAzÀÄ £ÀA§gï ¥ÉèÃmï EgÀÄvÉÛ. ªÀÄÄA¢£À £ÀA§gï ¥ÉèÃmï ©zÀÄÝ ºÉÆÃVgÀÄvÀÛzÉ. F C¥ÀWÁvÀ¢AzÀ ¸ÀzÀj PÁj£À ¥sÀæAmï ºÉqï ¯ÉÊmï ¨ÁåPï rQÌ, qÉÆÃgïUÀ¼ÀÄ, EAf£ï dRAUÉÆAqÀÄ D¬Ä¯ï ¸ÉÆÃjPÉAiÀiÁUÀÄwÛgÀĪÀÅzÀÄ PÀAqÀħA¢gÀÄvÉÛ. £Á®ÄÌ mÉÊgïUÀ¼ÀÄ eÁªÀiï DVgÀÄvÀÛzÉ.”

16.   The photographs produced shows that the car was under the water and another photographs is that the same has been removed and parked on by the side of the pond with the bonnet opened. There is a stone marking constructed by side of the road, and further policeman and three other persons were standing by the side of the pond wherein one can observe the side marks. From this, one can come to the conclusion that there is an accident in respect of the said vehicle. The water was not much in the pool as could be seen from the photos produced by the complainant. It is also to be noted in the mahazar that the distance from the right edge of the tar road to the water tank mentioned as Hinganakatte Nirinagundi is about 40 feet which is on the right side of the road and according to the complaint when he tried to avoid hitting the dog he took a right turn and lost control of it and car went to the pond.

17.   On the other hand, the accident reconstruction report has been carried out by the ICS Assure appointed by the OP. It is not known whether any notice has been issued to the complainant regarding carrying out of the reconstruction report or, performing the experiment in respect to ascertain the fact of the said accident.  It has gone through the details of the vehicle description, the reason of the accident given by the complainant with the police, the vehicle length, breath in millimeter and the object of conducting reconstruction of the accident to ascertain the fact of the said accident based on the scientific analysis of the vehicle damage and accident site scenario analysis. As per the scientific analysis, the insured vehicle mentioned with the accident at Bellaghatta, the photos has been taken.  It is also mentioned that the road is single carriage way and also the images or photos when the vehicle was lying in the pool.  The lower host of the car was under the water and image No.4 of the reconstruction report clearly shows that the doors have been opened and also dickey door is also be opened. That no impact or damage observed on the frontal portion of the vehicle. 

18.   According to the report, which had been made a graphical representation of the scenario, whereas the possibility to travel to the side with a curve and the vehicle would be pushed towards outside when the vehicle was at a speed of 80 kms.  It is mentioned that at the given speed, small radius turns produce more force than large radius turns. Large amount of centrifugal force large amount of centrifugal force requires equally large amount of counteracting force from the tyres if the vehicle is to remain on the road. It is also mentioned that considering the road conditions and surroundings of the spot, at the speed of 80 Kms could not take a quick turn and would have traveled some further distance which is showed in image No.10 of the report. Another possibility mentioned therein is that if the sudden turn is taken by considering that the vehicle has reached at a speed of 80 kms, than they would have dashed temple foundaction corner resulting damage to the vehicle. Since there no damage is caused to the right side of the vehicle, or to the vehicle externally and the vehicle final seen was not in a position with a insured mentioned senior of the final seen position at a slow speed by following path indicated in the red line image No.11. It has concluded that since from the scientific experiment, the vehicle seen position is not in lying with the insured mentioned scenario, and the final seen position of the vehicle has been taken to final slow speed the following path indicated by the red line in the image 11 the insured has misrepresented the fact of the said accident.

19.   It is on the guise of the said documents and opinion and reconstruction report of the accident, OP has repudiated the claim of the complainant and further mentioned the cause of the accident mentioned in the claim form is found to be incorrect and led to misrepresentation of material fact and complainant has deliberately attempted in planting with accident to take undue advantage of the insurance policy which constitute the violation of declaration clause as per the claim form and hence repudiated the claim of the complainant which has given rise the cause of action to raise this complaint.

20.   It is to be seen here that, the surveyor one Pruthivish has visited the spot immediately after the accident.  It is not known whether a notice was given to the complainant before conducting a survey.  Further it was noted that and verified the chassis number and all the documents. The Reek value approximately mentioned as Rs.6,00,000/-.  The assessment sheet in respect of repairing the vehicle has been produced. The repair costs about Rs.50,40,290/- and the assessment has been made on the basis of estimation submitted by the repairer and observation of the damage caused outwardly as far as without dismantling the vehicle for repair. There might be internal and in accessible parts which can only be ascertain after dismantling.

21.   It is to be noted here that the complainant has not for the first time got the vehicle insured with OP. It is a continued or renewed insurance policy wherein complainant has claimed no claim benefit and OP has provided no claim benefit of Rs.4,118/-.  Only on the assessment of the reconstruction of the accident, OP has repudiated the claim made by the complainant. On the other hand, it is to be observed here that the accident or accidents which happens in the spur of the movement and one cannot say how one cannot denying the same and have a hypothetical argument that this could have been the possibility or that could have been the possibility that the accident may due to other reason other than the one given an d stated and it could have happened in that particular car and not as standing the complainant to deny the accident. It cannot be ruled out the possibility of the complainant turning to avoid the accident in order to save the dog there by the vehicle went the right side leading the vehicle to the pond.  The final seen position mentioned in image No.10 amplifies the say of the complainant that the vehicle went to the pool after right turn and started drifting. There is every likelihood that the vehicle when hitting to the water to drift to either side due to the current of the water or to the wind. Thereby one cannot presume that the vehicle will be in same line as entered into the water.

22.   Though the motor accident reconstruction report says that if it is short turn, the vehicle ought to have hit the road side construction of the temple.  It can be accepted  if the vehicle had come so close to the said construction of the wall.  If that being the case the vehicle could not have gone to the pond and drifted into the pond, whereas due to the force which it hit the wall, it should have capsized to its left. That possibility of the report that it should have hit the wall cannot be accepted. 

23.   The report of reconstruction are all hypothetical and probabilities which may or may not happen at the time of accident. Further the said person who has reconstructed accident & submitted the report has not been examined before the forum and no opportunity was given to the complainant to put him to the cross examination to know the truth veracity and exactness of the report. Hence we are of the opinion that the said accident is not a planted one to gain the insurance amount and complainant has not violated the declaration clause as per the claim form. Hence the repudiation in our view is amounts to deficiency in service and hence we answer POINT NO.1 IN THE AFFIRMATIVE.

POINT NO.2

24.   This leads us to access as to what exactly the complainant is entitle too. As pointed earlier, the vehicle was insured with OP 1 for its “return of invoice policy”. “The return of invoice policy” means the cost at which the complainant has acquired/purchased the vehicle. In this case the vehicle was purchased in the year 2014 and the cost as per the Invoice No.NMINV1300778is Rs.36,57,777.78  excluding the other charges like CST, Road Tax, Insurance and other related expenses.

25.   In the policy produced and marked regarding the wording, it is mentioned that IDV shall treated as a market value throughout without any further depreciation for the purpose of total loss and constructive total loss claim. The insured vehicle shall be treated as constructive total loss if the aggregate cost of retrieval /repair of the vehicle subject to terms and conditions of the policy exceeds 75% of IDV of the vehicle.  In this case as per the report of Mr.Pruthrivish the surveyor and loss assessor of OP net repair cost is mentioned as Rs.50,40,290/- whereas the approximate reck value mentioned as Rs.6,00,000/-.  The complainant has produced the diagnosis general /repairing operating issued by Navnith motors Bangalore in respect of the vehicle which met with an accident.  The said document is marked as  Ex.P9 wherein as per the said quotation the total cost including the labour, the parts to be replaced, GST, SGST is Rs.63,30,780/-.  When this is taken into consideration the repair charges of the vehicle exceeds the invoice value of the vehicle. Here it is to be noted that the complainant has not produced the purchase invoice in respect of purchased of the vehicle. It is to be noted that the said vehicle has purchased in the year 2013 and naturally it has to undergo depreciation. Inspite of it, in view of the OP receiving Rs.33,537/- being the additional policy amount for “return of invoice”. We are of the opinion that the insurance company is liable to pay the invoice value of the vehicle without there being any deduction in respect of the depreciation.

26.   Since the repair charge of the vehicle claimed is Rs.63,30,780/- which exceeds the cost of the vehicle and also repair charges exceeds more than 75% of the IDV value and in view of the “return to invoice policy” we deem it proper to order the OP to pay the cost of the value of the vehicle purchased by the complainant in 2013-14 vide Tax Invoice dated 12.03.2014 in respect of Booking Order No. NMBA1300663, Invoice No.NMINV1300778, wherein the basic price of Mineral White 520D luxury line cost excluding the CST is Rs.36,57,777.78. Since this is the invoice value of the car purchased by the complainant, the same is entitle for reimbursement of the said amount, he is not entitle for CST/GST, Insurance and Road Tax.  

27.   Further the complainant after receiving the said amount is bound to hand over the vehicle to the OP as the same is considered as constructive total loss. Though the complainant has claimed Rs.2,50,000/- as parking charges he has not produced the receipt for having paid the same to the garage wherein he parked his vehicle. The complainant has also sought damage of Rs.20,00,000/- for the inconvenience caused to him and for mental trauma he has suffered and undergone for all these days. 

28.   The same has not been substantiated with supporting and convincing evidence. He has not produced any document to show that he has paid money to make alternate arrangement for his travelling. Inspite of it, he has to spend money for his travel purpose and travelling for his family members. In view of this, we are of opinion that if a sum of Rs.500/- per day from the date of repudiation i.e. from 10.03.2020 till the payment of the invoice value of the vehicle to the complainant, is to be paid by the OP towards conveyance charges for himself and for his family members in the absence of his vehicle, and also towards parking charges. Further since there is deficiency in service and the repudiation of the insurance policy and the claim, the complainant was made to approach this forum to seek remedy. He has spent time, money and energy and also engaged a person of legal knowledge by paying him profession fee. Hence we direct OP to pay Rs.15,000/- towards the litigation expenses and Rs.25,000/- towards damages for the sufferance of mental agony, physical hardship. Hence we answer POINT NO.2 PARTLY IN THE AFFIRMATIVE and pass the following:-

ORDER

1. The complaint is partly allowed with cost.
2. OPs 1 and 2 are jointly and severally hereby directed to pay Rs.36,57,777.78  being the vehicle value of the vehicle under the constructive total loss as per the invoice dated 12.03.2014 under which he purchase the vehicle along with interest at 12% p.a. on the said amount from the date of repudiation i.e 10.03.2020 till the payment of entire amount. Further OPs are directed to pay Rs.500/- per day to the complainant from 10.03.2020 till the payment of the entire amount as ordered above towards inconvenience caused to the complainant and family members in OPs not paying the repair charges due to which the vehicle was lying in the garage without repair and not available for the complainant for their use and also towards parking charges.
3. Further OPs are directed to pay Rs.25,000/- towards damages for causing mental agony and hardship and  Rs.15,000/- towards litigation expenses.

4. OPs are hereby directed to comply the above order within 30 days from the date of receipt of this order and submit the compliance report to this commission within 15 days thereafter.

5. Send a copy of this order to both parties free of cost.

Note: You are hereby directed to take back the extra copies of the Complaints/version, documents and records filed by you within one month from the date of receipt of this order.

(Dictated to the Stenographer over the computer, typed by him, corrected and then pronounced by us in the Open Forum on this day the 30^th day of JUNE 2021)

MEMBER                                PRESIDENT

ANNEXURES

1. Witness examined on behalf of the Complainant/s by way of affidavit:

Copies of Documents produced on behalf of Complainant/s:

Ex P1: Copy of the RC

Ex P2: Copy of the Adhaar Card

Ex. P3: Insurance policy

Ex P4: Photos of the car

Ex P5: Copy of the FIR along with complaint.

Ex P6: Copy of the statement

Ex P7: Copy of the spot mahazar

Ex P8: Diagnosis made by the service center.

Ex P9: Copy of the Quotation for repair.

Ex P10: Repudiation letter issued by OP.

 2. Witness examined on behalf of the Opposite party/s by way of affidavit:

RW-1: Sri Krishna Sheernali, Chief Manager –Legal Claims of OP.

Copies of Documents produced on behalf of Opposite Party/s

Ex R1: Copy of the policy with terms and conditions of the policy.

Ex R2: Copy of the Surveyor Report.

Ex R3: Copy of the Accident reconstruction report.

Ex R4: Copy of the letter dt:10.03.2020.

Ex R5: Copy of the letter dated 18.03.2020.

MEMBER                                PRESIDENT

*RAK