By Sri. MOHANDASAN.K, PRESIDENT

Complaint in short is as follows: -

1.         The complainant is a Gynecologist, practicing at Vengara and she has got a private clinic at her residence.  While so during October 2018 Mr. Nidhin P.N, the 6^th opposite party in the complaint approached the complainant stating that he is the authorized representative of the first opposite party and that the ultra sound scan machines manufactured / supplied by the first opposite party were very reliable and durable and would last for more than 10 years of heavy use.  The 6^th and 7^th opposite parties had given a demo of the functioning of the  “Affinity 30” model ultra sound scan machine manufactured / supplied by the first opposite party. Believing the representations of the 6^th and 7^th opposite parties, the complainant placed order for the purchase of the ultra sound system [Ultra Sound Scan machine affinity 30, SR No.USN 18 E 0462 on 05/12/2018] from the first opposite party for an offer price of Rs.35,70,600/-. The terms and conditions for supply and installation included the payment of Rs.7,00,000/- as advance along with PO, balance against COD.

2.         The complainant had been of the opinion of having an ultra sound scan machine with price around Rs. 15,00,000/-rupees  only, since she had very moderate use at her home clinic with exclusive obstetrics gynecological investigations.  But the opposite parties six and seven insisted upon the purchase of the “affinity 30” ultra sound scan machine, by impressing upon the complainant the aforesaid machine is durable and long lasting and would not require any replacement in future.  They prevailed upon the complainant by their false representations. The “affinity 30” scan machine had many components which were of use only for cardiological investigations.  Such use was not at all required by the complainant, and these cardiological components are stored in another room without any use. The opposite parties six and seven knew well that they were selling a product which was not at all required by a gynecologist.  The false and misleading representation of the opposite parties six and seven resulted in the purchase of the “affinity 30” ultra scan machine.  As per the conditions in the offer document Ext. B1, the complainant paid Rs.7,00,000/- (Rupees Seven Lakh only) as advance through her banks.  An amount of Rs.5,00,000/- (Rupees five lakh only) was paid to the opposite party as per the bank statement of Vengara Branch of Federal bank through a cheque dated 16/10/2018.  An amount of Rs.2,00,000/- (Rupees two lakh) was paid on 16/10/2018 through Vengara branch of south Indian bank limited.  The 6^th and 7^th  opposite parties themselves arranged  the 8^th opposite party, the official financier of the first opposite party  for arranging loan for the balance amount of Rs.28,70,600/- (Rupees twenty eight lakh seventy thousand  and six hundred only) for purchase of the scanning  machine.  The 6^th and 7^th opposite parties demonstrated  the capabilities  of the demo machine and convinced the complainant  that she would not have to purchase another scan machine in future,  since the scan machine  “Philips Affinity  30 “  was very durable  one and long lasting . The machine was delivered through the 4^th opposite party by the first opposite party.  The opposite parties showed an amount of Rs.26,62,000.04/- (Rupees twenty six lakh sixty two thousand and  four paisa only) as the total value of the product in the tax invoice, the offer price stated in the offer document and the actual amount taken by the opposite parties is Rs.35,70,600/- (Rupees thirty five lakh seventy thousand six hundred only). The opposite parties collected an excess amount of Rs.9,08,600/- (Rupees nine lakh eight thousand six hundred only) form the complainant. The complainant alleges the act as fraudulent one and deficiency of service.  The e-way bill system e-bill also stated the value of goods as Rs.26,62,000.04/-(Rupees twenty six lakh sixty two thousand and four paisa only). 

3.         The opposite parties have committed unfair trade practice of taking excessive price than the price shown in the Ext. P4 invoice bill.  The repayment schedule issued by the 8^th opposite party showed the down payment of margin money Rs.7,00,000/- (Rupees seven lakhs only) by the complainant.  It also showed the loan amount of Rs.28,70,600/- (Rupees twenty-eight lakh seventy thousand six hundred only). Thus a total amount of Rs.35,70,600/-(Rupees thirty five lakh seventy thousand six hundred only) was received by the opposite parties. The complainant alleges the opposite parties have defrauded the complainant of Rs.9,08,600/- (Rupees Nine lakh eight thousand six hundred only).

4.         The complainant already paid Rs.3,72,234/- (Rupees three lakh seventy-two thousand two hundred thirty-four only) as interest for the period from 05/01/2019 to 05/12/2020 for the loan amount of Rs.28,70,600/- (Rupees twenty eight lakh seventy thousand six hundred only) to the 8^th opposite party. The 8^th opposite party is part of the first opposite party.  The amount of Rs.7,00,000/- (Rupees seven lakh only) received by the opposite parties was misappropriated by them.

5.         The opposite parties have stated the serial number of the articles delivered by them to the complainant.  The ultra sound scan machine with serial number USN 18E0462-SW version: 3.0.3. The probe serial numbers: 3D9-3V, B2RL05, V6-2 B2RKVN, C6-2B2TK7M. Thermal printer UP- D 898MD SL number: 7184606.  SWO No.48722253. The invoice No.1030004632 dated 05/12/2018. 

6.         The complainant had a small clinic attached to her house and the use of ultra sound system was very essential for the clinical practice. The quality of the scan images was deplorably low compared to the demo machine shown to the complainant by the opposite party No.6 and 7.  The system was installed on 06/12/25018. On 08/12/2018 both 2D and 3D +TV probe showed cloudy images.  The clarity was poor compared to the demo machine.  The fifth opposite party had provided service for the problem.

7.         The complainant alleges the opposite parties sold the machine to the complainant stating that it was superior in quality and performance. But the complainant, on many occasions was compelled to send the patients for outside for examination, despite spending such a huge amount for the purpose of the scan machine from the opposite parties.   The complainant submit that the Indian medical association had black listed the opposite parties and it was widely published in the media.

8.         On 21/12/2018 the scanning machine as getting hung during case artifact issue. The 5^th opposite party provided service for the problem. Again on 29/12/2018 the machine was hanging during case.  The 5^th opposite party provided service for the problem.  On 02/01/2019 the system was hanging twice during case, the fifth opposite party provided service for that also. Even after attending the problem on 02/01/2019 the system was functioning only after generator power and not on KSEB electricity supply line or UPS.  Color Doppler showed abnormal values as an artifact for which the complainant had to send the patient for MRI, apprehending malignancy, which created unnecessary tension for the complainant as well as the patient.  The printer had also stopped working.  The fifth opposite party had provided service for the problem. On 21/01/2019 the machine was hanging and automatically switched off.  The machine required restarting while doing the examination. The fifth opposite party had provided service for the problem. On 08/05/2019 preventive maintenance was done and that was provided by fifth opposite party.  On 03/10/2019 also preventive maintenance was done through the 5^th opposite party. On 14/05/2020 also there was problem with machine.  The 5^th opposite party provided service and preventive maintenance was provided by 5^th opposite party.  On 16/05/2020 the machine showed in improper and erroneous reading.  Then also 5^th opposite party provided service. Thereafter 30/05/2020 and 13/11/2020 there was improper reading and preventive maintenance for the same was provided by the 5^th opposite party.  On 18/11/2020 the machine was hanging. On 19/11/2020 the machine failed totally.  On 21/11/2020 the problem recurred and the machine stopped functioning.  Though the fifth opposite party provided service for the problem it was not effective.

9.         Now the complainant undergoing the miserable expenses with the machine and the complainant lost faith in the machine.  The machine proved to be beyond any repair.  There was series   of malfunctioning and 15 repairs during the last two years immediately after its purchase.  The complainant alleges the opposite parties supplied a refurbished machine to the complainant and concealing the actual amount received by them from the invoice bill.   

10.      The complainant submits that she cannot examine patient with the defective machine. The complainant alleges unfair trade practice on the part of the opposite parties by supplying defective machine to medical professional.  It is submitted they are dealing human life and health.  The complainant demanded the opposite parties to replace the inherently defective machine with a new advanced machine.  But the opposite parties refuse to make a better replacement.  The complainant being a helpless lady doctor, the opposite parties are attempting to press upon the defective machine upon her.  The complainant alleges there was false and misleading representation by the opposite party as to the price and performance of the product.  The product delivered is mainly of cardiac use, rather than use by a gynecologist.  The complainant alleges the opposite parties illegally gained Rs.9,08,600/- (Rupees nine lakh eight thousand and six hundred only) from the complainant.  The complainant had request for a standby machine till the defective one replaced.  The complainant had waited for more than a week of the standby machine till they bought a standby machine on 24/11/2020.  The clinical practice was suspended for more than a week.

11.      The complainant submits that the installment amount to the 8^th opposite parties was more than 57,924/- (Rupees fifty-seven thousand nine hundred and twenty-four only) per month. The complainant is put too much hardship using the machine purchased by availing loan. Hence the complainant prays for the refund the amount of Rs.35,70,600/- (Rupees thirty-five lakh seventy thousand and six hundred only) collected from the complainant.  The complainant also entitled for the compensation. The machine is at present stand totally failed. The machine is within the warranty period also. Hence the prayer of the complainant is that to direct the opposite parties to refund the amount of Rs.35,70,600/- (Rupees thirty five lakh seventy thousand six hundred only) with interest at the rate of 18% from 05/12/2018 till realization from the opposite parties and their assets jointly and severally.  The complainant also prays for an amount of Rs.10,00,000/- (Rupees Ten lakh only) as compensation and as punitive damage for the loss and injury suffered by the complainant due to the negligence of opposite parties  and also cost of the proceedings.

12.      On admission of the complaint notice was issued to the opposite parties.  Opposite parties 1, 3, 4, 9 entered appearance.  Opposite parties, despite service of notice to 5,6,7,8 not turned up, hence name called and set exparte.  Opposite parties 1,3,4,9 filed version.

13.       The opposite parties 1,3,4,9 filed joint version denying the entire averment and allegations in the complaint.

14.       The opposite parties 1,3,4,9 submitted that they are a limited company focused on manufacturing devices and instruments for healthy living, prevention, diagnosis and treatment of deceases and ailment and home care. Philips India limit is part of the global Philips group, well known on the avails electrical and electronic and health care products across countries.  Philips India limited is a well-known and established company operating in India for over 80 years, engaged in the manufacturing of consumer durables and health care products and enjoys a wide and trusted customer base.  Philips India limited is renowned for its health care equipment and for global leadership and innovations in several technologies inter alia in X-ray, cardiac vascular imaging, ultra sound, magnetic resonance imaging, computed homographic and patient monitoring system.

15.       As a focused leader in healthy technology, they are on a mission to improve people’s life’s each year with their innovative technology solutions across the health continuum. The opposite parties 1,3,4, and 9 is trying to create lasting value for their shake holders by understating the challenges of customers and consumers face to ensure and deliver  with speed,  quality  and integrity.  The company is a leader in diagnostic imaging, image guided therapy, patient monitoring, and health informatics, as well as in consumer health and home care.  

16.      The opposite parties partly admitted averment in para one of the complaints but it is denied that opposite parties 1,3,4,9 insisted the complainant to purchase the “affinity 30” model ultra sound scan machine. The opposite parties admitted that they had given demo of the functioning of the “affinity 30” model ultra sound scan machine.  The opposite parties submitted that the complainant purchased the scanning machine after thoroughly going through the brochures  and the settings of the machine herself and decided to purchase the said machine for Rs.35,70,600/- (Rupees thirty five lakh seventy thousand six hundred only) adding Rs.7,00,000/- (Rupees Seventy thousand only)  for supply and installation .

17.      The opposite parties denied the allegation that they insisted to purchase the said scanning machine after giving false information.  The opposite parties submitted that as per the requirements of the complainant the opposite parties 1,3,4 and 9 recommended the complainant   the said scanning machine will be helpful for her in long run  and thereafter  the complainant personally verified all the peculiarities of the said scanning machine and after being satisfied by the same the complainant purchased the said scanning machine.  The opposite parties denied the allegation that the complainant has been charged excessively for the said scanning machine. It is submitted that the value of the scanning machine was Rs.26,62,000.04/- in in including one year warranty.  It is further submitted that they have not collected excess amount of Rs.9, 08,600/-. The opposite party submitted that the complainant knowingly and cunningly concealed the fact that the excess amount that paid for the purpose of extension of the guaranty period. The opposite party denied the allegation that they misappropriated the amount taken as loan by the complainant from the opposite party No.8. The opposite party submitted that they arranged loan facilities for the ease of business to their consumers and it is totally and individuals’ choice i.e., the consumers choice to avail loan services from the loaning facilities.  The complainant herein entered agreement with the 8^th opposite party and availed the loan facility and not at the instance of opposite parties 1,3,4, and 9.

18.       The opposite party parties admitted that there were some issues regarding the said scanning machine.  But the opposite parties 1, 3, 4 and 9 being a consumer oriented and consumer approachable company 24 *7 was available for the services and always cured the problems of the machine when ever asked by the consumer. The opposite parties submitted that the complaint is facing with the machine the opposite parties offered   

•  offered Diamond Selector (Ds system)
• Offered to take back of the system of the complaint and refund the money after deducting the depreciation value.

19.      The opposite parties submitted that though the offer were made by the opposite pares 1, 3, 4 and 9, the complainant was not ready to settle the matter but filed the present complaint.  The opposite parties denied the allegation that re- furbished machine to the complainant was sold by the opposite parties to the complainant.  The said scanning machine was an entirely new one and not a defective one.  The opposite parties denied the allegation of the complainant and submitted that only after furnishing the relevant information and demonstration and with the total satisfaction of the complainant, the complainant purchased the said scanning machine.  It is submitted that the complainant never demanded the opposite parties for the replacement of the machinery in fact, it is submitted that the opposite parties approached complainant for replacement or for a new one but the complainant denied the offer and perused towards filing the complaint.

20.      Hence the submission of the opposite parties is that the complainant never suffered any financial loss, mental agony or other hardship due to the negligence or deficiency in service of the opposite parties 1,3,4,9.  The scanning machine manufactured and supplied by the  opposite parties 1,3,4 and 9 with the warranty of  4 years for which the opposite party 1,3,4 and 9 charged Rs.9,08,600/- for the product “affinity 30” and so the allegation that the opposite parties charged  excess amount  is not correct. The opposite parties submitted that they took diligent care of the requirement of the consumer i.e the complainant herein whenever it was required. The opposite parties 1, 3,4 and 9 denied the allegation of unfair trade practice and negligence of service and so prayed for the dismissal of the complaint with cost of this opposite parties .

21.       Though the second opposite party filed vakkalth, no version is filed.  Opposite parties 5,6,8 did not appear despite service of notice and so they set exparte .

22.      The complainant filed affidavit and documents.  The documents on the side of complainant marked as Ext. A1 to A 46. The opposite parties 1,3,4,9 though filed version did not file affidavit. Hence the opposite parties 1,3,4, and 9 also set exparte under section 38 (3) ii.

23.      The case of the complainant is that she is being practicing gynecologist, she needed an ultra sound scan machine to use at her private clinic at her residence Vengara. During 2018 October the 6^th opposite party approached the complainant along with 7^th opposite party and had given a demo of the functioning of “affinity 30 “ ultra sound scanning machine manufactured by the first opposite party.  Believing the representation, the 6^th and seventh opposite parties the complainant placed order for the purchase of the ultra sound system (ultra sound scan machine affinity 30, SR number USN18E 0462 purchased on 05/12/2018) from the first opposite party for an offer price of Rs.35,70,600/-. The opposite parties installed the machine ultra sound scan machine in the clinic of the complainant  on 08/12/2018. But both 2DX3D probe showed cloudy images, the clarity was poor compared to the demo machine. Subsequently it appeared the scanning machine was defective and on reporting the same the 5^th opposite party regularly visited in the scanning machine at the clinic of the complainant to providing service to the scanning machine. In effect the complainant was in trouble, she could not even run the clinic and was compiled to close for a week. She was compelling to advice the patients to await service of scanning from the outside. Hence the complainant cannot utilize the scanning machine.  In addition to that the complainant  submit that  she availed  loan from the 8^th opposite party  with the assistance of opposite parties  1,3,4, and 9. The complainant also alleged  the opposite parties  collected  9,08,600/- rupee in excess of amount shown in the invoice bill from the complainant Hence the prayer of complainant is to  refund the amount of Rs.35,70,600/- with interest at the rate of 18% per annum from 05/12/2018 till realization . The complainant further prays compensation of Rs.10,00,000/-and cost of the proceedings.

24.      Though the opposite parties 1, 3, 4 and 9 filed version no affidavit has been filed in support of the contention in the version. The perusal of version it can be seen that   the opposite party was willing to refund the cost of the product or to replace the scanning machine with defect free one. The opposite parties admitted in para 9 of the version that there were some issues regarding the said scanning machine. Then the offer of the opposite party was either to provide Diamond Selector (D S system) or offered to take back the system of the complainant and refund the money after deducting the depreciation value.  The opposite party submitted in para 7 that the allegation of excess amount collected from the complainant is not correct and it was for the purpose of extension of the guaranty period. But on filing the version of the opposite parties the complainant filed replication clarifying the warranty condition and factual position of the collection of excess amounts.

25.      The Commission has gone through the entire averments in the affidavit of the complainant and documents and version of the opposite parties 1,3,4 and 9. It appears the case of the complainant is genuine one. The opposite parties 1,3,4 and 9 did not file affidavit in lieu of evidence. But the opposite parties filed an application IA 47/2023 challenging the maintainability of the complaint.  On the day of filing this IA 47/2023 the complaint was posted for filing the affidavit of the opposite party in lieu of evidence. The complainant filed counter also. The commission observed that IA 47/2023 filed only to protract the adjudication of proceedings without filing counter affidavit in lieu of evidence. The complainant already filed argument note in the complaint. Hence IA was disposed stating that the prayer will be considered   with final orders for which the complaint was posted to 20/04/2023.

26.      The commission has gone through the IA 47/2023. The contention is that the complainant herein is not covered under the definition of section 2 (7) of the consumer protection act 2019. It is contended that the complainant purchased the ultra sound scan machine for the use at her home clinic. Hence the submission of the opposite party was that the machine was used for commercial purpose and therefore the Consumer Dispute Redressal Commission does not have jurisdiction to entertain the complaint.

27.      The complainant submitted that she is a self-employed medical practitioner who has a clinic attached to her house.  The ultra sound scanning machine is bought and used by her exclusively for the purpose of earning her lively hood by means of self-employment.  The product is used by the complainant in her profession. The product purchased by the complainant for professional use and not meant for resale or for any commercial purpose as stated in section 2 (7) (i) of the act.

28.      We find there is merit in the contention of the complainant.  The complainant is a gynecologist, self-employed medical practitioner who has a clinic attached to her house. The ultra sound scanning machine is bought and used by her exclusively for the purpose of earning her lively hood by means of self-employment. Hence the contention of the opposite party that the complainant availed the machine for commercial purpose will not lie.

29.      The case of the complainant stands proved through the exparte affidavit and documents. There is no contra evidence against the contention of the complainant. The opposite party admitted the case of the complainant that the machinery has got some issues in para 9 of the version. It is also admitted in version they are willing to refund the money after deducting the deprecation value.  The complainant did not accept the offer of the opposite parities and filed this complaint. So, it is very apparent that the machinery was defective one and the complainant suffered a lot of inconvenience and hardship. It is to be relevant to not that the machinery is not a simple one but which deals with the precious human life. Hence the inconvenience caused to the complainant and thereby the patients as stated in the affidavit cannot be considered in a light way.  The complainant is entitled due redressal of grievance including under penal provision as provided under the consumer protection act. The Commission finds that the prayer to refund the cost of the machinery with interest is reasonable one. But the rate of interest for the amount shown as 18% is on higher side and so we reduce it as 12%. The complainant prayed compensation of Rs.10,00,000/- on account of unfair trade practice and deficiency in service and thereby caused inconvenience and hardship to the complainant. We consider Rs.5,00,000/- will be a reasonable amount considering the nature of deficiency in service on the part of opposite parties. The complainant is also entitled cost of Rs.20,000/-. The 5^th opposite party provided service duly to the complainant. The opposite parties 1,3,4 and 9 is honoring the ownership of the product. Hence, we find that opposite parties 1, 3, 4 and 9 is liable to compensate the complainant.

In the light of above fact and circumstances we allow this complaint as follows:

1. The opposite parties 1, 3, 4 and 9 are directed to pay an amount of Rs.35,70,600/- (Rupees thirty-five lakh seventy thousand six hundred only) to the complainant with interest at the rate of 9% from 05/12/2018 to till date of payment, as the cost of the product.
2. The opposite parties 1,3,4 and 9 are directed to pay Rs.5,00,000/- (Rupees five lakh only) as compensation to the complainant on account of unfair trade practice and deficiency in service and thereby caused inconvenience   and hardship to the complainant.
3. The opposite parties 1,3,4 and 9 are directed to pay cost of Rs.20,000/- (Rupees twenty thousand only) to the complainant.

4)         The opposite parties 1, 3, 4 and 9 is at liberty to take back the scanning machine from the clinic of the complainant after compliance of the above stated directions.

The opposite parties 1,3,4 and 9 shall comply this order within one month from the date of receipt copy of this order failing which the complainant is entitled for interest at the rate of 12% per annum on above entire amount from the date of order to till date of realization .

Dated this 20^th  day of April , 2023.

APPENDIX

Witness examined on the side of the complainant: Nil

Documents marked on the side of the complainant: Ext.A1 to A58

Ext.A1: True copy of offer document dated 10/01/2018.

Ext.A2: True copy of the bank statement issued by Federal Bank Limited , Vengara

              Branch dated 16/10/2018

Ext A3: True copy of the bank statement issued by Federal Bank Limited , Vengara

              Branch dated 16/10/2018

Ext A4: True copy of  the tax –invoice issued by the  opposite party dated 05/12/2018

Ext A5:True copy of E-way system e-way bill dated 05/12/2018.

Ext.A6: True copy of the repayment  schedule issued by the  8^th opposite party.

Ext.A7: True copy of the work sheet dated 18/12/2018.

Ext A8: True  copy of the work sheet dated 21/12/2018.

Ext A9: True  copy of the work sheet dated 29/12/2018.

Ext A10: True  copy of the work sheet dated 02/01/2019.

Ext.A11: True  copy of the work sheet dated 02/01/2019.

Ext.A12: True  copy of the work sheet dated 21/01/2019.

Ext A13: True  copy of the work sheet dated 08/05/2019.

Ext A14: True  copy of the work sheet dated 03/10/2019.

Ext A15: True  copy of the work sheet dated 14/05/2019.

Ext.A16: True  copy of the work sheet dated 16/05/2020.

Ext.A17: True  copy of the work sheet dated 30/05/2020.

Ext A18: True  copy of the work sheet dated 13/11/2020.

Ext A19: True  copy of the work sheet dated 18/11/2020.

Ext A20: True  copy of the work sheet dated 20/11/2020.

Ext.A21: True  copy of the work sheet dated 20/11/2020.

Ext.A22: True  copy of the work sheet dated 02/12/2020.

Ext A23: True  copy of the work sheet dated 07/12/2020.

Ext A24: True  copy of the work sheet dated 12/12/2020.

Ext A25: True  copy of the work sheet dated 18/12/2020.

Ext.A26: True  copy of the work sheet dated 20/12/2021.

Ext.A27: True  copy of the work sheet dated 05/01/2021.

Ext A28: True  copy of the work sheet dated 12/01/2021.

Ext A29: True  copy of the work sheet dated 25/03/2021.

Ext A30: True  copy of the work sheet dated 25/03/2021.

Ext.A31: True  copy of the work sheet dated 01/04/2021.

Ext.A32: True  copy of the work sheet dated 10/04/2021.

Ext A33: True  copy of the work sheet dated 19/06/2021.

Ext A34: True  copy of the work sheet dated 04/08/2021.

Ext A35: True  copy of the work sheet dated 25/10/2021.

Ext.A36: True  copy of the work sheet dated 09/12/2021.

Ext.A37: True  copy of the work sheet dated 13/12/2021.

Ext A38: True  copy of the work sheet dated 09/12/2021.

Ext A39: True  copy of the work sheet dated 16/12/2021.

Ext A40: True  copy of the work sheet dated 11/01/2022.

Ext.A41: True  copy of the  second invoice dated 05/812/2018.

Ext.A42: True copy of the Loan and Hypothecation Agreement dated 11/12/2018

Ext A43: True copy of the No dues Certificate issued by the 8^th opposite party  dated

                 16/12/2021.

Ext A44: True  copy of the work sheet dated 03/02/2022.

Ext A45: True copy of the  letter issued by Indian Medical Association dated

               02/03/2019.

Ext A46: True  copy of the work sheet dated 16/05/2022.

Ext.A47: True  copy of the work sheet dated 25/05/2022.

Ext.A48: True  copy of the work sheet dated 06/06/2022.

Ext A49: True  copy of the work sheet dated 19/07/2022.

Ext A50: True  copy of the work sheet dated 09/08/2022.

Ext A51:  True  copy of the work sheet dated 13/08/2022.

Ext A52:  True  copy of the work sheet dated 16/08/2022.

Ext A53: True  copy of the work sheet dated 15/09/2022.

Ext A54:  True  copy of the work sheet dated 07/10/2022.

Ext A55: True  copy of the work sheet dated 10/10/2022.

Ext A56: True  copy of the work sheet dated 09/11/2022.

Ext A57: True  copy of the work sheet dated 12/06/2021.

Ext A58: True  copy of the work sheet dated 03/02/2022.

Witness examined on the side of the opposite party: Nil

Documents marked on the side of the opposite party: Nil