Andhra Pradesh

Chittoor-II at triputi

CC/24/2017

V.Giridhar Reddy, S/o. V.Janakirami Reddy. - Complainant(s)

Versus

The Chief Manager, Apollo Munich Health Insurance Co. Ltd., - Opp.Party(s)

K.V.Bhaskar

22 Feb 2019

ORDER

Filing Date: 31.05.2017

Order Date:22.02.2019

 

 

 

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL FORUM-II,

CHITTOOR AT TIRUPATI

 

 

      PRESENT: Sri.T.Anand, President (FAC)

               Smt. T.Anitha, Member

 

 

 

FRIDAY THE TWENTY SECOND DAY OF FEBRUARY, TWO THOUSAND AND NINTEEN

 

 

 

C.C.No.24/2017

 

 

Between

 

 

V.Giridhar Reddy,

S/o. V.Janakirami Reddy,

D.No.19-3-28A, Old Renigunta Road,

Tirupati,

Chittoor District,

Andhra Pradesh.                                                                               … Complainant.

 

And

 

 

1.         The Chief Manager,

            Apollo Munich Health Insurance Co. Ltd.,

            Central Processing Center,

            2^nd and 3^rd Floor, ILABS Centre,

            Plot No.404-405, Udyog Vihar, Phase-III,

            Gurgaon – 122 016,

            Haryana State.

 

2.         The Chief Manager,

            Apollo Munich Health Insurance Co. Ltd.,

            Flat No.2B, 2^nd Floor, DEV Regency No.6,

            1^st Main Road, Gandhi Nagar, Adyar,

            Chennai - 600 200,

            Tamil Nadu.                                                                          …  Opposite parties.

 

 

 

 

            This complaint coming on before us for final hearing on 23.01.19 and upon perusing the complaint and other relevant material papers on record and on hearing Sri.K.V.Bhaskar, on behalf of the complainant, and Sri.Prem Kumar Karanam, counsel for opposite party No.1,  and having stood over till this day for consideration, this Forum makes the following:-

ORDER

DELIVERED BY SRI. T.ANAND, PRESIDENT (FAC)

ON BEHALF OF THE BENCH

           

            This complaint is filed under Sections –12 and 14  of C.P.Act 1986, alleging as follows -

2.  The complainant is a subscriber of ‘Easy Health Policy’. He obtained the  policy on 25.02.2011 for the first time and the same is valid till 24.02.2012. Thereafter, he renewed the policy for every two years. The policy was in force from February 2016 to February 2018, vide policy No.1000170996-03. The agents of opposite party No.2 met the complainant to join the insurance scheme. In January 2011 complainant’s wife had pain in abdomen, and she contacted Gynecologist of Apollo Hospitals, Chennai, for treatment and got admitted in the hospital on 23.01.2011, and on the next day she underwent ‘Abdominal Hysterectomy with Bilateral Salpingo Oophorectomy Adhesiolysis’ surgery and she was discharged on 29.01.2011. Thereafter, she had no complaint and was keeping good health. The complainant spent huge amount for surgery and hospitalization of his wife. The insurance wing of the hospital referred the agent of opposite party No.2, to approach the complainant for taking the policy, to avoid future hospitalization expenses. As advised by opposite party No.2 agent, complainant had been paying premium without interruption and had not claimed any amount for any treatment between 2011 and 2016. Recently on 22.02.2017 wife of the complainant went to Apollo hospital, Chennai, complaining pain in her left leg. One Dr. Balaji, Consultant Vascular Surgeon for Varicose Veins advised her to undergo surgery. But as she developed abdominal distension, she was asked to consult Dr.K.R.Palaniswamy, Consultant Medical Gastroenterologist. On 09.03.2017 complainant got his wife admitted in the hospital for diagnosis and ultra sound upper abdomen was done and no significant abnormality detected in chest. On 10.03.2017 2D Echo was done with ultrasound guided trucut core biopsy of the mass in lower abdomen detected and was discharged on 11.03.2017. Again on 13.03.2017 PET CT whole body scan was done and abdomino-pelvic mass with cycstic and hypermetabolic solid components, mildly FDG avid soft tissue deposit in the umbilical region found. The doctors had advised her to go for chemotherapy. The complainant gave requisition for claim on 09.03.2017 to opposite party No.2. He then got his wife admitted in the Apollo Hospital for chemotherapy on 15.03.2017 and she was discharged on 16.03.2017. The complainant had been paying all the bills for consultations, tests etc. from 09.03.2017 onwards and till date he paid Rs.3,00,000/- and further he has to spend amounts for future chemotherapy sittings. He spent Rs.10,000/- for travelling to Chennai, and to stay in Chennai. He was paying the annual premium of Rs.50,000/- under the health policy. At the time of taking policy, opposite party No.2 agent told him that he need not pay any single pie from his pocket, as medical expenses incurred will be paid to him by the insurance company including hospitalization cost and expenses. But to his surprise, he received a letter dt:14.03.2017 from opposite party No.2 terminating Easy Health Policy obtained by him under Section-VII J, for the reason of suppression of material facts. The premium amount paid by him was also forfeited. It is nothing but unfair trade practice by the opposite parties. The complainant underwent mental agony due to the acts of opposite parties. They are liable to pay necessary damages to him. There is no suppression of material facts relating to pre-existing disease of his wife. In 2011, she only underwent hysterectomy. The present tests and diagnosis revealed that complainant’s wife is suffering from some other problem. The termination of health policy on flimsy grounds is illegal. The complainant got issued legal notice on 07.04.2017 calling upon the opposite parties     1 and 2, to pay Rs.3,00,000/- spent on treatment along with Rs.10,000/- towards incidental charges, and also to pay Rs.50,000/- towards damages for undergoing mental agony by him due to deficiency in service by the opposite parties. The legal notice was acknowledged by opposite party No.2 on 10.04.2017. The complainant had spent Rs.1,50,000/- towards medical treatment, even after issuing legal notice. For every visit of chemotherapy, he has been spending Rs.1,50,000/- for his wife. Thus, he spent Rs.14,68,360-85 till the month of October, 2017. In the month of November, 2017 also chemotherapy sitting was held for his wife and for that also he spent Rs.1,50,000/-.

3. The original complaint was amended as per orders passed in I.A.No.74/2017 dt:12.04.2018, to claim reimbursement of medical expenses incurred by the complainant.

4.  Opposite party No.2, remained ex-parte.

5.  Opposite party No.1 filed the written version before the amendment of complaint, and subsequently filed additional written version after the amendment. In the written version, opposite party No.1 contended as follows – At the outset complaint allegations are denied. The averments in para Nos.1,2,3,4,5,6,7,8,9 are denied in Toto. It is contended that complaint is misconceived, misconstrued, contrary to the contract between the parties and therefore untenable in law. The insured has not disclosed the treatment undergone by her during the period 23.01.2011 to 29.01.2011 for ‘Endometriosis’ by way of surgery of ‘total abdominal hysterectomy with bilateral salpingo oophorectomy and the same was not in the proposal form dt:04.02.2011. The insured is under an obligation to mention the actual illness or disease in the proposal form at the time of applying for the insurance policy from the insurance company. Had she disclosed the same, insurance company would not have issued the policy. Breach of providing false information by the insured under the policy, entitles the insurer to avoid the contract of insurance so long as non-disclosure induced the making of the contract on the relevant terms. The insurance policy is based upon contract whereby the proposal along with the first insurance premium is received from the proposer, who intends to take insurance policy from the insurance company. The proposer, who intends to procure an insurance policy, has to fill in the material details in the proposal form, and the insurance company, on receipt of proposal form, issues the policy as per the requirement of the proposer. The policy holder and the company are bound by the terms and conditions of the insurance policy. The risk is covered under the policy solely basing on the facts mentioned in the proposal form signed by the wife of the complainant. The facts of existing health condition, illness and the treatment availed were known to insured prior to making the proposal for insurance and the same was deliberately concealed in the proposal form submitted to the opposite party. The opposite party made investigation after receipt of the claim from the complainant and found that insured had received treatment for ‘Endometriosis’ by way of surgery of total abdominal hysterectomy with bilateral salpingo oophorectomy at Apollo Hospital, Chennai, under UHID No.170806. She was treated in the hospital from 23.01.2011 to 29.01.2011.The proposal form was submitted on 04.02.2011, on the basis of which policy No.140600/11111/1000170996 was issued in the name of Sri.V.Giridhar Reddy. The said fact was not disclosed in the proposal form and as such opposite party repudiated the claim of the complainant due to non-disclosure of material facts. The insured had knowledge that she was suffering from the said disease at the time of making the proposal to opposite party. The complaint is therefore not bonafide and deserves to be dismissed on the principle of “Allegatio contra factum non est admittenda”. They issued the policy basing on the principles of ‘Uberimma Fidei’ i.e. utmost good faith and accordingly rely on the declarations and statements made in the proposal form. The insured is under obligation to make a true and full disclosure of the information on the subject within his knowledge. When the assured had knowledge of her particular pre-existing disease and other matters pertaining to health, she is under obligation to disclose the same while answering the questions in the proposal form. In the absence of such disclosure, the insurer is entitled to repudiate the claim. It is admitted that opposite party No.1 had issued policy bearing No.140600/11111/1000170996 in favour of the complainant. It was not the complainant, who filled the proposal form, but the insured and other filled the proposal form. The complainant admits that the insured was well aware of the terms and conditions of the policy, and as such complainant is estopped from denying that the disclosures made by insured in the proposal form shall be the basis for issuance of the policy and any material non-disclosure will disentitle the policy holder for the coverage of the policy. The opposite party had been acting in good faith and in accordance with the provisions of law and policy terms. The policy was repudiated as per Section-45 of Insurance Act, 1938. The complainant had not come to the Forum with clean hands. Complaint is not maintainable under the provisions of C.P.Act. The contract is vitiated by non-disclosure, as it did not provide proper opportunity to the insurer to underwrite the proposal before deciding to accept the risk. There is no deficiency in service on the part of opposite parties as per the decision reported in (2000) 1 SCC 66 between Ravneet Singh Bagga vs. KLM Royal Dutch Airlines. In the absence of deficiency in service, the aggrieved person may have a remedy under the common law to file suit for damages but cannot insist for grant of relief under the Act for the alleged acts of commission and omission attributable to the opposite parties. If the action of opposite party is found to be in good faith, there is no deficiency in service on their part. In the written version, opposite party referred the decisions reported in (i) IV (2009) CPJ 8 (SC) between Satwant Kaur Sandu vs. New India Assurance Co. Ltd., (ii) III (1996) CPJ 8 (SC) = (1996) 6 SCC 428 between United India Insurance Co. Ltd. vs. M.K.J.Corporation, in support of their claim that the repudiation is justified. It is therefore prayed to dismiss the complaint.

6.  In the additional written version, it is contended as follows – It is denied that complainant had spent Rs.3,00,000/- towards his wife’s treatment as on the date of complaint and thereafter spent a total sum of Rs. 14,68,360/- towards her treatment, as there were frequent chemotherapy sittings and for each sitting he has spent Rs.1,50,000/-. The alleged amendment to the complaint is in no way connected to the cause of action, as the original cause of action is not continuous.

7.  The complainant filed chief affidavit as P.W.1 and got marked Exs.A1 to A17. One Deepti Rustagi, Vice President – Legal and Compliance, Apollo Munich Health Insurance Company Ltd., Gurgaon, filed chief affidavit as R.W.1 and no documents are marked on behalf of the opposite parties.

8.  The point for consideration is whether there is deficiency in service on the part of opposite parties, in repudiating the claim of the complainant under mediclaim policy? If so, to what extent the complainant is entitled for the reliefs sought in the complaint?  

9.  Point:-  In the written arguments, complainant mainly argued that she had taken treatment in Apollo hospital for chemotherapy during the year 2017 by incurring an expenditure of Rs.14,68,360/- and the same is liable to be paid by the opposite parties being the insurer since the mediclaim policy was in force as on the date of treatment. In order to prove her claim, she had marked several documents. There is no dispute regarding Ex.A1 which is original policy showing the claimant as  policy holder vide Member ID 10001564649. It is the case of the complainant that the policy was renewed from time to time during the years 2012-2018. The policy was renewed as per the letter addressed to the complainant by the insurer. Ex.A2 is renewal letter dt:26.02.2014 with regard to mediclaim policy of complainant. Ex.A3 is renewal of health insurance coverage letter dt:17.02.2012 issued in favour of the complainant, wherein the policy details shows that complainant and his wife are the insured persons and the opposite party is not disputing about the policy. Their main contention is that the claim of the complainant was repudiated in view of the fact that she intentionally suppressed her pre-existing disease before taking the policy and played fraud on the insurance company. In support of their contention, opposite party relied upon the decisions –

 (i) In Satwant Kaur Sandu vs. New India Assurance Co. Ltd., reported in IV (2009) CPJ 8 (SC) the Hon’ble Apex Court held as follows –

 

Nonetheless, it is a contract of insurance falling in the category of contract ‘UBERRIMAE FIDEI’ meaning, a contract of utmost good faith, on the part of the assured. Thus, it needs little emphasis that when an information on a specific aspect is asked for in the proposal form, an assured is under a solemn obligation to make a true and full disclosure of the information on the subject which is within his knowledge. It is not for the proposer to determine whether the information sought for is material for the purpose of the policy or not. Of course, obligation to disclose extends only to facts which are known to the applicant and not to what she ought to have known. The obligation to disclose necessarily depends upon the knowledge one possesses. His opinion of the materiality of that knowledge is of no moment.

 

 

(ii). In United India Insurance Co. Ltd., vs. M.K.J.Corporation, III (1996) CPJ 8 (SC) = (1996) 6 SCC 428, the Hon’ble National Commission has observed that

it is a fundamental principle of insurance law that utmost faith must be observed by the contracting parties. Good faith forbids either party from non-disclosure of the facts which the party privately knows, to draw the other into a bargain, from his ignorance of that fact and his believing the contrary.

 

Further in the written arguments, opposite party referred ‘Pollock and Mull’s Indian Contract and Specific Relief Act’, wherein it is stated that any fact the knowledge or ignorance of which would materially influence an insurer in making the contract or in estimating the degree and character of risks in fixing the rate of premium as a material fact.

10.  It is an admitted fact that the complainant had undergone treatment for Endometriosis by way of surgery of total abdominal hysterectomy with bilateral salpingo oophorectomy, at Apollo hospital, Chennai, under UHID No.170806. The opposite party argument is that this fact of undergoing surgery by the complainant was not disclosed in the proposal form while obtaining mediclaim policy. It is the contention of complainant counsel that there is no question of suppression of material facts by the complainant while obtaining mediclaim policy as contended by the opposite party. The counsel for complainant placed reliance on the following citations:-

(i).  I (2012) CPJ 378

Consumer Protection Act 1986 – Sections 1 (1) (g), 14(1)(d), 15 – Insurance (Life) – Suppression of material facts – Death of insured – Claim repudiated on ground of concealment of previous disease – Alleged deficiency in service – District Forum allowed complaint – Hence appeal – A common man is not supposed to know all the niceties and technicalities of Law – Once accepting the premium and having entered into agreement without verifying the facts, Insurance company cannot wriggle out of liability merely by saying that contract was made by misrepresentation and concealment – Insurance policies should not be issued and repudiated in such casual mechanical manner – Policy entitles liability on both sides – It is rather exploitation of consumer and more or less fraud on public – Respondent has been put to great inconvenience in contesting present appeal – Cost of Rs.5,000/- awarded – Impugned order upheld. Appeal dismissed.

    

(ii).  II (2010) CPJ 562

Consumer Protection Act 1986 – Section 2(1)(g) – Life insurance – Suppression of material facts – Claim repudiated stating non – disclosure of pre existing facts – Deficiency in service alleged – Complaint allowed – Hence appeal – Abnormal menstruation in women cannot be classified as a disease – Such disorders normal amongst ladies – Repudiation not justified – Deficiency in service proved – Order upheld – No interference required. Appeal dismissed.

             

(iii).  I (2011) CPJ 517

Jammu and Kashmir Consumer Protection Act 1987 – Sections 2(g) and 13(d) – Insurance (Life) – Suppression of material facts – Claim repudiated – Hence, complaint – Contention, insured had not disclosed operation of Gall Bladder and guilty of willful suppression of material facts – No accepted – Proposal form was got filled by agent by way of observing an idle formality – Not a case of deliberate suppression of operation of Gall Bladder by insured which had a great bearing on contract of insurance – Expert witness of OP’s has admitted that Gall Bladder could not be case of heart attack – Repudiation unjustified. Complaint allowed.

 

            (iv).  I (2012) CPJ 224

Consumer Protection Act 1986 – Section 15 – Insurance (Life) – Suppression of material facts – Insured died due to cancer – Claim made – Repudiated on ground that insured was suffering from cancer  prior to taking of policy and so, willfully suppressed material facts – Complaint filed – Deficiency in service alleged – Dismissed – Hence appeal – Before issuance of policy, doctors who were on panel of respondent, examined deceased and not found any factor suggestive of deceased suffering from ill health – All hematological, pathological and other examinations of deceased and reports thereof are subsequent to obtaining insurance policy – No evidence brought on record by respondent to effect that deceased had knowledge of dreaded disease and that she had consulted a doctor or a hospital for treatment thereof, before taking of policy – Burden of proof to validate its decision of repudiation of claim, heavily lies upon respondent which he failed to discharge as not adduced any contemporaneous evidence in support of repudiation – Impugned order set aside – Appeal allowed.

 

 

 

(v).  IV (2012) CPJ 782 (NC)

Consumer Protection Act 1986 – Sections 2(1)(g), 14(a)(d), 21(b) – Insurance (Life) – Hospitalised complaining abdominal pain – Surgery perfomed – Death of insured – Alleged suppression of pre-existing disease – Claim repudiated – Deficiency in service – District Forum allowed complaint – State Commission dismissed appeal  - Hence revision – Contention, insured was suffering from some other disease, may be typhoid but all those disease have been suppressed – Not accepted – Insurance company must prove suppression by producing cogent and plausible evidence – Case of petitioner wallows in suspicious and uncertainties – impugned order upheld. Revision petition dismissed.

 

            On the basis of principles laid down in the above citations, the complainant argued that she had underwent surgery for hysterectomy before taking policy and that non-disclosure of fact of undergoing surgery in the proposal form does not amounts to suppression of fact, as the disease for which complainant had taken treatment subsequent to obtaining policy is for different purpose. It is an admitted fact that in the year 2011, complainant had undergone surgery for hysterectomy and at that time, it was not diagnosed that the complainant was suffering from ‘Metastatic Peritoneal Disease High Grade Serous Carcinoma Malignant Ascites on Chemotherapy’. It is in the year 2017 only she was diagnosed with carcinoma, for which she had undergone chemotherapy. The complainant had filed several bills relating to the treatment taken by her for undergoing chemotherapy for cancer. Ex.A6 is the Discharge Summary relating to complainant, as per which it is proved that she was admitted in the hospital on 15.03.2017 and was discharged on 16.03.2017. The disease diagnosed is ‘Metastatic Peritoneal Disease High Grade Serous Carcinoma Malignant Ascites on Chemotherapy’. Another discharge summary shows that again she was admitted in the same hospital on 05.04.2017 and was discharged on 06.04.2017, and again she was admitted on 26.04.2017 and discharged on 28.04.2017. As per another discharge summary, again she was admitted on 17.05.2017 and discharged on 18.05.2017 in the same hospital. Ex.A5 is bunch of bills filed by the complainant in order to prove the medical expenses incurred for the treatment taken by her in Apollo Hospital on various dates, as mentioned in discharge summaries. Ex.A11 is bill details UHID wise from 13.03.2017 to 17.08.2017. Ex.A12 is another bunch of bills for taking treatment in the same hospital by the complainant on 20.05.2017. The discharge summary shows that she was discharged on 18.05.2017.  Ex.A13 is another bunch of bills with discharge summary for the treatment taken by the complainant from 07.06.2017 to 08.06.2017. Ex.A14 in patient bill dt:03.07.2017 which shows that complainant had taken treatment for chemotherapy from 28.06.2017 to 30.06.2017. Ex.A15 is bill realization receipt dt:11.08.2017, for the treatment taken by the complainant in the same hospital from 16.08.2017 to 17.08.2017. Ex.A16 is also bunch of bills for the treatment from 06.09.2017 to 07.09.2017. Ex.A17 is deposit receipt for payment of bills amounts by the complainant for the treatment taken from 05.07.2017 to 07.07.2017 in the same hospital. Ex.A4 is network hospitals list. There is no dispute that Apollo Hospital is in the network of insurance company. Under Ex.A8 complainant had issued legal notice dt: 07.04.2017 to opposite parties asking them to settle the claim of Rs.3,00,000/- spent on the treatment along with Rs.10,000/- towards incidental charges and compensation of Rs.50,000/-. The complaint was filed on 31.05.2017, but subsequently complainant had undergone treatment in the Apollo Hospital as reflected in the deposit receipts pertaining to the bill payments. It is an admitted fact that during the period 2017-18 the mediclaim policy was in force and the sum assured under mediclaim policy is Rs.5,00,000/-. The complaint was subsequently amended to enhance the claim from Rs.3,00,000/- to Rs.14,68,360/-. Though the opposite parties have contended that there is suppression of material facts relating to the earlier disease by the complainant and on account of the same claim has been repudiated, the record shows that the complainant had undergone surgery for hysterectomy before obtaining the policy in 2011, and only in 2017 when the complainant went to Apollo Hospital for pain in left leg, she was advised to undergo 2D Echo test, and again on 13.03.2017 PET CT whole body scan was done and abdomino-pelvic mass with cyctic and hypermetabolic solid components, mildly FDG avid soft tissue deposit in the umbilical region found, and she was advised to undergo chemotherapy thereafter. So, it is clear that hysterectomy surgery has nothing to do with the present ailment of complainant detected in 2017. It is held in a decision by the Hon’ble Supreme Court in Sulbha Prakash Motegaonkar and Ors. Vs. Life Insurance Corporation of India in Civil Appeal No.8245 of 2015 dt:05.10.2015, wherein the Apex Court held that 

“We are of the opinion that National Commission was in error in denying to the appellants the insurance claim and accepting the repudiation of the claim by the respondent. The death of the insured due to ischaemic heart disease and myocardial infarction had nothing to do with this lumbar spondylitis with PID with sciatica. In our considered opinion, since the alleged concealment was not of such a nature as would disentitle the deceased from getting his life insured, the repudiation of the claim was incorrect and not justified”.

 

            Though the opposite parties have contended that complainant deliberately not disclosed the fact of earlier surgery and had it been disclosed in the proposal form, the insurance company would not have issued policy in her favour. In our considered opinion, on the basis of the above cited decisions and documentary evidence, we hold that there is no deliberate suppression of hysterectomy surgery in order to hoodwink the insurance company to obtain mediclaim policy, as the medical treatment undergone by the complainant subsequent to taking policy for cancer cannot be connected to hysterectomy surgery. We therefore hold that opposite party is liable to pay expenditure involved in the treatment during 2017 by the complainant. But as seen from the policy, we are of the view that liability of opposite party is limited to Rs.5,00,000/- only and to that extent complainant has to be reimbursed.

            11.  Basing on the citations submitted by the complainant, we hold that opposite parties are liable to pay Rs.5,00,000/- with interest at 9% p.a. from the date of submitting the claim by the complainant, till the same is realized. With regard to compensation, certainly complainant would have undergone mental agony due to non-settlement of claim, and therefore we are of the view that Rs.1,00,000/- can be awarded towards compensation. Apart from that complainant is also entitled to a sum of Rs.3,000/- towards litigation expenses. Accordingly, this complaint is to be allowed.

            12.  In the result, complaint is partly allowed directing the opposite parties to pay Rs.5,00,000/- (Rupees five lakhs only) with interest at 9% p.a. from the date of submitting the claim by the complainant, till realization, and also directed to pay Rs.1,00,000/- (Rupees one lakh only) towards compensation, and Rs.3,000/- (Rupees three thousand only) towards costs of the complaint. The opposite parties are directed to comply with the orders within eight (8) weeks from the date of this order, failing which the compensation amount of Rs.1,00,000/- shall also carry interest at 9% p.a. from the date of this order, till realization.  

Dictated to the stenographer, transcribed and typed by him, corrected and pronounced by me in the Open Forum this the 22^nd day of February, 2019.

 

      Sd/-                                                                                                                       Sd/-                                  

Lady Member                                                                                               President (FAC)

 

 

APPENDIX OF EVIDENCE

 

 

 

Witnesses Examined on behalf of Complainant/s.

 

PW-1: V. Giridhar Reddy (Chief Affidavit filed).

 

Witnesses Examined on behalf of Opposite PartY/S.

 

RW-1: Deepti Rustagi (Chief Affidavit filed).

 

 

EXHIBITS MARKED ON BEHALF OF THE COMPLAINANT/s

 

Exhibits (Ex.A)	Description of Documents
	Original copy of Letter regarding ‘Renewal of Your Easy Health Insurance Policy’ given by Authorized Signatory, Apollo Munich Health Insurance Co. Ltd. Dt: 19.02.2016.
	Original copy of Letter regarding ‘Your Health Insurance Coverage’ given by Authorized Signatory, Apollo Munich Health Insurance Co. Ltd. Dt: 26.02.2014.
	Original copy of Letter regarding ‘Renewal of Your Health Insurance Coverage’ given by Suraj Mishra, Senior Vice President- Operations & Customer Services, Apollo Munich Health Insurance Co. Ltd.  Dt: 17.02.2012.
	Original copy of Network Hospital List ( Booklet).
	Original copies of Bunch of Medical bills of Apollo Speciality Hospital.
	Discharge Summary of Apollo Speciality Hospital, Department of ONCOLOGY. Dt: 16.03.2017.
	Original copy of Letter regarding Termination of Notice Dt: 14.03.2017.
	Office copy of Legal Notice with postal receipts. Dt: 07.04.2017.
	Postal Acknowledgement Card from O.P.No.2. Dt: 10.04.2017.
	Photo copy of Statement of Account given by Lakshmi Vilas Bank, Tirupati. Period from 01.01.2011 to 28.02.2011.
	Original copy of Bill details UHID wise Apollo Hospitals Apollo Speciality Hospital-Teynampet, Chennai. From date: 01.03.2017 to 31.08.2017. Dt: 07.09.2017.
	Original copy of Bunch of Medical bills, Apollo Hospitals-Apollo Speciality Hospital, Chennai (May, 2017).
	Original copy of Bunch of Medical bills, Apollo Hospitals-Apollo Speciality Hospital, Chennai (June, 2017) along with Discharge Summary.
	Original copy of Bunch of Medical bills, Apollo Hospitals-Apollo Speciality Hospital, Chennai (July, 2017) along with Discharge Summary.
	Original copy of Bunch of Medical bills, Apollo Hospitals-Apollo Speciality Hospital, Chennai (August, 2017) along with Discharge Summary.
	Original copy of Bunch of Medical bills, Apollo Hospitals-Apollo Speciality Hospital, Chennai (Sep, 2017).
	Original copy of Bunch of Medical bills, Apollo Hospitals-Apollo Speciality Hospital, Chennai (October, 2017) along with Discharge Summary.

 

EXHIBITS MARKED ON BEHALF OF THE OPPOSITE PARTY/s

 

-NIL-

 

 

                                                                                                                       Sd/-        

                                                                                                                President (FAC)

 

   

      // TRUE COPY //

// BY ORDER //

 

Head Clerk/Sheristadar,

          Dist. Consumer Forum-II, Tirupati.

 

 

  Copies to:-   1.  The complainant.

                        2.  The opposite parties.