SRI G.APPALA NAIDU, MEMBER

O R D E R

          This complaint is filed Under section-12 of Consumer Protection Act 1986 seeking reliefs directing the O.Ps 1 to 4 to pay an amount of Rs.12,67,282/- to the complainant by way of award with interest at 12% p.a., from the date of accident till the date of realization and also to pay subsequent interest and costs in the above matter in the interest of justice on the following averments: 

          The complainant is the owner of the Poultry Farm at Palavalasa Village in Merakamudidam Mandalam of Vizianagaram District located in survey No.69 in an extent of 2 Acrs land on which he constructed 8 sheds for the poultry form and one feeder room.  The complainant is the permanent resident of the aforesaid village from the last 20 years within the jurisdiction of this Hon’ble Forum.  He took necessary loans and permissions from the local authorities and started the poultry form business in the year 2011 at the above village and the said form consisted of 8 sheds and also one feeder room and the complainant is having tie up with Suguna poultries Vizianagaram who are supplying necessary chicks and pesticides to the complainant from the starting of the poultry farm. The complainant invested an amount of Rs.20,00,000/- on the poultry by taking necessary loans and also investing his own capital for doing the above business.

          The complainant submits that on 1-10-2012 he took a standard fire and special perils policy from the 1^st O.P. bearing policy No.72010011120100000737 valid from 1-10-2012 to 30-9-2013 by paying Rs.5,663/- only by way of premium for the sum assured of Rs.16,80,000/- covering the entire poultry farm, furniture, fittings and stocks and the 2^nd O.P is the local insurance office within the jurisdiction of this Hon’ble Forum and the 3^rd and 4^th O.Ps are the necessary electrical officers who authorized to supply the electricity to the above said poultry farm and the complainant took necessary electricity permissions by paying the electrical charges to the 3^rd and 4^th O.Ps.

          The complainant also submits that on 12-4-2013 at about 11.30 hrs due to excess flow of electricity to nearest pole of the poultry form from Garividi and inturn from the pole to the poultry farm, a fire accident was occurred and the entire poultry farm engulfed into fire.  Immediately on report to the nearest Fire department by the complainant, they spread the water on the poultry farm from 12-00 hrs but in the mean time the entire poultry farm was destroyed and 3000 hens were turned into ashes.  In the previous day that is on  11-4-2013 at about 10,000 hens were transported to different parts, otherwise those hens also would have been died and turned into ashes in the said accident.  The complainant also submits that he informed the Insurance Company which deputed one Mr. Rama Krishna Rao of Visakhapatnam a surveyor of the 1^st and 2^nd O.Ps who inspected the damaged poultry farm in the accident on    12-4-2013 and on request by the said surveyor the complainant submitted the necessary documents and photographs to the surveyor at Visakhapatnam and also visited the officers of the O.Ps for the insurance compensation in respect of the said poultry farm.  It is further submitted that the complainant gave the estimation of loss to an extent of Rs.19,64,550/- to the Insurance company but they have not given any survey report and also that the complainant did not receive any letter of intimation from the 1^st and 2^nd O.Ps, though the complainant incurred heavy incidental and other transport charges for visiting from his village palavalasa to Visakhapatnam for claiming the insurance amount.  However all of a sudden without any intimation, the 1^st and 2^nd O.Ps paid an amount of Rs.6,96,718/- only on 25-9-2013 by crediting the said amount to the account of the complainant in Andhra Bank at Chipurupalli Branch and without any basis as to how the Insurance Company arrived at the said compensation amount, which clearly shows deficiency of service and dereliction of duties on the part of 1^st and 2^nd O.Ps.  Though immediately the complainant contacted the said Insurance company they have not cared him but only advised that he is entitled for the said compensation only.  At that stage also the Insurance Company did not give any survey report besides the basis as to how they arrived at the said compensation. 

          It is also submitted by the complainant that the 3^rd and 4^th O.Ps are the suppliers of the electricity in that area and the said accident was occurred only due to the excess flow of the electricity in that area on            12-4-2013 since the employees of the 3^rd and 4^th O.Ps have not supervised the correct flow of electricity in that area which also clearly shows their deficiency of service and dereliction of duty though they are the masters of their employees having joint and several liability for the said fire accident.  The complainant further submits that the inner wiring in the poultry farm is correctly arranged as a sequel to which the REC authorities have given necessary permissions to the said poultry farm and that too after inspection by the 3^rd and 4^th O.Ps and the complainant has been paying the necessary electrical charges to the electrical office regularly without any dues.  The complainant is the consumer of the said electricity and the REC authorities are the suppliers of the said electricity.   But even after the accident also the 1^st and 2^nd O.Ps have not paid the entire compensation as per the terms and conditions of the policy.  The 3^rd and 4^th O.Ps also did not pay any compensation even on intimation and also after having received registered lawyer notice.  Hence this complaint.

Counter filed by 1^st O.P denying the allegations leveled by the complainant except those which are specifically admitted therein and puts the complainant to strict proof of the same. 

In the said counter it is also submitted that the 1^st O.P. is only concerned to contest the complaint according to the facts and circumstances of the case and hence the 2^nd O.P is not a necessary party to the present complaint and it is liable to be discharged from the proceedings.   Further the complainant appears to have added the 2^nd O.P in the proceedings in order to bring cause of action to file the present complaint before the Forum, which is not maintainable inspite of adding 2^nd O.P since cause of action or part of cause of action for filing the present complaint did not arise within the jurisdiction of this Forum.  The premium amount was collected and the policy bearing No.72010011120100000737 was generated and issued by the 1^st O.P on 1-10-2012 whose address is at Coimbatore and the claim of the complaint was larged at Visakhapatnam and a surveyor was appointed and claim was processed by Visakhapatnam Divisional Office.  Hence the complainant has no cause of action to present a claim petition before this Forum.  However, the claim is imaginary which is not tenable under law particularly under the grab of deficiency of service and therefore the complaint is not maintainable.

The 1^st O.P settled the claim of the complainant in accordance with the coverage, limitations and stipulations of the policy issued by it and hence there is no question of deficiency of service on their part.  The complainant simply challenging the quantum of the claim under the grab of deficiency of service and it is not tenable under the provisions of Consumers Protection Act and if he so desires he has to file a suit before civil court with definite and proper calculations and claim.  Further the complainant is not entitled to invoke the provisions of Consumers Protection Act, since it is a poultry business on commercial basis and further the complainant intentionally and willfully suppressed the material information and mischievously filed the present complaint without disclosing the real facts which are leading to file the present complaint.  Prior to filing of the complaint, the complainant issued a legal notice which was received by the 2^nd O.P on 19-11-2013 but dated                    2-11-2013 and filed this complaint without waiting period in the legal notice and this O.P has no opportunity to issue suitable reply to the said legal notice and hence the said legal notice cannot be considered as part of these pleadings as it is not valid under law.  This O.P partly insured the sum for Rs.14,88,000/- for building – Super structures excluding birds therein and an amount of Rs.1,92,000/- towards plant, machinery and accessories and total sum insured was to the extent of Rs.16,80,000/- and the complainant opted deductible amount of 5% on total claim subject to the minimum Rs.10,000/-.  However, the said policy did not cover the risk of birds, which fact was clearly mentioned in the policy and hence this O.P did not collect any premium for the risk of birds.  Further the birds are not the property of the complainant and he has no locus stand to claim compensation on the same since they are the property of Suguna poultry farms and they might be insured by somebody by the said Suguna Company.  However, this OP did not collect any premium for the risk of birds and their risk is outside the purview of the policy, since the complainant has no insurable interest over the birds.

According to the stipulations of the policy, the claim of the complainant will be settled after deduction of depreciation, salvage value etc., and accordingly the claim of the complainant was settled in accordance with stipulations, terms and conditions of the policy basing on the report of the surveyor at the earliest possible time by appointing a surveyor and loss accessor by name Sri R.Rama Krishna Rao, who is a panel surveyor and competent person under Insurance Act and also IRDA norms and a qualified engineer to assess the loss.  The said surveyor visited the place of fire accident on 13-4-2013 and 15-5-2013 and submitted his report on 15-6-2013 after taking into consideration of the documents, valuation and information submitted by the complainant during his visits and the report of the said surveyor was received by the 1^st O.P on 23-7-2013.  As the surveyor assessed the net loss after deducting the depreciation, salvage value and policy excess amount of 5% of the claim amount and under Insurance share of this O.P on building etc., they paid the amount through NEFT (National Electronic Fund Transfer) to the account of the complainant and this O.P prays that the surveyor report may be read as a part and parcel of this counter in order to avoid repetition of the facts of the case.

According to the report of the surveyor the complainant constructed 9 sheds in the year 2009 with thatched roof, Palmyra poles, eucalyptus poles and bamboo sticks out of which one shed was damaged during fire accident during May,2012 and one and half shed was collapsed in the month of October,2011 due to heavy wind and gales, which were not re-constructed  till the date of alleged fire accident on   12-4-2013.  Therefore, on the date of this accident, only 6 ½ sheds were damaged due to fire accident, but not 9 sheds as claimed by the complainant.  The surveyor estimated the value of each shed at Rs.2,52,000/- and in total 16,38,000/- but the sum insured was Rs.14,88,000/-.  The alleged sheds were constructed more than 4 years back as on the date of fire accident and hence 50% depreciation was applicable to the present sheds as per the stipulations of the policy and after deduction of depreciation and salvage value  (Rs.14,88,000/- minus 50% depreciation minus salvage of Rs.8,000/- = Rs.7,36,000/-) Net amount for the head of loss of building is Rs.7,36,000/-.  Likewise the surveyor also assessed the loss pertaining to plant and machinery as Rs.1,12,952/-.  (Total value of plant and machinery as per invoices submitted by the insured comes to Rs.1,89,086/- minus depreciation of 40% and salvage value of Rs.500/-) and hence the total loss as assessed by the surveyor comes to Rs.8,48,952/- Minus policy excess 5% of the claim amount) (Rs.16,77,086/- X 5%) i.e., Rs.83,854/- comes to Rs.7,65,098/-.  Since the building value is Rs.16,38,000/- as per the surveyor estimation but the complainant insured the said building for Rs.14,88,000/- only and since under-insured, according to policy stipulations 9.66% is deductable under the head of under-insured.  Therefore, an amount of Rs.67,399/- was deducted under the head of under insurance.  So, this O.P paid the net amount to the complainant by invoking NEFT.

However, the complainant is claiming loss to the tune of Rs.19,64,000/- on all heads without disclosing anything about the basis for such estimation, though he admitted in his complaint that he insured his poultry Farm for Rs.16,80,000/-, which clearly shows his attitude and falsity of claim.  The complainant has no cause of action to file the present complaint against them along with 3^rd and 4^th O.Ps and there is no nexus of any kind of whatsoever in between the 3^rd and 4^th O.Ps and this O.P and the cause of action stated is not correct.  Further the complainant without following the procedure laid down under Insurance Act and the terms and conditions of the policy is straight away invoking the provisions of Consumer Protection Act under the grab of deficiency of service though there is no deficiency of service on their part in settling the claim of the complainant.  However, there is no common cause of action in between the complainant and 1^st O.P., 3^rd and 4^th O.Ps and there is no vicarious liability or master and servant relationship of whatsoever in between them for claiming common relief against all the O.Ps.   Further, the complainant approached this Hon’ble Forum with an ulterior motive and a false and fictitious claim without any proper assessment made by qualified person and without any sort of bills, vouchers or invoices and hence, the claim of the complainant is not valid under law and also liable to be scraped.  Still if the complainant has any grievance, he has to file a suit in a civil court by placing all the material and prove the same under standard procedure of evidence Act, and therefore the O.P prays that the complaint may be dismissed with costs under circumstances of the case.

Separate counter filed by the 3^rd O.P which is adopted by  the 4^th O.P by filing a memo denying the allegations leveled by the complainant except those which are specifically admitted therein and puts the complainant to strict proof of the same.  It is stated that the averments made in the complaint that a fire accident occurred only due to the excess flow of the electricity in that area on 12-4-2013 is utterly false and the other averment that the employees of the O.Ps 3 and 4 society have not supervised the correct flow of electricity in that area and that there is deficiency of service and dereliction of duty on their part are not true and correct.  Further, there is no service connection extended in the name of the complainant by the OPs 3 and 4 of the society and hence they are not liable to pay any amount much less as claimed in the complaint as there is also no master and customer relationship between O.Ps 3 and 4 society and the complainant. 

Further, the Assistant Divisional Engineer, Operations of RECS Ltd., Cheepurupalli Vide his letter No.REC/CPL/Garividi Sec/D.No.22/dt.20-5-2013 as per the consumer of S.C.No.201 of Sri M.Visweswara Rao of Kumarapalavalasa Village who requested vide reference letter dt.14-5-2013 to issue fire accident certificate occurred on 12-4-2013 to the poultry sheds, it was opined that the said fire accident was occurred due to short circuit in the internal wiring of the consumer premises due to rats biting and not due to negligence of the RECS, Cheepurupalli, which was based on the inspection conducted by the A.A.E  (Operations), Garividi along with the L.I.(Rural), Garividi and also based on enquiry with the consumer and local public.  Hence the said certificate issued by the A.D.E.(Operations) reveals that the fire accident might have occurred due to short circuit in the internal wiring of the poultry sheds of S.C.No.201 of Sri M.Visweswara Rao of  Kumarampalavalasa Village which was issued at the request of the said consumer.  Therefore, the O.Ps 3^rd and 4^th prays the Hon’ble Forum to dismiss the complaint against them with costs and to render justice as there is no cause of action for the complainant for this complaint.

Ex.A.1 to A.9 are marked on behalf of the complainant and Ex.B.1 to B.5 are marked on behalf of the O.Ps.  Heard arguments. Posted for orders.   The orders are as follows:  The counsel for both the parties argued vehemently reiterating what they have stated in the complaint, counters, evidence affidavits and brief written arguments respectively. 

The bone of contention in between the complainant and O.Ps is with regard to dispute in the assessment of the damage and claim settlement and also with regard to the cause of fire accident, under Insurance and Jurisdiction.  The Main contention of the complainant is that even though they paid the premium for the sum assured of Rs.16,80,000/- covering the entire poultry Farm, furniture, fittings and stocks the O.P.1 paid the amount of Rs.6,96,718/- only on 25-9-2013 by crediting the said amount to his Andhra Bank account, Cheepurupalli without any intimation and also conclusion how the insurance company arrived at the compensation and further the insurance company did not give any survey report and hence there is deficiency of service on the part of Insurance company.  The 2^nd contention raised by the complainant is with regard to REC, Cheepurupalli as the fire accident was occurred due to the excess flow of electricity in that area on 12-4-2013 which was not correctly supervised by the employees of the REC and hence it clearly shows deficiency of service and dereliction of duty on behalf of 3^rd and 4^th O.Ps and therefore they are also liable to pay damages / compensation.  In view of the above, the complainant is claiming the balance compensation of Rs.12,67,282/- (As per the loss of poultry farm and the loss estimated by the complainant at Rs.19,64,000 minus the compensation partly paid by the 1^st and 2^nd O.Ps amounting to Rs.6,96,718/-) as against the insured sum of Rs.16,80,000/- for which premium was paid by the complainant and since the policy was valid from 1-10-2012 to 13-9-2013 as the said fire accident occurred on                12-4-2013.

The main contention raised by the Insurance company is that the net loss assessed by the qualified and competent surveryor is at Rs.7,65,098/- and after deduction of 9.66% i.e., Rs.67,399/- under the head under-insurance as per their stipulation.  They have finally paid an amount of Rs.6,96,718/- on 25-9-2013 through NEFT (National Electronic Fund Transfer) to the account of the complainant, which is as per the standard norms of the policy and the terms and conditions and if the complainant has any grievance he has to file a suit by placing all the material before civil court and prove the same under standard procedure of evidence Act.   Since the damage to the birds was not covered under the policy they have not paid any compensation on the same but they have paid all the eligible amounts as per the standard norms under the policy without any deviation and in terms of the assessment and recommendation of the qualified surveyor. 

The surveyor in his report underlined the following about the insured and the estimate of the loss for settlement of compensation: 

1. The insured Sri Y.Pydi Naidu got good reputation in the market for his quality services for the last 5 years as they have got poultry farms of Suguna Brand. 

2)  The insured took a standard fire and special perils policy with the New India Assurance Company Limited, Divisional Office at Coimbatore in Tamil Nadu.

3) Fire Accident occurred in the poultry sheds and damaged the property but they immediately called the Fire brigade who came and controlled fire and in the meanwhile total property gutted into ashes. 

4)  It was revealed that the fire originated from the electrical wires from the mains in the poultry Farm and got short circuit which is propagated to near poultry Farm six sheds and one shed of store room made out of thatched leafs completely burnt during the above fire accident and it took 2 hours by the fire brigade to control the fire. 

5) the major loss to the insured property is the poultry Farm six sheds and one small shed for feed of storage for birds and the plastic machinery inside the shed completely gutted.

6) On enquiry with local people and employees details of stocks, items and its operation have been verified for its satisfactory operation and maintenance prior to the fire accident.

7) the sheds are completely burnt because of dry wood and as it is     peak summer and dry and old thatched leaf roof which is vulnerable for fire.

8) The loss adjustment and assessment of loss has been made as per present market rates based on local market enquiry subject to other policy terms and conditions.

9) It was noticed that the main electrical supply from grid pole to poultry shed mains near the thatched sheds which is in continuous    operation caused the insulation failure and in turn it produced sparks could catch fire.  The sparks might have fallen on dry thatched leafs could catch fire.  As per his opinion, the loss of property is due to fire as a result of electric short circuit and it is within the insured peril.

In conclusion the surveyor opined that the insured sustained damages to their property due to fire accident, which is covered under standard fire and special perils policy and the policy was in force as on the date of loss and hence he estimated the loss sustained as per prevailing market rates and information given by the insured in the utmost good faith.

As per the Fire service attendence certificate issued by the Fire station, Cheepurupalli, the cause of fire accident expected as “Electrical short circuit” and in this accident 9 poultry Farm sheds, four thousand production birds are burnt out and feeding material of the birds also destroyed

Now the point for consideration is whether there is deficiency of service on the part of 1^st and 2^nd O.P and also 3^rd and 4^th O.Ps ? 

From the entire material placed on record it is evident and established that the O.P.1 settled the claim for compensation as per the terms and conditions of the insurance policy and also based on the detailed report of the qualified and competent surveyor who assessed the damage as per the present market rates as is done in such type of cases.  In support of their assessment and settlement, the O.Ps have cited the following judgments:

First appeal No.673 of 2007 (Against the order dt.4-10-2007 in C.C.No.6/05 of Rajastan State Commission, Jaipur) by Hon’ble National Commission.

It is well settled through a catena of judgments of this Commission as also of the Hon’ble Supreme Court (New India Assurance Co.Ltd. V.Rohan Lal Oil Mills (2010)10 SCC 19) that the Surveyor’s report has significant evidentiary value and cannot be displaced unless it is contradicted by credible evidence to the contrary.  So far as the present case is concerned, after carefully perusing the entire evidence on record, we are unable to conclude that the Appellant has been able to produce any credible documentary or other evidence to contradict the report of the second surveyor clearly giving detailed reasons for assessing the loss at Rs.22,11,824/-.

The Surveyor report in the present case is valid and the complainant failed to contradict it by placing any credible documentary or other evidence.  So, the 1^st O.P settled the claim of the complainant as per the recommendation of the surveyor.  The complainant has insured the subject property for less than the amount required to be insured. So, an amount of Rs.67,399/- was deducted @ 9.66% on building by the surveyor by applying pro-rata formula from the building loss head and he also deducted depreciation in accordance with standard procedure.  The act of the surveyor in deducting the under insurance and depreciation is nothing wrong and it was in accordance with terms and condition of policy and the same was recognized by position of law prevailing on the subject as on today.  The same was confirmed by the Supreme Court of India in the following decision reported in:

2010(4) ALT 23.1 (DN SC) 2009 (5) SCJ 661 : 

Consumer Protection Act, 1986          , Section 23 – Insurance claim – Diesel generating set along with alternator purchased by complainant for Rs.45,25,000/- was insured for a period of one year for Rs.35,00,000/- - Said diesel generating set broke down – complainant paid Rs.25,00,000/- to the repairers – Case of complainant that the Insurance Company reimbursed Rs.8,07,110/- only – complaint – National Commission directed the insurer to pay to the complainant an amount of Rs.10,47,491/- along with interest at 12% p.a., - Appeal by complainant – Held, the policy did not provide for protection against wear and tear that the machinery had undergone and that the insured may have chosen to replace – Parts, which had suffered due to wear and tear on account of constant use, although replaced, could not form part of claim for reimbursement under the terms of the policy – Therefore, the surveyor, in his report, cannot be said to have wrongly rejected the claim – The policy provides that, if the sum insured is less than the amount required to be insured, the insurer will pay only in such proportion as the sum insured – In accordance with the said provision in the policy, if the surveyor applied the pro-rata formula and deducted 25.71% from the loss so assessed i.e., Rs.3,71,509.50 from the sum payable as under –insurance, such deduction cannot be faulted – National Commission did not commit any error in accepting the surveyor’s report, as the assessment made therein is proper and in accordance with the provisions of the policy – Order of National Commission does not suffer any legal flaw justifying interference – Appeal dismissed.

Hon’ble Supreme Court of India in the following decision reported in 2013 (1) ALT 56 (SC).  Export credit guarantee corpn.of India Vs M/s Garg sons international.

          The following three aspects were confirmed by the apex court:

          Quotable point:

(1) Insurance Policy  -  The insured cannot claim anything more than what is covered by the insurance policy.

2)  Contract must be read as a whole – The contract must be read as whole and every attempt should be made to harmonize the terms thereof.

3) Endeavour of the court – The endeavour of the court should be always be to interpret the words used in the contract in the manner that will best express the intention of the parties.

          The principles laid down in the above citations reiterates that survey’s report has significant evidentiary value, which cannot be displaced unless it is contradicted by credible evidence to the contrary.  But in this case the complainant simply contradicted the assessment of the surveyor and settlement procedure of the insurance company and had not submitted any documentary evidence.  Also he did neither appoint any surveyor on his own nor produced any other material evidence to prove his contention or in order to negate the basis of the estimation of the surveyor appointed by the insurance company. 

          Further the assessment made by the surveyor of the Insurance company cannot be simply rejected or modified without any scientific basis from the complainant.  It is also evident that the said surveyor has taken into consideration of all the aspects governing the basis for estimation and settlement of compensation, which seems to be a comprehensive approach.

          It is also clear from the material available on record that the complainant obtained insurance policy from the Divisional office at Coimbatore and the claim was settled by the Visakhapatnam office of the said insurance company where as O.Ps 1 and 2 have not their office within the jurisdiction of this Forum.  Hence as per the provisions of the Consumer Protection Act with regard to jurisdiction, the complaint cannot be entertained in this Forum.

          Since there is no deficiency on the part of 1^st and 2^nd O.Ps as they have settled the compensation with regard to the claim within a reasonable time as per the basis being arrived at by a qualified and    competent surveyor appointed by them and since there is no credible evidence to the contrary from the complainant and there is no jurisdiction, the complainant is liable to be dismissed.  With regard to the complaint against 3^rd and 4^th O.Ps it is to be stated that since the complainant has not filed a separate complaint against them and only common complaint is filed against all the 4 O.Ps, even though the cause of action differs among them, the complaint cannot be entertained by this Forum.  The 1^st and 2^nd O.Ps in the counter as well as subsequent arguments pleaded that the complainant under a grab of deficiency of service is challenging the assessment of the surveyor by filing a false and motivated claim, which is not valid under law and if the complainant has any grievance of whatsoever he may file a suit by placing all the material before Civil Court and prove the same under standard procedure of evidence Act, as the complainant is not entitled to invoke the provisions of Consumer Protection Act since they are doing poultry business on commercial basis.

          Under all the above circumstances we are of the well considered opinion that the complaint merits no consideration in this Forum.

          In the result, the complaint is dismissed but under the circumstances without costs.

Dictated to the Typist, transcribed by her, corrected by me and pronounced by us in the open Forum, this the 21^st day of October, 2014.

     Member                                                                        President.

C.C.No.72 of 2013

APPENDIX OF EVIDENCE

WITNESSES EXAMINED

For complainant:-                                          For opposite parties:-

        PW 1.                                                               RW 1.

DOCUMENTS MARKED

For complainant:-

1. Ex.A.1 Loss of estimation dt.13-4-2013
2. Ex.A.2 Service attendance certificate by fire department

           dt.12-4-2013

1. Ex.A.3 Certificate issued by the RECS, Chipurupalli dt.20-5-2013
2. Ex.A.4 Policy copy by issued 1^st OP dt.12-1-2012
3. Ex.A.5 Bank Account of the complainant dt.25-9-2013
4. Ex.A.6 Sakshi Paper cutting dt.13-4-2013
5. Ex.A.7 Lawyer Notice dt.8-11-2013
6. Ex.A.8 Electricity bill dt.14-2-2012
7. Ex.A.9 Photographs of damaged poultry farm.

For O.Ps. :-   

1. Ex.B.1 Policy with terms and conditions dt.1-10-2012
2. Ex.B.2 Surveyor report with documents dt.15-6-2013
3. Ex.B.3 Panchayati Resolution dt.17-5-2007
4. Ex.B.4 Lawyer notice dt. 2-11-2013                                                                                                                                                           
5. Ex.B.5 Paper cutting

President.