IN THE CONSUMER DISPUTES REDRESSAL COMMISSION, ALAPPUZHA
Monday the 17th day of April, 2023.
Filed on : 08.12.2022
Present
- Sri.S.Santhosh Kumar BSc.,LL.B (President )
- Smt. P.R.Sholy B.A.L, LLB (Member)
In
CC/No.311/2022
between
Complainant:- Opposite party:-
Sri.Bipin Babu The New India Assurance Co.Ltd.
Kairali House Rep.by its Divisional Manager
Pathiyoor East Muri Divisional Office, J&J Avenue
Pathiyoor P.O. VCSB Road, Alappuzha-688011
Keerikkad Village (Adv.P.S.Ramu)
Alappuzha
(Adv.Nishamol.S)
O R D E R
SRI. S.SANTHOSH KUMAR (PRESIDENT)
Complaint filed under Sec.35 of the Consumer Protection Act, 2019.
Material averments briefly stated are as follows:-
Complainant is the registered owner of Tata Nexon motor car bearing registration No.KL 29 S 6009. The vehicle was insured with the opposite party for own damage with effect from 06.11.2020 to 05.11.2023.
2. On 20/03/22 at about 8.45 PM the vehicle met with an accident at Pathiyoor- Bhagavathipadi road near Bhagavathipadi canal and sustained damage to the front bumber, T-Emblem, front fender LH, front grill, winding glass front, rear LH, rear glass and rear spoiler of the vehicle. The accident was immediately reported to Kareelakulangara Police Station and to the opposite party. On the next day the vehicle was brought to M/s Focuz Automobile services Pvt.Ltd. who is the authorised service center of TATA motors and on 23.03.22 complainant received GD entry and produced the same before showroom. The investigators of the opposite party surveyed the vehicle and submitted report stating that the vehicle was damaged in the said accident. However on 07.10.22 opposite party disallowed the claim on the sole ground that there are certain mismatches on the inspection photos of the damaged vehicle submitted by the surveyor and the pre-acceptance break inspection photos of the said vehicle. Apparently, there were no such mismatches as claimed by the opposite party and even otherwise it is not a valid ground for rejecting the claim of the complainant since the vehicle had a valid insurance at the time of accident.
3. On 05.11.22 complainant issued a legal notice to the opposite party. Opposite party received the notice on 10.11.22 and sent a reply notice refusing to reconsider their decision.
4. Since the opposite party had rejected the claim of the complainant he had to spent Rs.3,12,783/- as expenses for fixing the damages to the vehicle. Opposite party had rejected the claim of the complainant on technical ground and in a mechanical manner. The vehicle was duly insured with the opposite party and it was damaged in an accident. Thus as a service provider opposite party is legally bound to indemnify the complainant for the loss caused to him in the accident. The claim was rejected without any valid reason and it amounts to unfair trade practice.
5. Complainant is entitled to get Rs.3,12,783/- from the opposite party and is also entitled to realise an amount of Rs.2 lakhs as compensation on account of mental agony and inconvenience.
6. Opposite party filed a version mainly contenting as follows:-
The complaint is not maintainable either in law or on facts. It is premature in nature as this opposite party had not rejected the claim. There is no deficiency of service or unfair trade practice from the part of this opposite party. Complainant has approached this Commission with unclean hands.
7. Complainant had violated all legal principles and statutory obligations by suppressing and misrepresenting the material facts, committed cheating, dishonest misappropriation of property, criminal breach of trust, forgery and using the insured vehicle in question in the case violating the provisions of Indian Motor tariff, Motor Vehicles Act and Rules framed there under. The insurance policy in question was availed from this opposite party by cheating, forgery and misappropriation of property. The alleged damage, loss of the vehicle will not come under the preview of insurance policy as the alleged loss was occurred before the issuance of insurance policy. The case in hand involves intricate questions of facts and law, which require voluminous evidence, oral as well as documentary, to be lead for proper adjudication of the matter. Hence it is not possible to decide the complainant under summary procedure. A detailed investigation is underway by the Kareelakulangara Police station authorities as directed by the District Police Chief Alappuzha regarding the offences committed by the complainant.
8. The vehicle was previously insured with M/s Oriental Insurance Co.Ltd. for a period of 3 years bundled policy for own damage for a period from 06.11.2020 to 05.11.2021 (1 year) and 3rd party liability only for a period from 06.11.2020 to 05.11.2023 (3 years). The own damage policy coverage of the vehicle ends on 05.11.2021 and on 02.03.2022complainant had availed an insurance policy for the period from 02.03.2022 to 01.03.2023 from the Mavelikkara branch of this opposite party. The policy was availed through an agent / intermediatory of this opposite party Sri.Anil S. The said policy was issued after a long breakage from the previous policy for a period of 117 days. Sri.Anil S had forwarded the proposal along with his pre inspection report recommending for issuance of fresh own damage policy believing the statements of the complainant and placing credence of the agent and this opposite party had issued the policy.
9. While this opposite party was conducting enquiries regarding the pre inspection photos forwarded by the agent the complainant had submitted a claim on 24.03.2022 stating the damage to the insured vehicle. The accident was not immediately intimated to this opposite party and the intimation was received on 20.03.2022.
10. On receipt of the claim this opposite party deputed an independent IRDA licensed surveyor and loss assessor Mr. K S Abhilash to conduct survey and assess the loss. Surveyor conducted detailed survey and assessed the damages and filed report dated 25.05.2022. On verification of the insurance policy the surveyor found that there was breakage of policy as the previous insurance policy issued by M/s Oriental Insurance Co.Ltd. towards own damage coverage was for a period from 06.11.2020 to 05.11.2021. After a break of 4 months and 16 days complainant had availed the present policy from this opposite party. On comparing the photos uploaded at the time of policy by the agent with photos taken at the time of inspection surveyor found certain differences. The extent of damages in the vehicle was not tallying with the cause and description of the accident and so he had recommended for a thorough investigation before processing the claim. Hence this opposite party appointed an independent investigation agency M/s Intense Ancillary Services LLP and he filed a report on 29.06.2022 from which it is revealed that there was some discrepancies regarding the cause of alleged accident. The extent of damages does not corroborate with the case and description of the accident as narrated in the claim form.
11. There is gross suppression of material facts with regard to the accident. The insurance policy was availed by fraud, dishonest, misappropriation of property, criminal breach of trust, forgery in collision with the agent of opposite party Sri.Anil. Hence this opposite party had issued letter dated 06.07.2022, 19.07.2022, 29.07.2022 and 25.08.2022 to the complainant for clarifications. This opposite party had filed a complaint on 22.08.2022 before the District Police Chief Alappuzha for cheating, misappropriation of property, criminal breach of trust, forgery etc. It was registered as petition No.58847/2022/A and directed the SHO, Kareelakulangara Police station to conduct detailed investigation and it is underway.
12. The averment that this opposite party had rejected the claim is not true and it is treated as no claim. There is no deficiency of service from the part of this opposite party. The claim was processed by this opposite party considering survey report and investigating report. Complainant is not entitled to get Rs.3,12,783/- and Rs.2 lakhs as compensation. The complaint is devoid of merits and hence it may be dismissed with compensatory cost.
13. On the above pleadings following points were raised for consideration:-
- Whether the policy was obtained fraudulently as alleged?
- Whether there is any unfair trade practice and deficiency of service from the part of opposite party as alleged?
- Whether the complainant is entitled to realise an amount of Rs.3,12,783/- along with interest from the opposite party as prayed for?
- Whether the complainant is entitled to realise an amount of Rs.2,00,000/- as compensation from the opposite party as prayed for ?
- Reliefs and costs?
14. Evidence in this case consists of the oral evidence of PW1 and Ext.A1 to A10 from the side of the complainant and the oral evidence of RW1 to RW3 and Ext.B1 to B6 from the side of the opposite party. Ext.X1 series were produced by RW1 and Ext.X2 series were produced by RW2.
15. Point Nos.1 to 4
PW1 is the complainant. He filed an affidavit in tune with the complaint and marked Ext.A1 to A10. During cross examination Ext.B1 & B2 were marked.
16. RW1 is an IRDA approved independent surveyor. On 24.03.2022 he surveyed the vehicle bearing KL 20 S 6009 and prepared a survey report. It is marked as Ext.X1 series. He requested the company to investigate regarding the genuineness of the policy. The policy was not renewed for about 3 months. The previous policy issued by M/s Oriental insurance company expired on 05.11.2021 and the policy was renewed on 02.03.2022. If there is any break pre inspection is necessary. Since the policy is issued online, photos will be uploaded. The photos are marked as Ext.X1 (a) and the photos taken by him were marked as Ext.X1 (b). On a comparison of Ext.X1 (a) and Ext.X1 (b) there were differences. As per the survey report he had assessed an amount of Rs.2,88,013/-.
17. RW2 is an insurance investigator. On 26.05.2022 opposite party entrusted him to conduct an investigation with respect to vehicle No.KL 29 S 6009. Though the accident had occurred there was no consensus regarding the date. One of the person told him that the accident occurred on 28.02.2022. He conducted the investigation on 07.06.2022 and the report is marked as Ext.X2 series. He had also taken photographs and it is marked as Ext.X2 (a). X2 (b) are the photograph taken after comparing the pre-inspection photos and the photos taken by surveyor. There were certain differences in the photographs. As per the claim form the date of accident was on 20.03.2022. From his investigation it was revealed that policy was taken using a different car and the claim was filed with a different date.
18. RW3 is the Divisional Manager of the opposite party. She filed an affidavit in tune with the version and marked as Ext.B3 to B6.
The substance of the evidence is discussed above. PW1 , the complainant is the registered owner of TATA Nexon motor car bearing Reg. No. KL-29-S-6009. As per Ext.B1 motor insurance certificate cum policy schedule he insured the vehicle with M/s Oriental Insurance Co. Ltd. Own damage policy was for a period of one year from 6/11/2020 to 5/11/2021 and the liability policy was for a period of three years from 6/11/2020 to 5/11/2023. Later as per Ext.A2 policy the own damage policy was renewed for a period of one year from 2/3/2022 to 1/3/2023. While so on 20/3/2022 the car met with an accident and sustained heavy damage. The matter was intimated to Kareelakulangara police station and Ext.A3 copy of General Dairy was obtained to prove the accident. The matter was immediately informed to the opposite party M/s New India Assurance Co. Ltd from where Ext.A2 policy was taken. On getting policy opposite party appointed RW1 IRDA approved independent surveyor. He inspected the vehicle on 24/3/2022 and prepared Ext.X1 series report. However he recommended for an investigation regarding the genuineness of the policy since there was a breakage for the policy. Accordingly RW2 an investigator was appointed and after investigation he filed Ext.X2 series report, on a contention that there is no consensus regarding the date of accident. He had some doubt that the policy was taken after the accident uploading the photographs of a different vehicle of same model. Opposite party informed the matter to the District Police Chief through Ext.B5 complaint . Certain letters were sent to the complainant regarding clarifications. The policy was not honoured and as per Ext.B6 letter dtd. 7/10/2022 the claim was closed treating the claim as ‘NO CLAIM’. Aggrieved by the same the complaint is filed for realizing an amount of Rs. 3,12,783/- along with interest being the amount spend for repairs and Rs. 2 lakhs along with interest as compensation on account of deficiency of service. Opposite party filed a version admitting the policy. However according to them since RW1 surveyor requested to make an investigation regarding genuineness. RW2 investigator was appointed. RW1 and RW2 took photographs of the vehicle and noticed some difference with the photographs which were uploaded at the time of availing Ext.A2 policy. According to them there was a policy fraud and so a complaint was filed before the District Police Chief on 22/8/2022. Though letters were issued seeking clarifications it was not answered properly. Hence the claim was treated as ‘NO CLAIM.’ According to them there is no reason to interfere and hence prayed for dismissal of the complaint. Complainant got examined as PW1 and marked Ext.A1 to A10. During the cross examination of PW1 Ext.B1 and B2 were marked. RW1 to 3 were examined from the side of opposite party and Ext.B3 to B6 were marked. Ext.X1 series were marked through RW1 and Ext.X2 series were marked through RW2. Relying upon the evidence on record the learned counsel appearing for the complainant contended that the complaint is proved as per law and so the complainant is entitled to get the reliefs claimed in the complaint. It was pointed out that on the date of accident ie, on 20/3/2022 there was a valid policy issued by the opposite party and so there is no reason to repudiate the claim. Per contra the learned counsel appearing for the opposite party pointed out that immediately on getting the claim application a surveyor was deputed. On inspection it was noticed that there was a breakage of policy. Ext.B1 policy was up to 5/11/2021 and Ext.A2 policy was taken only on 2/3/2022. There was a brake of policy for about 3 months. It was also pointed out that the policy was renewed on 2/3/2022 and immediately after 18 days the accident occurred. Since the surveyor suspected about the genuineness an investigator was appointed. He also noticed some differences with regard to the photographs uploaded at the time of availing Ext.A2 policy and the present condition of the vehicle. It was contended that Ext.A3 General Dairy was obtained fraudulently and Ext.B5 complaint was filed before the District Police Chief which is under investigation. Hence according to the learned counsel there was no deficiency of service from the part of opposite party since the policy was obtained fraudulently and so that investigation is pending the complainant is not entitled for any relief sought. In support of the contentions he relied upon the ruling of the Hon’ble National Consumer Disputes Redressal Commission in National Insurance Co. Ltd. Vs. M/s Krishna Spico Industries dtd. 20/7/2020, the decision of the Hon’ble Supreme Court in Ravneet Singh Bagga vs. Klm Royal Dutch Airlines and Anr. ( 1999 AIR SC 4223) and the decision of the Hon’ble Supreme Court in The Chairman & Managing Director, City Union Bank Ltd & Anr. Vs. R. Chandramohan dtd. 27/3/2023 in Civil Appeal No. 7289 of 2009.
19. As per Ext.A1 Registration Certificate on. 10/12/2020 PW1 registered his car TATA Nexon XE 1.2 RTN BS VI with registration number KL.29-S-6009. Ext.B1 is the 1st policy taken from M/s Oriental Insurance Co. Ltd. As explained by RW3 the Divisional Manager of the opposite party insurance companies used to issue bundled policies on long term basis for a period of 5 years for two wheelers and for a period of 3 years for private cars. Though the 3rd party liability is for 5 years and 3 years respectively the own damage and PA cover is only issued for a period of one year. In other words own damage policy and PA cover is to be renewed every year. As per Ext.B1, liability policy is for a period of three years from 6/11/2020 to 5/11/2023 and the own damage policy is for a period of one year from 6/11/2020 to 5/11/2021. Thereafter PW1 renewed the own damage policy for a period of one year from 2/3/2022 to 1/3/2023 as per Ext.A2 with the opposite party M/s New India Assurance Co. Ltd. As rightly pointed out by the learned counsel appearing for the opposite party there is a break of policy. As per Ext.B1 the policy ended on 5/11/2021 and the renewal was made only on 2/3/2022. There is a gap of about 4 months for renewing the policy which is exactly 116 days. While Ext.A2 policy was inforce the accident occurred on 20/3/2022 by which extensive damage was caused to the vehicle. Though it is not relevant interestingly it is noticed that as per Ext.A1 registration certificate the model of the vehicle is TATA Nexon XE1.2 RTN BSVI whereas the model noted in Ext.B1 policy issued by M/s Oriental Insurance Co. Ltd is TATA Nexon XZA+ 1.2 RTN BSIV. It is also noticed that as per Ext.A1 the fuel used is petrol where as Ext.B1 it is stated that the type of fuel is Diesel. However in Ext.A2 policy issued by the opposite party the variant and the type of fuel used is matching with Ext.A1 registration certificate. Now the case of PW1 is that on 20/3/2022 at about 8.45PM while he was driving the vehicle the accident occurred by which the vehicle fell into the drainage by the side of Pathiyoor-Bhagavathipadi Road. To prove the accident PW1 is relying upon Ext.A3 copy of General Dairy issued by the Sub Inspector of Police, Kareelakulangara Police Station. Through the Chief affidavit of PW1 Ext.A1 to A10 were marked. Out of which Ext.A3, Ext.A9 and Ext.A10 were marked subject to proof. Ext.A3 is the copy of General Dairy, Ext.A9 is the bill issued by M/s Focus Automobiles Services Pvt. Ltd and Ext.A10 is the cash receipt issued by M/s Focus Automobiles Services Pvt Ltd. Though Ext.A3, A9 and A10 were marked subject to proof no attempt is seen made by the complainant to examine the respective witness who issued these documents. This attained significance since the date of accident is disputed by the learned counsel appearing for the opposite party. It was pointed out that as per Ext.A2 insurance was taken on 2/3/2022 after a gap of 116 days from the previous policy and on the 18th day ie, on 20/3/2020 the accident occurred. It was also pointed out that regarding Ext.A3 General Dairy the senior Divisional Manager of opposite party filed Ext.B5 complaint before the District Police Chief, Alappuzha and it is pending enquiry. As held by the Hon’ble High Court in PRS Hospital (M/s), Thiruvananthapuram and Anr Vs. P. Anil Kumar (2021 KHC 1)
“There are four stages before a Court of law can rely upon a document. They are (i) marking of a document, (ii) admissibility of a document, (iii) proof of contents of the document and (iv) evaluation of the document. Reliance upon a document can be made by the court only if all the above four stages are complied with or satisfied. By the mere marking of a document, it does not become admissible in evidence. Further, the marking of a document and being admissible in evidence, will still not render the contents of a document as proved. When a document, admissible in evidence, is marked, still to be relied upon by the courts, its contents will have to be proved. For the contents of a document to have a probative value, the person who wrote the contents or is aware of the contents and its veracity must be invited to give evidence about it. It is thereafter the last stage ie, evaluation takes place. Evaluation of the document is a judicial exercise. Unless all these stages are done, a court of law cannot rely upon any document produced or marked before it.”
20. Here in this case as stated earlier Ext.A3, A9 and A10 were marked subject to proof and no attempt was made by complainant to prove the same by examining the witnesses who issued the same. Since the date of accident is seriously disputed it was incumbent upon the part of complainant to prove Ext.A3 General Dairy by examining the witness who issued the same. It is not seen done for the best reason known to the complainant.
21 Immediately after the accident complainant filed a claim petition before the opposite party and they appointed RW1 an IRDA approved independent surveyor. He inspected the vehicle on 24/3/2022 and prepared Ext.X1 series survey report. RW1 stated that at the time of survey he had some doubt and so he recommended to investigate regarding the genuineness of the policy. He clarified that the earlier policy expired on 5/11/2021 and it was renewed only on 2/3/2022. Immediately after 18 days the accident occurred. Ext.A2 policy was renewed through an agent by name Mr. Anil and at the time of renewal the photographs of the vehicle were uploaded. Opposite party had sent said photographs to RW1 and he has produced the same along with Ext.X1 and it was marked as Ext.X1 (a) series. The photo graphs taken by RW1 at the time of survey was marked as Ext.X1(b) series. According to RW1 on a comparison of Ext.X1(a) photographs with Ext.X1(b) photographs he had noticed certain differences. The difference such as colour difference of the handles, certain stickers, difference of wheel cover are not relevant. However he had noticed a serious difference with respect to vehicle identification sticker affixed on the front glass. Ext.X1(a) photograph such a sticker was not available whereas it was available in Ext.X1(b). Further according to RW1 from 2016 onwards high security number plates are issued to the vehicles and it is riveted to the vehicle so as to avoid misuse. In Ext.X1(b) photograph the number plate was riveted whereas in Ext.X1(a) it was fixed using nut and bolt. It is to be remembered that as per Ext.A1 registration certificate the vehicle was purchased during 2020 and so normally the number plate ought to have been riveted. It is a suspicious circumstances with regard to the change of vehicle at the time of availing insurance policy as per Ext.A2 by uploading the photographs. On the basis of the recommendation of RW1, RW2 an investigator was appointed by the opposite party. On 7/6/2022 he conducted investigation and prepared Ext.X2 series report. Though the accident was confirmed there was no consensus regarding the date of accident. According to RW2 one of the party present at the spot stated that the accident occurred on 28/2/2022. On a reading of the evidence of PW1 also it is seen that he has no consistent case with regard to the date of accident. He filed chief affidavit stating that the accident occurred on 20/3/2022 at 8.45 PM. However during re-examination he stated that the accident occurred on 20/2/2022 and on the same day the matter was informed to the police and after examining the vehicle on the next day they issued Ext.A3 GD entry on 23/2/2022. If the accident occurred on 20/2/2022 the vehicle had no valid policy since Ext.A2 was issued only on 2/3/2022.
22. Ext.X2 (a) are the photographs taken by RW2 and Ext. X2(b) are the photographs taken by surveyor and pre-inspection photos. He had noticed 10 differences in the photographs out of which 1 and 2 are significant. There was high security number plate affixed in the glass in the photograph taken by RW1 whereas it was not available in the pre-inspection photograph. There was distance variation in the fastag affixed in the front glass. The other differences can be done by the owner of the vehicle without any permission from any authority. The conclusion arrived by RW2 is that Ext.A2 policy was taken using some other car and photographs of the said car was uploaded for availing the policy. Though during cross examination the learned counsel appearing for the complainant put a question that the number plate was removed at the time of accident such a possibility was denied by him. So on a combined reading of the evidence tendered by RW1 and RW2 coupled with Ext.X1 and X2 report it can be seen that as rightly pointed out by the learned counsel appearing for the opposite party it is an insurance fraud. As stated earlier Senior Divisional Manager of the opposite party had filed Ext.B5 complaint before the District Police Chief Alappuzha and the petition was numbered as 58847/2022/A and it is under investigation by the Station House Officer, Kareelakulangara Police Station.
23. It was pointed out by the learned counsel appearing for the opposite party that certain clarifications were sought from the complainant and satisfactory answers were not given and so it is treated as ‘NO CLAIM’. In other words there was no repudiation of the claim. If complainant gives satisfactory answers it can be processed at any time. From the discussions made above it is crystal clear that there is some doubt regarding the availing of Ext.A2 policy. As discussed earlier Ext.B1 policy was only upto 5/11/2021 and it was renewed as per Ext.A2 on 2/3/2022 after a gap of about 116 days. The policy was renewed on 2/3/2022 and on the 18th day ie, on 20/3/2022 the accident occurred. To prove the date of accident there is no convincing evidence. Ext.A3 GD was marked subject to proof and no attempt was made to examine the Sub Inspector of Police who issued the GD entry. In re-examination PW1 stated that the accident occurred on 20/2/2022 whereas in the chief affidavit the date of accident is stated as 20/3/2022. As held by the Hon’ble Supreme Court in The Chairman and Managing Director, City Union Bank Ltd & Anr Vs. R. Chandramohan (Civil Appeal No. 7289 of 2009) dtd. 27/3/2023
“The proceedings before the Commission being summary in nature, the complaints involving highly disputed question of facts or the cases involving tortuous acts or criminality like fraud or cheating, could not be decided by the Forum/Commission under the said Act. The “deficiency in service” as well settled, has to be distinguished from the criminal acts or tortuous acts. There could not be any presumption with regard to the willful fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance in service, as contemplated in Section 2(1) (g) of the Act. The burden of proving the deficiency in service would always be upon the person alleging it.”
24. Hence assessing the evidence as a whole and applying the principles laid down by the Hon’ble Supreme Court it can be safely concluded that there is a doubt regarding the genuiness of the policy. The break of policy for about 116 days is not satisfactorily explained as opined by RW2 investigator. It is doubtful whether the policy was taken after the accident by producing a different vehicle. RW3 the Divisional Manager has stated that after this incident they are not availing the services of Sri. Anil.S who has issued Ext.A2 policy. Since opposite party had alleged fraud in availing the policy and so that investigation is pending with regard to the genuiness of Ext.A3 GD entry, no order can be passed in favour of the complainant and so the complaint is only to be dismissed.
25. Point No.5
In the result complaint is dismissed. Parties are directed to bear their respective costs.
Dictated to the Confidential Assistant, transcribed by him corrected by me and pronounced in open Commission on this the 17th day of April, 2023.
Sd/-Sri.S.SanthoshKumar(President)
Sd/-Smt.P.R.Sholy (Member)
Appendix:-Evidence of the complainant:-
PW1 - Sri.Bipin Babu (Complainant)
Ext.A1 - Copy of RC book
Ext.A2 - Copy of policy schedule cum certificate of insurance
Ext.A3 - Copy of general diary
Ext.A4 - Copy of registered letter dtd.07.10.2022
Ext.A5 - Registered notice with AD
Ext.A6 - Postal receipt
Ext.A7 - AD card
Ext.A8 - Registered letter dtd.10.11.2022
Ext.A9 - Copy of invoice
Ext.A10 - Cash receipt dtd.16.07.2022
Ext.X1 series - Motor survey report
Ext.X2 series - Private and confidential investigation report
Evidence of the opposite parties:
RW1 - Sri.Abhilash.P (Witness)
RW2 - Sri.Jinson George (Witness)
RW3 - Smt.Sangeetha.M (Witness)
Ext.B1 - Copy of motor insurance certificate cum policy schedule
Ext.B2 - Copy of motor claim form
Ext.B3 - Policy schedule cum certificate of insurance
Ext.B4 - Copy of letters and AD card
Ext.B5 - Letter to District Police chief, Alappuzha
Ext.B6 - Letter dtd.07.10.2022
///True Copy ///
To
Complainant/Oppo.party/S.F.
By Order
Assistant Registrar
Typed by:- Sa/-
Comp.by:
