BEFORE
THE HON’BLE DISTRICT CONSUMER DISPUTE REDRESSAL COMMISSION |
KOLKATA
UNIT-III (South), West Bengal |
18,
Judges Court Road, Kolkata 700027 |
Consumer Complaint no. 336 of
2022
In
the matter of :
Smt.
Sabita Singh
________Petitioner
-
Versus
–
M/s. Dhani
Loans and Services Limited & Others
_________Respondents
REPLY ON AFFIDAVIT
BY THE PETITIONER
SABITA SINGH
AFFIDAVIT
Affidavit of Smt. Sabita Singh, Wife
of Sri Lallan Singh, aged about 42 years, by faith Hindu, by Occupation
Business, residing at premises being no. 232, Dhalipara, Purba Putiary, Near
Panchanan Play Ground, Police Station – Regent Park, Kolkata – 700093, District
– South 24 Parganas, West Bengal.
I,
the above deponents do hereby solemnly affirm and declare as under :
1.
I am the Petitioner and thoroughly
conversant with the facts and circumstances of the present consumer proceeding
and are competent to swear this affidavit.
2.
I am replying the questionnaire
put forward by the respondents/ Opposite Parties, in the followings;
(a)
Answer of Question
no. 1 - Yes, I have supported documents in that regard. I am enclosing
herewith a copy of Enlistment, for references.
(b)
Answer of Question
no. 2 - I am running the business to earn for my livelihood.
(c)
Answer of Question
no. 3 - Irrelevant question, therefore no comments.
(d)
Answer of the
Question no. 4 - Yes, I have described in details in my
petition of consumer complaint as well as in my Evidence on Affidavit.
(e)
Answer of Question
no. 5 - Bank, Financial Institution, and NBFC, etc. so far my
knowledge is concerned.
(f)
Answer of Question
no. 6 - I do not have any knowledge so far.
(g)
Answer of Question
no. 7 - I do not have any knowledge so far though as acquired NBFCs can issue credit cards, but
these can only be co-branded credit cards with banks. Under the new system, the
NBFCs will be allowed to originate the credit cards and also directly tie up
with Visa or MasterCard or RuPay for processing and transaction back office for
these credit cards. This will ensure that the customer ownership stays with the
NBFCs and they don’t need to share it with banks.
(h)
Answer of Question no. 8 -
The facts related to your query has already
been answered in my petition of consumer complaint.
(i)
Answer of Question no. 9 - I did not receive any welcome kit as marked
as Annexure A of the written version of the O.P. your given annexure –A, is a
manufactured document, since I did not apply in the month of October, and did not
have such card in the month of October’ 2021.
(j)
Answer of Question no. 10 - Its’
does not arise as the same has never been received by me.
(k)
Answer of Question no. 11 - Its’
does not arise as the same has never been received by me.
3.
Answer of Question no. 12 - I beg to says that in the month of January’ 2022, the
respondents herein send a Credit Card namely “Dhani One Freedom Card” having number as
5085070203322359, which valid from 06/21 until end of 06/26, having Credit
limit up-to Rs. 50,000/- ( Rupees Fifty Thousand ) only, to the Petitioner.
Your petitioner started using the said credit card on the following dates and
credits;
a)
18-01-2022 – card
used for Rs. 4,500/-
b)
23-01-2022 – card
used for Rs. 501/-
c)
23-01-2022 – card
used for Rs. 1,035/-
d)
24-01-2022 – card
used for Rs. 5,000/-
e)
25-01-2022 – card
used for Rs. 5,000/-
f)
27-01-2022 – card
used for Rs. 5,000/-
Total - card used for 21,036/- ( Rupees Twenty
One Thousand and Thirty Six ) only.
4.
Answer of Question
no. 13 - I beg to says that using the said Credit Card and accordingly
paying to the respondents, continuously since 5th day of 2022,
up-till 28th day of March’ 2022. Your petitioner paid a total sum of
money as Rs. 23,582/- ( Rupees Twenty Three Thousand and Five Hundred Eighty
Two ) only, to the Respondents.
5.
Answer of Question
no. 14 - I have paid extra money as of Rs. 2,452/- to the respondents,
as the same has been asked for in different heads, etc., whereas the monthly
subscription has been wrongly charged as of Rs. 825/- ( Rupees Eight Hundred
and Twenty Five) only, and other similar amounts as appeared in the statements
of the respondents.
6.
Answer of Question
no. 15 - I am not agree with your
Suggestion. The Card is a Credit Card associated with Rupay.
7.
Answer of Question
no. 16 - I do not understand your query. However my answer being “NOT A
FACT”.
8.
Answer of Question
no. 17 - I have cleared my dues prior to the institution of the present
consumer proceeding, you were charged much more money than the dues to the
card.
9.
Answer of Question
no. 18 - My claim is much
justified in pursuing the documents and facts on record, given by me before the
Hon’ble District Consumer Commission.
10. Answer of Question no. 19 -
After clearing my all dues to the said Card,
as the said card was blocked earlier, prior to clearance of all dues on the
said card, without any information to me. Therefore in such compelling
situation, wherein I was not able to use the said card thus I initiate
cancellation process of the said card only on 28th day of March’
2022.
11. Answer of Question no. 20 -
your suggestion is not acceptable,
as there is sufficient cause of action and accrual of such cause of action to
lodge the present consumer complaint.
12. Answer of Question no. 21 -
No, it’s not true, I lodge
Complaint to get justice.
13. Answer of Question no. 22 - No,
it’s not true, I depose truly on fact and available situations at your behest.
14. That
I beg to says that the facts contained in my consumer complaint or application,
the contents of which have not been repeated herein for the sake of brevity may
be read as an integral part of this affidavit and are true and correct to my
knowledge, and belief.
DEPONENT
Verification
I,
the above named deponents do hereby solemnly verify that the contents of my
above affidavit are true and correct to my best of knowledge and belief and no
part of it is false and nothing material facts has been concealed therein.
Verified this ____________the day of _____________2023, at Kolkata, West Bengal
DEPONENT
Identified by me,
Advocate
Prepared
in my Chamber,
Advocate
Date
: _________________2023.
Place
: Kolkata, West Bengal.
NOTARY
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