Wednesday, October 16, 2024

Brief Notes of Argument ob behalf of the Consumer Complainant in Consumer Case

 

District : South 24 Parganas.

Before the Hon’ble District Consumer Disputes Redressal Forum, at Alipore, South 24 Parganas.

                                                         

Complaint Case no. 500 of 2013.

                                                         

In the matter of :

Madar Molla,                  __________Applicant / Petitioner.

 

-          Versus –

 

The Station Manager, Bhangore Group Electric Supply, West Bengal Electricity Distribution Company Limited, and anr.

_____Respondents / Opposite Parties.

Brief  Notes Of Argument

On behalf of the Complainant

 

1.   That your petitioner had applied for New Electric Connection, to the respondent / opposite party no.1, vide application under form Annexure – A, being Application Sl. No. BGS / 1483, dated 18-02-2009,  which has been obtained by your petitioner on  paying Rs.10/- ( Rupees Ten ) only, thereof, and whereas your petitioner  applied for domestic electric services / connection for the expected electric load of 0.5 KW, and thereby depositing of Rs.200/- ( Rupees Two hundred ) only, as earnest money as he was asked for by the respondent no.1, herein, and whereas the respondent / opposite party no.1, have given and discharge proper money receipts thereof to your petitioner .

 

2.   That thereafter the respondents officials cause inspection over the premises of your petitioner, and thereby stating such facts, the respondent / opposite party no.1, issued one Quotation being no. BGS/4/2044, dated 11-06-2009, in reference to the application no. BGS / 1483, dated 18-02-2009, to your petitioner, for an amount of Rs. 835/- ( Rupees Eight Hundred and Thirty Five ) only, describing as Service Connection Charges as of Rs. 185/- ( Rupees One Hundred and eighty five )only, and Security Deposit of Rs. 650/- ( Rupees Six Hundred and fifty ) only, and the said quotation was valid for the period of sixty days from the date of issue, as stated by the respondent / opposite party no.1, therein.

 

3.   That your petitioner had paid the requisite amount as was asked for under the Quotation being no. BGS/4/2044, dated 11-06-2009, as on 23-07-2009, and thereafter the respondent / opposite party no.1,  had  given the proper receipts thereof for such amount and taken signature on some papers, allegedly called as an Agreement, and the respondent / opposite party no.1,  state such facts on the page of the said quotation, that the agreement executed on 23-07-2009.

 

4.   That your petitioner had  have complied therewith all the formalities and payments as was asked for though the respondent no.1,  did not provide and or give the services of the electric energy at the premises of your petitioner.

 

5.   That your petitioner visited the office of the respondent / opposite party no.1, on several occasions, with a request to get electricity connection at the earliest, and whereas the respondent / opposite party no.1, did assure to provide such electricity connection at the earliest to your petitioner, though he did not provide such connection.

 

6.   That your petitioner had made written representation as on 11-08-2009, addressed to the respondent / opposite party no.1, herein, which has been duly receipt and acknowledged by the said respondent, though the respondent / opposite party no.1, did not heed to act in accordance with the law as to provide electricity connection to your petitioner, at the premises of your petitioner.

 

7.   That your petitioner served one Notice, stating interalia the facts of your petitioner and request made therein as to complied in accordance with the law i.e. as to provide electricity connection to your petitioner at the earliest, through his Learned Advocate Rabindra Nath Das, vide Ref.: Legal / AP / 1998, dated 3rd day of October’ 2013, upon the respondent / opposite party no.1, as well as supplied copy to the respondent / opposite party no.2, who is the head of the consumer grievance cell for such region of the district south 24 parganas, through Speed Post with A/D, and the said notice has been duly received and acknowledged by them, as appeared from the A/D, card returned  to your petitioner, and as it appears from the Consignment tracking report obtain from the web site of the India Post.

 

8.   That your petitioner states that even after the respondents / opposite parties, are in receipt of the notices of your petitioner, did not heed to answer such notices to your petitioner, and very vehemently did not provide any electricity connection to your petitioner, till date of filling of the present proceedings.

 

9.   That the Respondents appeared in the present proceedings and filed their written version, contended interalia as the quotation money has not been deposited within the validity period and thus such quotation elapsed and due performance of the petitioner failed to get electricity and the money receipt has not been annexed with the petition thus raised suspicion about payment of such quotation money, and therefore in view of such contention the petitioner is not entitled to get electricity.

 

10.                That the Complainant placed his petition to treat his petition of complaint as an Evidence on Affidavit in the present proceedings, which was allowed by the Hon’ble Forum, and thereafter questionnaire and reply of the parties has been complied with.

 

11.                That the Respondents filed their Evidence on Affidavit on the contention as stated earlier in their written version,  and thereafter questionnaire and reply of the parties has been complied with.

 

12.                That Annexure B of the petition of complaint shows that one agreement has been made by the respondents with the petitioner as on 23-07-2009, and the Annexure D shows that on 11-08-2009, it has been intimated by the petitioner to the respondents, that as he went to deposit the quotational amount the respondents officials refused to take, and later no acts and deeds has ever been taken by the respondents to take such deposit of quotation money from the petitioner, and did not provide electricity connection at the premises of the petitioner.

 

 

13.                That all the acts and deeds of the respondents are described as deficiency in essential services of electricity connection to the petitioner.

 

 

14.                That the petitioner is entitled to get relief in terms of his prayer as made in the petition of complaint before the Hon’ble Forum, on making necessary payments to the respondents.

 

 

 

Through _______________

 

 

 

Advocate for the Complainant.

Dated : 25th day of June’ 2014.

Place : Alipore Judges’ Court.

 

No comments:

Post a Comment