Wednesday, October 16, 2024

Written Notes of Argument on Admission Hearing in Consumer Case

 

District South 24 Parganas

Before the Hon'ble district Consumer Disputes Redressal   Forum, at bariupur South 24 parganas

                                                

                                                          Complaint Case no 41 of 2016

                                               In The Matter of :

                                                          Sri Malay Bhattacherjee ,

                                                                   ................Petitioner

                                                           Versus-

                                                          Sri Asit Kumar Mishra and Others

                                                                    ..................Opposite parties

 

Written notes of argument

on admission hearing

 

1) Since the petitioner running his grocery shop for his livelihood, through his proprietorship firm M/s. Triparna Traders and therefore he place his order of the grocery product on being came into the knowledge by the employee of the opposite parties. The petitioner is a consumer under section -2(1)(d) of the consumer protection act 1986.

2) That the petitioner made his advance payment of total values of goods ordered by him to the opposite parties. The opposite parties even after in receipt of such payment   did not deliver the goods ordered by the petitioner, therefore the opposite parties established their acts and deeds of deficiency in services and unfair trade practices.

3) It is patient to state that at First the petitioner came into knowledge about the product and services of the opposite parties on the visit of their employee, who acknowledge about the product and services of the opposite parties to your petitioner at his grocery shop at Charial  Bazar, Budge Budge under the jurisdiction of Budge Budge police station, District South 24 Parganas.

Secondly,  your petitioner placed his order of grocery product to the opposite parties, only on visit of employee of the opposite parties at the shop of your petitioner at chorial bazar, budge budge, district South 24 Parganas.

Thirdly the payment of the value of the product which has been ordered by the petitioner to the opposite parties has been collected by the employee of the opposite parties on his visit at the shop of the petitioner at chorial bazar, budge budge, South 24 Parganas on several occasions.

Fourthly  the employee of the opposite parties visited to the shop of the petitioner at chorial bazar, budge budge South 24 Parganas on several occasion repeatedly and periodically and lastly on 9th day of July 2015 on his such visit, he acknowledge to the petitioner that the opposite parties refuse and neglect to deliver the goods to your petitioner and suggested to take legal recourses against the opposite parties.

                                             In view of the fact that the petitioner never visited the office of the opposite parties rather the employee of the opposite parties visited the shop of your petitioner who takes the order of goods, take the payment of total value of goods, visited the shop on several occasion and acknowledge on his last visit about the refusal and neglect in delivery of goods by the opposite parties, therefore all the acts and deeds pertaining of the opposite parties has been arises and cause of action in its totality   sustained at the shop of the petitioner at chorial bazar, budge budge, South 24 Parganas.

4) Sec 11(2)(c) of Consumer Protection Act 1986, it speaks about the jurisdiction of the district forum as the cause of action wholly or in part arises, in the present case the fact remain shows the cause of action wholly arises in the district of South 24 Parganas, i.e. the shop of your petitioner at chorial bazar, budge budge, South 24 Parganas, therefore the present case is well within the jurisdiction of Hon'ble Forum to adjudicate the present case, in the interest of administration of justice. 

5) This is the case where the petitioner in a consumer and consumer dispute and the cause of action wholly arises at the shop of the petitioner at chorial bazar, budge budge, South 24 Parganas, therefore this is a appropriate case for admission for adjudication, before the Hon'ble Forum.

  6) That the petitioner relied on TATA COFFEE LTD cases of NCDRC, NEW DELHI (RP NO 2475 to 2478 of 2010) decided on 7th March 2014, wherein THE four respondents had filed separate complain before The District Consumer Forum, Bellary, seeking refund and compensation against the revision petitioners. All four complains where allowed by the District Forum and appeals against them have been dismissed by the State Commission by a common order.

In brief as per Hon'ble NCDRC all four complainant are brothers and their complaints have arises from a single transaction of purchase of block board from the respondent. All four used the materials in their respective houses for making of furniture box type wardrobe, tv cabinet, dressing table and other furniture item. The block after sometime where found to be affected by borer infestation. They took up the matter with the vendor/ O.P but did not get appropriate response. Hence four different complain where filled before the District Forum Bellary with prayer for refund of cost and award of compensation.

In the above mentioned landmark decision Hon'ble NCDRC has been pleased to observe keeping in mind the essence of Section 11(c) of the consumer protection act 1986 that complainant purchased block boards for making furniture items -After some item block boards were found to be affected by borer intestation complaints filed at Bellary opposite party objected that there was a stipulation in purchase bill. Stating all disputes are subject to Bangalore jurisdiction. in this regard Hon'ble Court has been pleased to observe that goods where deliver in Bellary - Hence Jurisdiction lay with the District Forum Bellary. jurisdiction would lie with the District Forum where the cause of action has arises whether wholly or in part. In instance case the cause of action arise in Bellary, where the goods were physically received and utilized. Therefore District Forum Bellary has rightly exercised jurisdiction over the consumer complain because as per 11(c) of the C.P. Act considering the "Cause of action" District Forum Bellary has territorial Jurisdiction.

7) This case is a classic example of the length to which large commercial organisations can sometime go to deny the rightful claim of innocent consumer who repose their implicit trust in them, based on the reputations that they enjoy. yet at the moment of reckoning when the veneer peels away, the reputation on shows itself to be only an illusion the trust totally misplaced. What reveals itself is a powerful organization which consider that  it can do no wrong, books no opposition are consumer towards its action and inaction is ready to justify its action any which way, rises every conceivable objection before the Consumer Forum whether sound in law or not fair or unfair tries to confuse and compound the issue involve and to divert the attention of the juridical forums from the root of the matter prolongs the litigation and eventually tries out the consumer .It prefers to rise the speech of a simple consumer complain to that of a legal battle and to make large sums of money, often public money, to tight search unnecessary battles rather than accept  that it is not in tillable and settle the dispute in a just and fair manner. Consumer Forum which are expected to dispose consumer cases by the summary procedure are forced to follow in the footstep of civil court as multiple issues and objection are raised and once raised have invariable to be death with an adjudicated upon.

8)  Now we have to examine separately under clauses  (a), (b) and (c) of section 11(2) of the Consumer protection Act 1986, as whether the District Forum at Baruipur South 24 Parganas have territorial jurisdiction over the complaint.

Clause (a) : This clause has no application to the fact of the case as admittedly, not all the opposite party resize or carry on business or have a branch office at the District South 24 Parganas.

Clause (b) : This clause applies to the case where there are more opposite party than 1 and postulates that at least any one of them should, at the time of the institution of the complaint either actually and voluntarily reside or carry on business, or have a branch office or personally work for gain within the local limit of the Jurisdiction of the Forum where the complaint is instituted provided further that either permission o f the District Forum is obtained with reference to the opposite parties who are not actually and voluntarily residing or carrying on business or having a branch office or personally working for gain within the local limit of the Jurisdiction of the Forum where the complaint is instituted or they acquiesce in the institution of the complaint.

Clause (c) : Let us now consider clause (c) section 11(2) of the act and also see whether the clause of action In the complaint has arises party or wholly within the local limits of the territorial Jurisdiction of the District Forum at South 24 Parganas. It cannot be disputed can  a consumer Dispute Redressal  Forum is competent to entertain a consumer complaint even if only and infinite simile part of the clause of action arises within its territorial jurisdiction. Now cause of action as is well known is a bundle of fact which taken with the law applicable to them gives the plain tiff are right to relief against the defendant.

9) In the case at hand the complaint who is a resident of South 24 Parganas placed his order for purchasing grocery product and made payment of the total value of goods to the opposite parties at his shop at Chorial bazaar, Budge budge, South 24 parganas, therefore the facts having cause of actions arises within the district South 24 Parganas, and the present complaint is maintainable having proper Jurisdiction under section 11(2)(c) of the Consumer Protection Act 1986.

Through___________

Advocate for the Complainant, Date:17th Day of May,2016, Place: Baruipur, South 24 Parganas.

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