Consumer
Complaint no. 226 of 2024 |
In
the matter of ;
1.
Smt.
KakaliSen, Wife of Sri AbhinandanGhosh, and Daughter of Sri Amal Kumar Sen,
2.
Sri
AbhinandanGhosh, Son of Sri ChittaranjanGhosh,
Both are permanent residents of
Banshbari, P.O. – Banshbari, P.S. – English Bazar, District – Malda, PIN –
732201, and presently residing at D/82, Bapuji Nagar, P.O. – Regent Estate,
P.S. – Jadavpur, Kolkata – 700092.
_____Complainants
-
Versus
–
1.
M/s.
S.S. Construction, a proprietorship firm, having its registered office at
A/61/2, Bapuji Nagar, P.O. – Regent Estate, P.S. – Jadavpur, Kolkata - 700092.
2.
Sri
SujitSaha, Sole Proprietor of M/s. S.S. Construction, residing at A/61/2,
Bapuji Nagar, P.O. – Regent Estate, P.S. – Jadavpur, Kolkata - 700092.
________Opposite Parties.
WRITTEN
VERSION
OF OPPOSITE
PARTIES
M/s. S.S.
Construction and Sri SujitSaha,
The humble
petition on behalf of the above named Opposite PartiesM/s. S.S. Construction
and Sri SujitSaha, most respectfully;
Sheweth as
under;
1.
That
the Petitioner has been served with the purported copy of petition, made by the
Complainants. The Petitioner have gone through the contents of the purported
petition and made replies to the same, are as follows.
2.
That
the Consumer Complaint is not maintainable in its present form, either in term
of the facts or in term of the Law.
3.
That
the Petition is speculative, harassing, motivated and barred by the Principles
of Law and hence it is liable to be rejected at once.
4.
That
the petition is suffering from misjoinder and non-joinder of necessary party in
the proceeding, and therefore liable to be dismissed at once with exemplary
costs.
5.
That
the petition is suffering from suppression of material facts and necessary
party, and therefore liable to be dismissed at once with exemplary costs.
6.
That
the petition is suffering from any legal demand and thereby cause of action,
the present petition is motivated and without any jurisdiction.
7.
That
the Opposite Party, do not admit all the allegations made in the application of
the Petitioners / Complainants, to be true and save and except those that are
specifically admitted he put the Petitioners, to the strict proof of the rest.
8.
That
the contents of the Complaint is vague and based on after thought concocted
story, made out by the Complainants to in-clinch issues in theirfavour, and
thus no part of the contents of the Complaint has ever been admitted by the
Opposite Party, except those are the matter of records.
9.
That
the Opposite Party states that the present Complaint has been instituted by the
Complainants against this Opposite Party to cause several hassle and harassments
to this Opposite Party.
10.
That
the complainantsare not a Consumer as per provision of Section 2 (7) of the
Consumer Protection Act’ 2019, and therefore deserve to be dismissed with cost
thereof in terms of the provisions of the Consumer Protection Act’ 2019.
11.
That
the present complaint has not been placed in terms of the provision of Section
35 of the Consumer Protection Act’ 2019, and therefore deserve to be dismissed
with cost thereof in terms of the provisions of the Consumer Protection Act’ 2019.
12.
That
the present Complaint did not disclose any cause of action to be accrued ever
to place the present consumer application, more particularly against this
opposite party.
13.
That
the present complaint has no cause of action to place before the Hon’ble
Commission, in any terms of the provisions of the Consumer Protection Act’
2019, and therefore deserve to be dismissed with cost thereof in terms of the
provisions of the Consumer Protection Act’ 2019.
14.
That
the present complaint has no accrual of any cause of action to place before the
Hon’ble Commission, in any terms of the provisions of the Consumer Protection
Act’ 2019, and therefore deserve to be dismissed with cost thereof in terms of
the provisions of the Consumer Protection Act’ 2019.
15.
That
the story of the complainant does not constitute the consumer disputes in terms
of the provisions of the Consumer Protection Act’ 2019, and therefore deserve
to be dismissed with cost thereof in terms of the provisions of the Consumer
Protection Act’ 2019.
16.
That
the present Consumer application has not been valued appropriately for the
purpose of pecuniary jurisdiction of the Hon’ble Commission, and therefore
deserve to be dismissed with cost thereof in terms of the provisions of the
Consumer Protection Act’ 2019.
17.
That
the present application of the complainantsare an endavour of them to cooked up
a false story, and manufactured documents shown to be relied on by them, before
the Hon’ble Commission, for their wrongful gains and others, and therefore
deserve to be dismissed with cost thereof in terms of the provisions of the
Consumer Protection Act’ 2019.
18.
That
the present complaint is false, vague, and frivolous one, and thus entitle the
rejection with cost on the complainants, in terms of the provisions of the Consumer
Protection Act’ 2019.
19.
That
there is no Consumer disputes to be adjudicated before the Hon’ble Commission,
between the parties herein, and therefore deserve to be dismissed with cost
thereof in terms of the provisions of the Consumer Protection Act’ 2019.
20.
That
the Opposite Party states and submits that the Complainant’s disputes, is not a
Consumer dispute and the Complainants are not a consumer, as defined and
enumerated in the relevant provisions of the Consumer Protection Act’ 2019.
21.
That
before dealing with the statements made in the petition under objection
paragraph wise, this Opposite Party states the following facts for Your
Honour’s kind perusal :
(i)
M/s. S.S. Construction a
Proprietorship Firm carrying on its business at Premises being No. A/61/2,
Bapuji Nagar, Police Station – Jadavpur, Kolkata – 700092, represented by its
Sole Proprietor ShriSujitSaha, Son of Late SambhunathSaha, residing at Premises
being no. A/61/2, Bapujinagar, Post Office – Regent Estate, Police Station – Jadavpur,
Kolkata – 700092, carrying its business in the field of Realty &
Construction.
(ii)
The Opposite Party no. 1, represented
by the Opposite Party no. 2, entered into Development Agreement dated
21-12-2012, with the Land Owners (1) Sri AmritlalDutta, (2) Sri DhananjoyDutta,
(3) Sri Ajay Dutta, (4) Sri DigbijayDutta, (5) Smt. GopaDutta, and (6) Smt.
Molina Dutta. The said Development Agreement registered on 21-12-2012, before
the D.S.R. – I, Alipore, vide Book No. I, CD Volume No. 20, Pages 216 to 240,
Being No. 04460 for the year 2012., in respect of ALL THAT piece and parcel of
land measuring more or less 04 Cottahs lying and situate at Mouza – Baderaipur,
J.L. No. 34, within Police Station – Jadavpur, comprised in C.S. Plot No. 523
(P), 524 (P), 532 (P), 533 (P), Being E/P No. 54, S.P. 212, District South 24
Parganas, under Ward No. 96, of the Kolkata Municipal Corporation, Premises No.
62E/54A, Raja Subodh Chandra Mullick Road, also known as Postal Premises No.
D/82, Bapuji Nagar, Post Office Regent Estate, Police Station Jadavpur, Kolkata
700092, District South 24 Parganas.
(iii)
Subsequently, The Owners executed a
registered Power of Attorney in favour of Sri SujitSaha, on 21-12-2012,
registered before the D.S.R. –I, Alipore and recorded in Book No. I, CD Volume
No. 20, Pages 241 to 256, Being No. 04461 for the year 2012, to do any acts and
things on their behalf and also empowered to enter any Agreement for Sale and
to execute Deed of Conveyance in respect of the said property to any intending
Purchasers.
(iv)
The Complainants herein have
approached the opposite party no.2 with an intention to parches a flat along
with a covered car parking space from the developer’s allocation being flat no.
2B on the southern side of first floor measuring an area of about 750 sq. ft. a
little more or less super built up area consisting of 2 (Two) bed rooms, 1
(One) kitchen, 1 (One) drawing-cum-dining, 1 (One) toilet, 1 (One) WC, 1 (One)
Balcony and a covered car parking space measuring about 125 sq. ft. one the
ground floor of the proposed G+3 storied building to be constructed by the
opposite party no.2 in the said premises.
(v)
Accordingly, the complainants herein
enter into a registered agreement for sale which was registered on 5th
January 2016 before the office of the DSR-I, Alipore, registered in Book No. I,
Volume No. 1601/2016, Pages 1160 to 1210, Being No. 060100025 for the year
2016.
(vi)
It was agreed by and between the
parties that the sale consideration would be Rs. 42 Lakhs (Rupees Forty Two
Lakhs only) and accordingly complaints herein procured a loan two the tune of
Rs. 33,60,000/- (Rupees Thirty Three Lakhs Sixty Thousand only) from the HDFC
Bank for making payment towards the purchase of the said residential flat being
Flat No. 2B on the southern side of first floor measuring an area of about 750
sq. ft. a little more or less super built up area alongwith a covered car
parking space on the ground floor of the G+3 storied building proposed to be
constructed at the premises No. D/82, Bapuji Nagar, P.O – Regent Estate, P.S –
Jadavpur, Kolkata – 700092.
(vii)
The Complainant herein paid a sum of
Rs. 6,80,000/- (Rupees Six Lakhs and Eighty Thousand) only, on the day of
execution of the Agreement for Sale dated 21-12-2012. Subsequently, the
Complainants tendered two numbers of demand drafty being nos. 095491, and
095492, dated 25-06-2016, amounting to Rs. 85,000/- (Rupees Eighty Five
Thousand) only, and Rs. 75,000/- (Rupees Seventy Five Thousand) only,
respectively. The Complainants herein procured a loan to the tune of Rs.
33,60,000/- (Rupees Thirty Three Lakhs and Sixty Thousand) only, and Rs.
50,000/- (Rupees Fifty Thousand) only, on 27/12/2022. Thus a total sum of Rs.
41,96,000/- (Rupees Forty One Lakhs and Ninety Six Thousand) only, has been
paid by the Complainants herein till the 27th day of December’ 2022.
The Complainants are not due diligent in making payment of the consideration
value of the subjected flat in terms of the agreement for sale dated 5th
day of January’ 2016, even after handing over the Physical Possession of the
said subjected flat by the Opposite Parties. The Opposite Party is still
awaiting to get his balance sum of money from the complainants herein.
(viii)
It is stated that the said flat, as
agreed upon by and between the parties, that the said flat with all amenities,
fixtures and fittings to be handed over to the complaints herein within 2 years
from the date of execution of the said agreement for sale, i.e. 5th
January 2016.
(ix)
That after completion of the basic
construction of the said G+3 storied building in the said premises, the
complainants were given possession of the said flat by the opposite party no. 2
measuring an area of about 750 sq.ft. super built up area along with the car
parking space measuring about 125 sq. ft. in the ground floor of the said
premises.
(x)
That since the day of taking
possession of the said subjected flat and Car Parking, the Complainants enjoyed
without any hindrances, so far; But did not arrange themselves for the
registration of Deed of Conveyance in terms of the said Agreement for Sale
dated 5th day of January’ 2016.
(xi)
This Opposite Party is all along ready
and willing to register the deed of conveyance in terms of the said Agreement
for Sale dated 5th day of January’ 2016.
(xii)
That
the complainantsare not a Consumer as per provision of Section 2 (7) of the
Consumer Protection Act’ 2019.
(xiii)
That
there is no Consumer disputes to be adjudicated between the parties, before the
Hon’ble Commission, between the parties herein.
(xiv)
That
the present claim of the Complainants if any, is barred by the Limitation as
enshrined under the provision of Section 69 of the Consumer Protection Act’
2019.
(xv)
That
the Opposite Party, have no iota of knowledge about the alleged story of the
complainant herein.
(xvi)
That
the Opposite party, herein have no relationship with the complainant herein as
alleged by them, in their petition of consumer complaint.
(xvii)
That
the opposite party, herein have no disputes as alleged by the complainants
herein, in the petition of consumer complaint.
(xviii)
That
the present Consumer disputes as alleged by the complainants herein, is not
maintainable in the facts and in the law against the opposite party, in the
terms of the Consumer Protection Act’ 2019.
(xix)
That
the allegations as contended by the complainants herein are all fake and
frivolous one, as those are not substantiated with any single piece of papers
or evidentiary value papers, against this opposite party.
(xx)
That
the present complaint has been made before the Hon’ble Commission, motivated
and with an intention for the wrongful gain and acquire of wrongful claim
thereby the complainants herein.
(xxi)
That
the Opposite Party, herein did not cause any deficiency in services, and or
unfair trade practices, in terms of the provisions of the Consumer Protection
Act’ 2019, and rules made thereof.
(xxii)
That
there is no cause of action has ever been described and or more particularly
raised against this opposite party, by the complainant.
22.
That
without waiving any of the aforesaid Objections and Facts and fully relying
thereupon and without prejudice to the same. This Opposite Party now deals with
the specific paragraphs of the said Application in seriatim as hereunder.
23.
That
the Application is not maintainable either in facts or in its present form and
the petitioners have no cause of action for bringing this suit against the
Opposite Party as the said application is speculative, harassing, motivated,
concocted and baseless as is barred by the Principles of Law and hence same is
liable to be rejected at once.
24.
Save
and except the statements made in the said application which are matter of
record, the Opposite Parties denies each and every allegations contained in the
said application and calls upon the petitioner to strict proof of the said
allegations.
25.
That
with references to the statements made in paragraph nos. 1, 2, 3, 4, 5, 6, 7,
8, 9, 10, and 11, of the application, this Opposite Parties deny and disputes
each and every allegations made therein save and except what are the matters of
record and not related to this opposite party. The Opposite Party repeats and
reiterates the statement made in paragraph no.21, herein above. The Opposite
Party states that M/s.
S.S. Construction a Proprietorship Firm carrying on its business at Premises
being No. A/61/2, Bapuji Nagar, Police Station – Jadavpur, Kolkata – 700092,
represented by its Sole Proprietor ShriSujitSaha, Son of Late SambhunathSaha,
residing at Premises being no.A/61/2, Bapujinagar, Post Office – Regent Estate,
Police Station – Jadavpur, Kolkata – 700092, carrying its business in the field
of Realty & Construction.The Opposite Party no. 1, represented by the
Opposite Party no. 2, entered into Development Agreement dated 21-12-2012, with
the Land Owners (1) Sri AmritlalDutta, (2) Sri DhananjoyDutta, (3) Sri Ajay
Dutta, (4) Sri DigbijayDutta, (5) Smt. GopaDutta, and (6) Smt. Molina Dutta.
The said Development Agreement registered on 21-12-2012, before the D.S.R. – I,
Alipore, vide Book No. I, CD Volume No. 20, Pages 216 to 240, Being No. 04460
for the year 2012., in respect of ALL THAT piece and parcel of land measuring
more or less 04 Cottahs lying and situate at Mouza – Baderaipur, J.L. No. 34,
within Police Station – Jadavpur, comprised in C.S. Plot No. 523 (P), 524 (P),
532 (P), 533 (P), Being E/P No. 54, S.P. 212, District South 24 Parganas, under
Ward No. 96, of the Kolkata Municipal Corporation, Premises No. 62E/54A, Raja
Subodh Chandra Mullick Road, also known as Postal Premises No. D/82, Bapuji
Nagar, Post Office Regent Estate, Police Station Jadavpur, Kolkata 700092,
District South 24 Parganas.Subsequently, The Owners executed a registered Power
of Attorney in favour of Sri SujitSaha, on 21-12-2012, registered before the
D.S.R. –I, Alipore and recorded in Book No. I, CD Volume No. 20, Pages 241 to
256, Being No. 04461 for the year 2012, to do any acts and things on their
behalf and also empowered to enter any Agreement for Sale and to execute Deed
of Conveyance in respect of the said property to any intending Purchasers.The
Complainants herein have approached the opposite party no.2 with an intention
to parches a flat along with a covered car parking space from the developer’s
allocation being flat no. 2B on the southern side of first floor measuring an
area of about 750 sq. ft. a little more or less super built up area consisting
of 2 (Two) bed rooms, 1 (One) kitchen, 1 (One) drawing-cum-dining, 1 (One)
toilet, 1 (One) WC, 1 (One) Balcony and a covered car parking space measuring
about 125 sq. ft. one the ground floor of the proposed G+3 storied building to
be constructed by the opposite party no.2 in the said premises.Accordingly, the
complainants herein enter into a registered agreement for sale which was
registered on 5th January 2016 before the office of the DSR-I,
Alipore, registered in Book No. I, Volume No. 1601/2016, Pages 1160 to 1210,
Being No. 060100025 for the year 2016.
26.
That
with references to the statements made in paragraph nos. 12, 13, 14, 15, 16,
17, 18, 19, and 20, of the application, being the petition of the complaint
made by the complainant, this Opposite Parties deny and disputes each and every
allegations made therein save and except what are the matters of record and not
related to this opposite party. The Opposite Party repeat and reiterate the
statements made in paragraph no. 21, herein above. The Opposite Party states
that it
was agreed by and between the parties that the sale consideration would be Rs.
42 Lakhs (Rupees Forty Two Lakhs only) and accordingly complaints herein
procured a loan two the tune of Rs. 33,60,000/- (Rupees Thirty Three Lakhs
Sixty Thousand only) from the HDFC Bank for making payment towards the purchase
of the said residential flat being Flat No. 2B on the southern side of first
floor measuring an area of about 750 sq. ft. a little more or less super built
up area along with a covered car parking space on the ground floor of the G+3
storied building proposed to be constructed at the premises No. D/82, Bapuji
Nagar, P.O – Regent Estate, P.S – Jadavpur, Kolkata – 700092.The Complainant
herein paid a sum of Rs. 6,80,000/- (Rupees Six Lakhs and Eighty Thousand)
only, on the day of execution of the Agreement for Sale dated 21-12-2012.
Subsequently, the Complainants tendered two numbers of demand drafty being nos.
095491, and 095492, dated 25-06-2016, amounting to Rs. 85,000/- (Rupees Eighty
Five Thousand) only, and Rs. 75,000/- (Rupees Seventy Five Thousand) only,
respectively. The Complainants herein procured a loan to the tune of Rs.
33,60,000/- (Rupees Thirty Three Lakhs and Sixty Thousand) only, and Rs. 50,000/-
(Rupees Fifty Thousand) only, on 27/12/2022. Thus a total sum of Rs.
41,96,000/- (Rupees Forty One Lakhs and Ninety Six Thousand) only, has been
paid by the Complainants herein till the 27th day of December’ 2022.
The Complainants are not due diligent in making payment of the consideration
value of the subjected flat in terms of the agreement for sale dated 5th
day of January’ 2016, even after handing over the Physical Possession of the
said subjected flat by the Opposite Parties. The Opposite Party is still
awaiting to get his balance sum of money from the complainants herein.It is
stated that the said flat, as agreed upon by and between the parties, that the
said flat with all amenities, fixtures and fittings to be handed over to the
complaints herein within 2 years from the date of execution of the said
agreement for sale, i.e. 5th January 2016.
27.
That
with references to the statements made in paragraph nos. 21, 22, 23, 24, &
25, of the application, this Opposite Parties deny and disputes each and every
allegations made therein save and except what are the matters of record and not
related to this opposite party. The Opposite Party repeat and reiterate the
statements made in paragraph no. 21, herein above. The Opposite Party states
that That
after completion of the basic construction of the said G+3 storied building in
the said premises, the complainants were given possession of the said flat by
the opposite party no. 2 measuring an area of about 750 sq. ft. super built up
area along with the car parking space measuring about 125 sq. ft. in the ground
floor of the said premises. Since the day of taking possession of the said
subjected flat and Car Parking, the Complainants enjoyed without any
hindrances, so far; But did not arrange themselves for the registration of Deed
of Conveyance in terms of the said Agreement for Sale dated 5th day
of January’ 2016.This
Opposite Party is all along ready and willing to register the deed of conveyance
in terms of the said Agreement for Sale dated 5th day of January’
2016.
28.
That
with references to the statements made in paragraph nos. 26, 27, 28, 29, and 30,
of the application, this Opposite Parties deny and disputes each and every
allegations made therein save and except what are the matters of record and not
related to this opposite party. The Opposite Party repeat and reiterate the
statements made in paragraph no. 21, herein above. This Opposite Party put
forward his comments in the followings;
The complainant is
not a Consumer as per provision of Section 2 (7) of the Consumer Protection
Act’ 2019.
Thereis no Consumer
disputes to be adjudicated between the parties, before the Hon’ble Commission,
between the parties herein.
The present claim of
the Complainants if any, is barred by the Limitation as enshrined under the
provision of Section 69 of the Consumer Protection Act’ 2019.
The Opposite Party,
have no iota of knowledge about the alleged story of the complainant herein.
The Opposite party,
herein have no relationship with the complainant herein as alleged by him, in
his petition of consumer complaint.
The opposite party,
herein have no disputes as alleged by the complainant herein, in the petition
of consumer complaint.
The present Consumer complaint
as alleged by the complainants herein, is not maintainable in the facts and in
the law against the opposite party, in the terms of the Consumer Protection
Act’ 2019.
The allegations as
contended by the complainant herein are all fake and frivolous one, as those
are not substantiated with any single piece of papers or evidentiary value
papers.
The present consumer complaint
has made motivated and with an intention for the wrongful gain and acquire of
wrongful claim thereby the complainants herein.
The Opposite Party,
herein did not cause any deficiency in services, and or unfair trade practices,
in terms of the provisions of the Consumer Protection Act’ 2019, and rules made
thereof.
There is no cause of
action has ever been described and or more particularly raised against this
opposite party, by the complainant.
The
Complainant is not entitled to get any relief in terms of his/ her prayer more
particularly any relief as prayed to acquire from this opposite party. The
allegations of the complainant are baseless, false and frivolous one, thus the
prayer of the complainant is not tenable to give on the direction of this
opposite party.
This opposite
party is not a cup of tea for the complainant’s relief, as the same has been
consumed by the complainant on full satisfaction.
The present
consumer complaint is not tenable either in the facts or in the law, thus
liable to be dismissed inlimnie with
cost on the complainant.
The instant
matter comes within the purview of Commercial dispute, which is within the
ambit of the Commercial Courts Act, 2015, therefore the present Consumer
Complaint should be dismissed at once.
The Petition
of Consumer Complaint is not in terms of the Provisions of Section 35 of the
Consumer Protection Act, 2019.
29.
That
this opposite party states that the present petition of complaint is not
bonafide against this opposite party, and the complainant is not entitled to
get any relief in terms of her prayer made therein from this opposite party in
terms of the provision of the Consumer Protection Act’ 2019.
30.
That
in the facts and in the laws, it is totally evident from the application itself
that the complainants made their endeavor to put the Hon’ble Commission into
motion to get their wrongful gains by procuring orders in terms of their prayer
before the Hon’ble Commission.
31.
That
in the facts and in the laws, it is totally evident from the application itself
that the complainants are trying to miss utilizing the jurisdiction of this
Hon’ble Commission.
32.
That
in the above circumstances, there is no cause of action for the present
proceedings by the Petitioners, against the Opposite Party, the Opposite Party,
accordingly pray that the Consumer Complaint be dismissed with costs.
33.
That
in the above circumstances, there is no deficiency in service, and or unfair
trade practices, on the part of the Opposite Party, rather the Opposite Party
is victim of the concocted story and wrongful demand of the complainant.
34.
That
the entire facts are Commercial in nature, therefore the present consumer
complaint should be dismissed inlimnie.
35.
That
the instant matter comes within the purview of Commercial dispute, which is
within the ambit of the Commercial Courts Act, 2015, therefore the present
Consumer Complaint should be dismissed at once.
36.
That
in view of the facts that the Opposite Party is victim of the purported alleged
allegations and wrongful demand, the Opposite Party thereby seeking
compensation as of Rs. 1,00,000/- ( Rupees One Lakh ) only, for harassment and
mental anxiety, arising from the institution of the present proceeding by the
complainants, against this opposite party, before the Hon’ble Commission.
37.
That
the Petitioner, neither has any cause of action nor the basis for filling the
present consumer complaint and the Petitioners’ consumer complaint is entirely
baseless and misconceived and deserve to be dismissed on this ground alone.
38.
That
the Consumer Complaint is false, frivolous and vexatious and has been filed
with the mala fide intention, and as such deserves to be dismissed with special
costs.
39.
That
the Petitioners, are not entitled to any relief as prayed in the Consumer
Complaint, and the same is liable to be dismissed inlimnie.
40.
That
in the aforesaid circumstances, the Opposite Party is seeking the dismissal of
the Complaint filed by the Petitioners, with exemplary cost.
41.
That
the Opposite Party crave leave to produce any necessary documents and or
papers, in the proceeding at the time of hearing and or placing the Evidence on
Affidavit, before the Hon’ble Commission, in the interest of Administration of
Justice.
42.
That
the present consumer complaint should be dismissed at once in terms of the
provisions of the Consumer Protection Act’ 2019, as the same is found frivolous
and vexatious one, against this opposite party.
It is therefore prayed that the
Hon’ble Consumer Disputes Redressal Commission, would graciously be pleased to
allow this Written Version of the Opposite Party, and to dismiss and or reject
at once the petition of consumer complaint filed by the Petitioners, against
this opposite party herein, with costs, in terms of the provisions of the
Consumer Protection Act’ 2019, and rules made therein, in the interest of
administration of justice, and or to pass such other necessary order or orders
or further order or orders as the Hon’ble Commission, may deem, fit, and proper
for the end of justice.
And for
this act of kindness, the Petitioner, as in duty bound shall ever pray.
VERIFICATION
I, being
the Opposite Party number 2, in the present consumer proceeding, I am
acquainted and conversant with the material facts stated in the Written
Version. I am Proprietor of the Opposite Party number 1, M/s. S.S. Construction.
I verify, & sign the written version on ______July’ 2024, at the Alipore
Judges’ Court Premises.
AFFIDAVIT
I,
ShriSujitSaha, Son of Late SambhunathSaha, aged about ____years, by faith
Hindu, by Occupation Business, residing at Premises being No. A/61/2,
Bapujinagar, Post Office – Regent Estate, Police Station – Jadavpur, Kolkata –
700092, District South 24 Parganas, do hereby solemnly affirm and say as
follows;
1.
I
am Proprietor of the Opposite Party number 1, M/s. S.S. Construction. I am the
Opposite Party number 2, in the present Consumer Proceeding.
I am acquainted and conversant with the material facts stated in the Written
Version and Competent to swear this affidavit.
This
is true to our knowledge.
2.
That the statements made in paragraph
number 1 to 21 of the Written Version are true to my knowledge and the rests
are my humble submissions before the Learned Commission.
The
above statements are true to our knowledge and belief.
DEPONENT
Identified
by me,
Advocate
Prepared
in my Chamber,
Advocate
Place
:Alipore Judges’ Court
N O T A R Y
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