Petition Coonsumer Defective Product

BEFORE THE PRESIDING OFFICER, DISTRIC CONSUMER
.COURT LAHORE
Complaint No,____________/2021
Shafiq Ur Rehman S/o Sardar Muhammad Resident of House No.
E700,Rehman St#5,Block C,Ali Park Nadrabad #1,badian Road Lahore Can
.COMPLAINANT…
VERSUS
1. M/S Faisal Silk House Thorugh its Properitor, Head office, Chowk Ghanta
Ghar Rail Bazar, Faisalabad.
2. M/S Faisal Silk House, through its Sales Manager, Zahid Mehmood,Sub
office, 34/36,St no.56,Almadad Park Colony Near Timber Market Ravi
Road Lahore
…RESPONDENTS.
COMPLAINT UNDER SECTION 25 OF THE PUNJAB CONSUMER

PROTECTION ACT, 2005
Respectfully Sheweth;-
1. That the addresses of the parties given above are correct and proper for the
service of purposes issued by this honorable court.
2. That the brief fact of the instant complaint are that on 21-03-2020 the
complainant purchased the (good/Item) from the respondent by paying an
amount of Rs.167000/- in cash against a receipt with his signature on his
letterhead. Copy of the receipt is attached herewith the complaint for
kind perusal of this Honorable court. On 21-03-2020, respondent no. 1

and 2 came to complainant house with bundle of clothes, bed sheets and
other items and complainant bought all the bundle of clothes, bed sheets and
other items against the payment of Rs.167000/- in return of receipt but when
complainant opened the bundle of clothes, bed sheets and other items, the
complainant found that one bundle of clothes cost of which was Rs.13650/-
was missing and respondent no. 1 and 2 already collected the same amount
but not delivered the said clothes, the complainant also found that other
items/goods were also very sub-standard, rough and the price collected by
the respondent no. 1 and 2 was many fold. Complainant urged for a
replacement and return of that, but it turned into deniable action.
3. That the complainant many times called/messaged the respondents and said
that these items/goods are totally rough, substandard, defective product and
not in accordance with our standards for which respondents already
collected money against the product.
4. That the complainant many times called/messaged the respondents and said
that these items/goods are totally rough, substandard, and not in accordance
with our standards as well as the complainant requested to return that
product and already collected money but the respondent did not pay any
heed to the genuine request of the complainant and lingered on the matter on
one pretext or the other.
5. That the complainant once again called to the respondent No.1 and told
about faulty and defective products and again requested the respondents to
return all the items/goods and that very bundle of clothes which they missed
and already collected money but respondents refused to redress the lawful
grievance of the complainant and seeks some time to do the needful.

6. That it was already decided between the parties that in case of any problem
respondents would return all the items/goods as soon as possible. In this
eventuality, the complainant time and again contacted the respondents on
phone but the respondents always lingered on the matter on one pretext or
the other and did not bother to replace defective goods/items and two days
ago flatly refused to return the same.
7. That due to the negligent act, behavior and sub-standard goods selling in the
market, the complainant suffered damages. Detail of which are as under:
Actual Price of Product: 1,67,000/-
Loss of Reputation, Mental Agony 10,000,00/-
Counsel Fee: 100,000/-
Total: 12,67,000/-
So, as per above tabular, the respondents are liable to pay the above
mentioned damages to the complainant.
8. That the complainant has sent a legal notice to the respondent and informed
the respondent regarding the matter but after passing the several days the
respondent had failed to reply the said legal notice so the complainant has no
other options/way except to file this complaint before this honorable court.
Copy of the legal notice and receiept is attached herewith the complaint
for kind perusal of this Honorable court.
9. That the cause of action firstly accrued in favor of the complainant when he
received rough and sub-standard good/items and the price collected by the
respondents was many folds and that very bundle of clothes which the
respondents missed and already collected money in against of it and
secondly when the respondent failed to redress the complaint/grievance,

thirdly, two days ago when the respondents faltly refused to adher the lawful
and genuine grievance of the complainant which is still continuing.
10.That the subject matter was purchased from the sub-office of the respondents
at Lahore, Cause of action is also accrued at Lahore, the respondents have
also having sub-office for gain of work at Lahore, hence, this honorable
court has jurisdiction to adjudicate upon the matter.
Prayer:
In the light of above submission, it is most respectfully and humbly

prayed that the complaint in hand may very kindly be accepted in favor of the
complainant and against the respondents and the respondents may kindly be
directed to pay Rs.12,67,000/- in shape of damages etc forthwith and also
return the sub-standard product in the interest of justice and fair play.
Any other relief which this honorable court may deem fit and proper may be
granted.
…Complainant
Through
Faiza Shafiq
Advocate High Court
Certificate: As per instruction of my client this is first complaint on this

subject.
Advocate

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BEFORE THE PRESIDING OFFICER, DISTRIC CONSUMER

COMPLAINT UNDER SECTION 25 OF THE PUNJAB CONSUMER

service of purposes issued by this honorable court.

complainant purchased the (good/Item) from the respondent by paying an

amount of Rs.167000/- in cash against a receipt with his signature on his

letterhead. Copy of the receipt is attached herewith the complaint for

kind perusal of this Honorable court. On 21-03-2020, respondent no. 1

replacement and return of that, but it turned into deniable action.

not in accordance with our standards for which respondents already

collected money against the product.

with our standards as well as the complainant requested to return that

one pretext or the other.

grievance of the complainant and seeks some time to do the needful.

respondents would return all the items/goods as soon as possible. In this

eventuality, the complainant time and again contacted the respondents on

ago flatly refused to return the same.

market, the complainant suffered damages. Detail of which are as under:

Actual Price of Product: 1,67,000/-

Loss of Reputation, Mental Agony 10,000,00/-

Counsel Fee: 100,000/-

mentioned damages to the complainant.

for kind perusal of this Honorable court.

respondents missed and already collected money in against of it and

secondly when the respondent failed to redress the complaint/grievance,

and genuine grievance of the complainant which is still continuing.

at Lahore, Cause of action is also accrued at Lahore, the respondents have

court has jurisdiction to adjudicate upon the matter.

In the light of above submission, it is most respectfully and humbly

Certificate: As per instruction of my client this is first complaint on this

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