BEFORE THE CONSUME
COURT,
Complaint No.
______________________/2015
Mr. Muhammad Latif Qureshi son of Muhammad Anwar
Qureshi Resident House No. 4 Street No. 2 Bilal Street Samanabad,
……Complainant
VERSUS
1. UNITED MOBILES, Shop No. 234, 2nd
Floor, Mera,
2. A.A. Mobiles, Shop No. 1, Usama Centre, 1st Floor,
……Respondents
COMPLAINT UNDER SECTION 25 AND ALL OTHER RELEVANT
PROVISIONS OF THE
Respectfully Sheweth:
1. That the addresses of the parties have
been given correctly for the services of summons and notices etc.
2. That the brief facts leading to rise the present suit are that complainant purchased a
3. That under the warrantee you are bound to
repair the mobile or in case of un-repairable fault you are liable to replace
the mobile set.
4. That after three months of purchasing the
said item is not working properly and the said item remained hang and showed the
slow speed as well as during call it becomes off.
5. That immediately complainant visited to
respondent No. 2 for the replacement of the cell or removing the above said
fault, but respondent No. 2 stated that the said fault be removed or replaced
from the respondent No. 1.
6. That thereafter complainant visited the
concerned company on 03.01.2015 and informed about the fault, the staff of
respondent No. 1 firstly asked complainant we will replace your set after 15
days.
7. That on the fixed date, complainant again
visited respondents No. 1 as well as respondent No. 2 the fault will be
repaired otherwise the company will be bound to exchange with new mobile set.
8. That thereafter on 11.03.2015, complainant
visited the respondent No. 1 he also refused to repair or change the said
mobile and did not pay any heed for replacement of the defects in manufacturing
mobile set of complainant.
9. That due to the manufacturing of the
respondents the mobile set of complainant found defective and according to
warrantee card the respondents are responsible for the replacement of the same
but the respondents have declined to replace the defects found it in the mobile
set of complainant.
10. That complainant requested the respondents
to replace the same in the light of para 3 but the
respondents declining to accede the genuine request/ demand of the complainant
for which the respondents are liable to be prosecuted before the Consumer
Courts at
11. That apart from the refusal of the
respondents have disreputed, degraded and ridiculed
complainant which created mental torture, shock agony and financial loss and
also misbehaved within the presence of staff and other consumers present at the
same time for which complainant also reserves his right to claim damages from the
respondents to the tune of Rs. 500000/- for each of the above act.
12. That the complainant served the legal
notices to the respondents but uptill now the
respondents did not response the same.
13. That the cause of action accrued in favour of the complainant and the respondents due to the
above said facts and circumstances and finally when the respondents refused to accede the genuine request of the complainant, which is
still continuing.
14. That the parties to the petition are
residing at
15. That the requisite court fee has been
affixed on the petition.
Under
the above said mentioned circumstances, it is, therefore, most respectfully
prayed that the complaint in hand may very kindly be accepted by passing an
appropriate order may very kindly be passed in favour
of the complainant and against the respondents directing him to replace the
mobile set.
Any other relief, which this Honourable Court deems fit and proper in the circumstances
of the case may also be awarded.
Petitioner
Through
Mudaber Hussain
Qureshi
Advocate High Court
127-Disctrict Courts,
Custody :
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