Sanjay

VISION AND GOALS/OBJECTIVES OF BANKING OMBUDSMAN

SCHEME
Vision Statement:
To be a visible and credible system of dispute resolution mechanism for
common persons utilizing the banking services.
Goals/objectives:
 To ensure redressal of grievances of users of banking services in an
inexpensive, expeditious, fair and reasonable manner.
 To provide valuable feedback/ suggestions to RBI towards framing
appropriate and timely guidelines to banks to improve the level of
customer service.
 To facilitate quick and fair (non-discriminatory) redressal of grievances
through use of IT systems.
 Provide feedback for framing appropriate and timely guidelines
 Enhance awareness of the scheme itself

OBJECTIVES OF THE STUDY

The objectives of the study are:
• To study about the role and performance of the Banking Ombudsman
Scheme.
• To study about the redressal procedure under the banking ombudsman
scheme and exemplary cases covered under the scheme.
• Analysis of annual report of banking ombudsman scheme.

REVIEW OF LITERATURE
1) THE IMPACT OF BANKING OMBUDSMAN SCHEME ON INDIAN
BANKING INDUSTRY by mam S. SIRISHA and sir P. MALYADRI
found out that there is an increasing trend in cases against
deficiency in banking services over a period of study of seven
years from 2006-07 to 2012-13, which also represents the
increased trust of customers in Bank Ombudsman. The study
 shows that there is an growing awareness among consumers
about grievance redressal, but mainly in the metropolises.
2). A STUDY ON EFFECTIVENESS OF INDIAN BANKING OMBUDSMAN by
Kantamaneni HemaDivya mam, Koteshwar Reddy and Satyadev Kota ,MBA
Students of (K L University)
The study made by them analyses the role of the banking Ombudsman in India
and does the evaluation of effectiveness of the Banks ombudsman as a banking
dispute redressal body or Bank’s redressal mechanism for a period of about
five years from 2011 to 2015. The study and analysis made by them shows that
a good number of complaints is received and redressed.
3).Banking Ombudsman Scheme and Bank Customer Complaints in India by
Mr. Ajit Narayan Jadhav, Assistant Professor
The study made by Mr.Ajit Narayan Jadhav is an attempt to study the banking
ombudsman scheme and the way different types of complaints of bank
customers are handled and also the statistical data of bank complaints
received under banking ombudsman scheme for a period of seven years from
2011-12 to 2016-17 and its disposal rate under banking ombudsman scheme
for a period of three years from 2014-15 to 2016-17.
4.A Research on Banking Ombudsman Scheme by
C. Vijai, St.Peter’s Institute of Higher Education and Research,chennai,India
The study made by Mr.C.Vijai talks about the overall performance of the
Banking Ombudsman Scheme for a period of three years from 2015-16 to
2016-17 by use of statistical information from technical books, articles, RBI
announcements and Indian bank association bulletin. Through the discussion
and evaluation done in this study, author suggests that the variety of the court
case are acquired and handled by using the banking ombudsman.
WHO IS BANKING OMBUDSMAN
Banking Ombudsman is a quasi-judicial official or senior official appointed by a
quasi-judicial authority and the Reserve bank of India under India’s Banking
Ombudsman Scheme 2006 as per clause 4, and the jurisdiction was formed
following to a judgment made by India’s government to facilitate in resolving
customer complaints and objections against insufficiency in banking services.
APPOINTMENT AND TENURE OF BANKING OMBUDSMAN
(a) The Reserve Bank may on the recommendation of a Selection Committee of
four persons constituted by its Governor appoint one or more persons to be
known as Banking Ombudsman to carry out the functions entrusted to him by
or under the Scheme.
(b) The Committee referred to in sub-clause (1) of this Clause shall consist of; 1.
all the three Deputy Governors of the Reserve Bank; and 2. the Additional
Secretary (Financial Sector) from Department of Economic Affairs as a Special
Invitee.
(c) The minimum age of the person to be considered by the said Committee for
appointment, as Banking Ombudsman shall be 55 years.
(d) The appointment of Banking Ombudsman under this Clause may be made
for a period not exceeding three years, but Sometimes due to the
recommendation of the Committee tenure can be extended for period of two
years subject to an overall age limit of 65 years.
(e) The Banking Ombudsman appointed shall devote his whole-time to the
affairs of his office, provided that the RBI may permit the Banking Ombudsman
to undertake such part-time honorary work, if it is considered to be necessary
to do so.
POWERS AND JURISDICTION
a) The Reserve Bank shall specify the territorial limits to which the authority of
each Banking Ombudsman appointed under Clause 4 of the Scheme shall
extend.
b) The Banking Ombudsman shall receive and consider complaints relating to
the deficiencies in banking or other services filed on the grounds mentioned in
clause 8 irrespective of the pecuniary value of the deficiency in service
complained and facilitate their satisfaction or settlement by agreement or
through conciliation and mediation between the bank concerned and the
aggrieved parties or by passing an Award as per the provisions of the Scheme.
c) The Banking Ombudsman shall exercise general powers of superintendence
and control over his Office and shall be responsible for the conduct of business
there at.
d) The Office of the Banking Ombudsman shall draw up an annual budget for
itself in consultation with Reserve Bank and shall exercise the powers of
expenditure within the approved budget on the lines of Reserve Bank of India
Expenditure Rules, 2005.
e) On 30th June of every year, Banking Ombudsman should send a report
containing a general review of the activities of his Office during the preceding
financial year to the Governor and Reserve Bank.
f) The ombudsman shall have the power to supervise the general civil
administration. On this point the duty of ombudsman is closely connected with
the public administration. Because the protection of freedom, execution of
policies and other fall within the jurisdiction of public administration and
whether these are properly performed or not that requires to be examined-
and ombudsman does this job. It is also called general surveillance of the
functioning of the government.
g) An important function of Ombudsman is the exercise of discretionary
powers. Discretionary powers include corruption, negligence, inefficiency,
misbehavior, etc.

E. OTHER COMPLAINTS
1.Complaint:
The grievance of the complainant was that the bank had levied prepayment
charges and had charged interest on the subsidy portion of the loan amount.
Decision: when the case was brought to the ombudsman, BO pointed out that
the terms and condition specified in the sanction letter did not provide for levy
of prepayment charges and bank admitted that 8.2% was collected as
prepayment charges. The Banking Ombudsman observed and stated that in
the absence of any agreed condition for levy of prepayment charges, the bank
could not levy it and directed bank to refund the prepayment charges.
2. Complaint:
The complainant had alleged that the bank had charged interest far in excess
of the stipulations as contained in RBI guidelines on their overdraft amount
against the security of FCNR deposit receipt. The bank had granted an
overdraft limit against the security of FCNR deposit of adequate value at an
interest of 22.25% whereas the deposit carried interest at 6.25%.
Decision:
When the complaint was taken to BO, it was found that interest was to be
charged on the basis of credit ratings and on the basis of a benchmark rate
linked to the bank’s PLR as per bank’s internal circulars and As the bank could
not justify its stand of charging an interest at 22.25% which was higher than
the interest rate as specified in the bank’s internal circulars, an Award was
passed against the bank to refund the excess interest recovered from the
complainant.
Conclusion
At last, I will conclude our presentation by saying that Indian government is
seriously pursuing financial inclusion of a huge proportion of unbanked
population in the country. As the banking activities increase, and people who
have never banked before come to participate in formal banking, they need
banking awareness as well as protection. Thus, India needs to be prepared
with a redressal mechanism that is well equipped and designed to handle fair
and satisfactory investigation to the complainants. Offices of Banking
Ombudsmen should organize awareness campaigns/outreach activities, Town
Hall events, advertisement campaigns to spread awareness about the Scheme.
So, that bank customers will come forward for solving their grievances and also
prefer to lodge complaints to the office of banking ombudsman instead of
courts. Even though the scope of banking Ombudsman has been revised and
enhanced four times till date, due to increase in number of bank customers
every year, there is a need to increase number offices of Banking Ombudsman.
Thank you.
Yogesh
ORGANISATIONAL CHART
1.Office of banking ombudsman: The office of the Banking Ombudsman shall
be located at places specified by the Reserve Bank. In order to accelerate
disposal of complaints, the Banking Ombudsman may hold sittings at such
places within his area of jurisdiction.
2. Executive director (Customer service department): Executive director is
responsible for the day-to-day leadership and management of service. They’re
accountable to board of non-executive directors.
The executive director: • proposes and manages Banking ombudsman scheme
budget • oversees how BO’s act on our strategy and commitments • and
makes sure they are running effectively and efficiently • manages how BO’s
respond to risks.
3. Deputy governor (Appellate authority): ‘Appellate Authority’ means the
Deputy Governor in charge of the Department of the Reserve Bank
implementing the Scheme. The Deputy Governor-in-Charge of the Consumer
Education and Protection Department (CEPD) of the RBI is the designated as
the Appellate Authority (AA) as per the provisions of the BO Scheme. CEPD
provided the Secretariat to the AA and listens to appeals against BO’S awards
and rejection.
ESCALATION OF GRIEVANCES TO BO
Level 1 - City Heads / Branch Managers
In case the Customer Service Managers of respective banks fail to contact the
customers within 3 working days, or if customers are not satisfied with the
response, the customer can write to the City Business Head/ Cluster Head /
Branch Head explaining the details of the concern.
Level 2 - Nodal Officer or Grievance Redressal officer
If customers are still not satisfied with the resolution they receive after level 1,
they can write to the Nodal Officer and bank shall respond to customer’s
complaint within 7 working days.
Level 3 - Principal Nodal Officer or Chief Grievance Redressal officer
If customers are still not satisfied with the resolution they receive in level 2,
they can write to the Nodal Officer and bank shall respond to customer’s
complaint within 7 working days.
Level 4 – Internal Ombudsman
Again, If there is no response from the Principal nodal officer within 7 working
days, or if the customer is still not satisfied with the response, the customer
may write to the Internal Ombudsman, a person appointed under clause 5 of
the internal ombudsman scheme,2018 and he/she may be a retired or
servicing officer but below the rank of deputy general manager or equivalent
of another bank/financial sector regulatory body.
However, while performing all these steps Customers are required to quote
the complaint reference number provided to them in their earlier interaction
with the Bank in order to help them understand and address their concerns.
If the customer’s complaint is not resolved within the given time or the
customer is not satisfied by the resolution provided by the Bank, he /she can
appeal to the Banking Ombudsman, RBI.
The Reserve Bank of India has appointed an Ombudsman’s, who can be
approached for redressing customer grievances if they have not already been
redressed by respective Banks. But before that:
• The complainant should have made a written representation to respective
banks, and the Bank should have either rejected it or not replied to
complainant for a maximum period of one month the complainant or the
complainant was not satisfied with the reply given.
• The complaint is made not later than one year after the complainant has
received reply to his/her representation or where no reply is received from
respective banks not later than one year and one month after the date of the
representation to respective Banks.
• The complaint has not been settled by the Ombudsman in any previous
proceedings.
• The complaint is not the subject matter of proceedings before any court,
tribunal, arbitrator or any other forum.
• The complaint is made before the expiry of the period of limitation
prescribed under the Indian Limitation Act, 1963 for such claims.
(a)Ground of complaints
An unhappy customer can lodge a complaint with the Banking Ombudsman
with respect to the following grounds alleging deficiency in banking including
internet banking or other services like
 Non-payment or unreasonable delay in the payment /collection/ issue of
cheques, drafts, bills etc.;
 Non-acceptance of small denomination notes and coins tendered for any
purpose, and for charging of commission in respect thereof;
 Non-payment or delay in payment of inward remittances;
 Non-adherence to prescribed working hours;
 Delay or failure to provide any banking facility (other than loans and
advances) which has been promised in writing by the Bank
 Delay or non-credit of proceeds to the respective parties’ accounts, non-
payment of deposit or non-observance of the RBI directives, with
respect to the rate of interest on bank deposits
 Complaints from NRIs having accounts in India in relation to their
remittances from abroad, deposits and other bank related matters;
 Refusal to open deposit accounts without any valid reason for this
refusal;
 Levying charges without adequate prior notice to the customer;
 Non-adherence to RBI instructions on ATM / Debit Card /Prepaid Card /
Credit Card operations in India by the bank or its subsidiaries
 Non-adherence to RBI instruction with regard to Mobile Banking /
Electronic Banking service in India.
 Non-disbursement or delay in disbursement of pension
 Refusal to accept or delay in accepting payment towards taxes.
 Failure or Delay with regard to the issue, service or redemption of
Government securities;
 Forced closure of deposit accounts without any notice or without giving
sufficient reason;
 Refusal to close or delay in closing accounts;
 Not following the fair practices code as adopted by the bank;
 Non-observance of Reserve Bank guidelines on engagement of recovery
agents by banks;
 Non-adherence to RBI guidelines on allied-banking activities like sale of
insurance or mutual fund or other investment products by banks
  Any other matter relating to the violation of RBI directives
Regarding loans and advances, complaints with respect to the following areas
can be lodged:
 Non-observance of Reserve Bank Directives on interest rates;
 Delays in sanction, disbursement or non-observance of prescribed time
schedule for disposal of loan applications;
 Not accepting application for loans without furnishing valid reasons to
the applicant; and
 Non-observance of any other direction or instruction given by the
Reserve Bank as may be specified by the RBI for this purpose from time
to time.
STATISTICAL DATA OF GROUND OF COMPALINTS
As per the statistical data
The Complaints on non-observance of FPC constituted the largest number of
complaints in 2017-18 and 2018-19. However, in the year 2019-20, complaints
related to ATM/ Debit Cards surpassed FPC as the ground with the highest
number of complaints. The upsurge in complaints related to Credit Cards and
Mobile/ Electronic Banking was also observed. On the part of ATM / Debit Card
complaints, a major part was from ‘Account debited but cash not dispensed by
ATMs’ with a share of 46.95% in the ATM related complaints and ‘Debit in
account without use of the card or details of the card’ increased substantially
from 12.27% to 23.23% of the total ATM / Debit Card complaints.
Banks To Display Salient Features of The Scheme for Common Knowledge Of
Public.
(1) The banks covered by the Scheme shall ensure that the purpose of the
Scheme and the contact details of the Banking Ombudsman to whom the
complaints are to be made by the aggrieved party are displayed prominently in
all the offices and branches of the bank in such manner that a person visiting
the office or branch has adequate information of the Scheme.
(2) The banks covered by the Scheme shall ensure that a copy of the Scheme is
available with the designated officer of the bank for perusal in the office
premises of the bank.
(3) The banks covered by the Scheme shall appoint Nodal Officers at their
Regional/Zonal Offices and inform the respective Office of the Banking
Ombudsman under whose jurisdiction the Regional/Zonal Office falls. The
Nodal Officer so appointed shall be responsible for representing the bank to
the Banking Ombudsman in respect of complaints filed against the bank.
(4) Disclosure of complaints - The Committee on Procedures and Performance
Audit on Public Services (CPPAPS) has recommended that banks should place a
statement before their Boards analyzing the complaints received. Further, it
has been told that all details including unimplemented awards of the Banking
Ombudsman should also be disclosed along with financial results in the format
stated here. Banks should give wide publicity to the grievance redressal
through advertisements and also by placing them on their web sites.
B. COMPLAINT RELATING TO INTEREST RATES
Complaint: The complainant's father’s joint Fixed Deposit was under partition
suit hence it was not renewed on maturity date. In the meantime, both the
account holders expired. After obtaining succession certificate and settlement
of partition suit the complainant submitted claim for payment of fixed deposit
with up-to-date interest. The Bank had paid the maturity value but without
interest for overdue period.
Decision: The banking ombudsman stated that as per RBI Circulars, more
weightage has been given to the deceased accounts in the matter on the
subject of making payment of interest for the overdue period and the bank
paid the interest for the overdue period after mutual agreement.
C. NON-HONOURING OF BANK GUARANTEE
Complaint: The complainant claimed that the validity of a Bank guarantee (BG)
issued in the complainant’s favour was up to 30.08.2003 and that the BG was
invoked on 22.08.2003 during its validity, whereas the bank contended that
the validity of BG was only up to 30.07.2003 and the BG was not invoked
during its validity.
Decision: BO stated that facts of the case revealed that a correction had been
made in the expiry date of the BG written in numbers in the guarantee
extension letter, which was delivered to the complainant (beneficiary) through
the applicant. Therefore, the complaint was rejected in terms of clause 19(2) of
the Banking Ombudsman Scheme.
Naveen
Power to call for information
All the maintainable complaints are called by banking ombudsman for
redressal
(1) For that purpose, a Banking Ombudsman may require the bank against
whom the complaint is made to furnish certified copies of any document
relating to the complaint which is or is alleged to be in its possession.
(2) The Banking Ombudsman shall maintain confidentiality of any information
or document that may come into his knowledge or possession in the course of
discharging his duties and shall not disclose such information or document to
any person except with the consent of the person furnishing such information
or document for any legal requirement or the principles of natural justice and
fair play in the proceedings.
After this stage, the banking ombudsman can redress the complaints by way of
mutual agreement, issue of awards and rejection of complaint as necessary.
First
Settlement of complaint by agreement
(1) the Banking Ombudsman shall send a copy of the complaint to the branch
or office of the bank named in the complaint, under advice to the nodal officer
referred to in Sub-Clause (3) of Clause 15 can enable promotion of settlement
of the complaint by agreement between the complainant and the bank
through conciliation or mediation.
(2) For the purpose of promoting a settlement of the complaint, the Banking
Ombudsman shall not be bound by any rules of evidence and may follow
procedure as he may consider just and proper, however, Banking Ombudsman
should provide an opportunity to the complainant to furnish his/her
submissions in writing along with documentary evidence within a time limit on
the written submissions made by the bank.
If the Banking Ombudsman is of the opinion that the documentary evidence
furnished and written submissions by both the parties are not conclusive
enough to arrive at a decision then he may call for a meeting of bank or the
concerned subsidiary and the complainant together to promote an amicable
resolution and such meeting held for resolution of the grievance shall be
documented along with proceedings and signed by the parties specifically
stating that they are agreeable to the resolution and after that Banking
Ombudsman shall pass an order recording the fact of settlement annexing
thereto the terms of the settlement.
(3) The Banking Ombudsman may deem the complaint as resolved when the
complaint is resolved as per said procedure earlier by settlement or
intervention of the Banking Ombudsman; or by the Banking Ombudsman
based on the conciliation and mediation efforts.
Next way- Award by the Banking Ombudsman
(1) If a complaint is not settled by agreement within a period of one month
from the date of receipt of the complaint even after affording the parties a
reasonable opportunity to present their case, Banking ombudsman can pass an
Award.
(2) The Banking Ombudsman shall take into account the evidence placed
before him by the parties, the principles of banking law and practice,
directions, instructions and guidelines issued by the Reserve Bank from time to
time and such other factors which in his opinion are relevant to the complaint
while passing an award.
(3) The Banking ombudsman shall state briefly the reasons for passing the
award.
(4) The Award passed by BO under Sub-Clause (1) shall contain the direction/s,
if any, to the bank for specific performance of its obligations or otherwise, the
amount, if any, to be paid by the bank to the complainant by way of
compensation for any loss suffered by the complainant, arising directly out of
the act or omission of the bank.
(5) in case of Notwithstanding anything contained in Sub-Clause (4), the
Banking Ombudsman shall not have the power to pass an Award directing
payment of an amount towards compensation which is more than the actual
loss suffered by the complainant as a direct consequence of the act of omission
or commission of the bank, or two million rupees whichever is lower. The
compensation that can be awarded by the Banking Ombudsman shall be
exclusive of the amount involved in the dispute.
(7) A copy of the Award shall be sent to the complainant and the bank by BO.
8) After this it is customer’s duty to furnish a letter of acceptance of award
within 30 days from date of receipt of copy of award otherwise, the award will
have no effect and final settlement of his claim cannot be made except when
complainant has filed an Appeal under Sub-Clause (1) of clause 14.
(9) Similarly, the bank shall within one month from the date of receipt by it of
the acceptance in writing of the Award by the complainant under Sub-Clause
(8), comply with the Award and intimate compliance to the Banking
Ombudsman.
Next, the banking ombudsman have the power to reject the maintainable
complaint on certain grounds instead of settlement of agreement or issuing an
award.
Rejection of the Complaint
(1) The Banking Ombudsman can opt for rejection of maintainable complaint if
it appears to him that the complaint made is:
a. not on the grounds of complaint referred to in clause 8; or
b. otherwise not in accordance with Sub Clause (3) of clause 9; or
c. beyond the pecuniary jurisdiction of Banking Ombudsman prescribed under
clause 12 (5) and 12 (6): or
d. requires consideration of elaborate documentary and oral evidence and as
the proceedings before the Banking Ombudsman are not appropriate for
adjudication of such complaint; or
e. complaint is without any sufficient cause; or
f. complaint is not pursued by the complainant with reasonable diligence; or
g. In the opinion of the Banking Ombudsman there is no loss or damage or
inconvenience caused to the complainant.
(2) if it appears at any stage of the proceedings that the complaint pertains to
the same cause of action for which any proceedings were already made before
any court, tribunal or arbitrator or any other forum and decision is still pending
or a decree or Award or order has been passed by any such court, tribunal,
arbitrator or forum, then banking ombudsman shall pass an order rejecting the
complaint giving reasons thereof.
As per the STATISTICAL DATA OF MODE OF SETTLEMENT of COMPLAINT BY
BANKING OMBUDSMAN
The share of maintainable complaints disposed by way of mutual settlement/
agreement has gone up to 72.34% during 2019-20 as compared to 69.88%
during 2018-19 and 65.83% during 2017-18, indicating the increasing share of
complaints being resolved through mediation. The time taken by BOs to
dispose a complaint increased significantly to 95 days during the year 2019-20
as compared to 47 days a year ago.
And in case of rejection of complaints, the number of maintainable complaints
rejected has increased in absolute number from 26,905 in 2018-19 to 47,873 in
2019- 20. The maximum number of rejections was on the ground that the
complaint was ‘not on the grounds of complaint (Clause 8)’ or ‘not filed in
accordance with required provisions of Clause 9 (3)’, accounting for 98.30% of
the rejected maintainable complaints in 2018-19 and 98.64% in 2019-20.
And during the year 2019-20, 68 Awards were issued by BOs of which only 38
were implemented.
Appeal Before the Appellate Authority
(1) After the settlement of complaint, if any Party to the complaint is satisfied
by an Award under Clause 12 or rejection of a complaint for the reasons
referred to in sub clauses (d) to (g) of Clause 13, may within 30 days of the date
of receipt of communication of Award or rejection of complaint, file an appeal
before the Appellate Authority against decision of BO.
A period of thirty days is allowed for filing an appeal from the date on which
the bank receives letter of acceptance of Award by complainant under Sub-
Clause (8) of Clause 12 and in some cases Appellate Authority may extend time
by another 30 days if there is a sufficient cause for not filing appeal within 30
days. Appeal may be filed by a bank only with the previous sanction of the
Chairman or any other officer of equal rank in his absence.”
(2) The Deputy Governor-in-Charge of Consumer Education and Protection
Department (CEPD), RBI is designated as the Appellate authority as per the
provisions of BOS, 2006. CEPD provides the secretariat to it.
After giving the parties a reasonable opportunity of being heard, Appellate
authority can either
(a) dismiss the appeal; or
(b) allow the appeal and set aside the Award; or
(c) remand the matter to the Banking Ombudsman for fresh disposal in
accordance with such directions as the Appellate Authority may consider
necessary or proper; or
(d) modify the Award and pass such directions as may be necessary to give
effect to the Award so modified; or
(e) pass any other order as it may deem fit.
3) The order of the Appellate Authority shall have the same effect as the Award
passed by Banking Ombudsman under Clause 12 or the order rejecting the
complaint under Clause 13, as the case may be.
AS per STATISTICAL DATA OF APPEALS AGAINST THE DECISIONS OF THE BOs
During the year 2019-20, 63 appeals were received as compared to 78 appeals
during the previous year. Of these, 34 appeals were received from
complainants who were aggrieved by the decision of the respective BOs
whereas 29 were filed by the banks against Awards. With 72 appeals pending
from the previous year, the Appellate authority handled 135 appeals during
the year. Eighty-eight appeals were disposed during the year.
D. COMPLAINTS RELATING TO LOANS
Complaint:
Complainant availed a Housing loan of Rs 3 lakhs from the bank in July 2000 for
the purpose of construction of a residential building repayable in 168 monthly
instalments at an interest rate of 12.25%. The complainant requested to
reduce the interest rate to 7.75%, but the bank refused to do so stating that
the revised interest rate was applicable to loans sanctioned with a repayment
period of 5 years. So, he approached AA Bank and after processing the 49
documents and inspection of site they took over the loan by paying a cheque
for Rs 266,000/- to BB bank who charged Rs. 5242/- as pre-closure charges.
Decision: when the complaint was taken up it was found that bank had
recovered Rs 5242/- as foreclosure charges as per their circular dated
14.05.2002 which they have not mentioned in the loan sanction letter nor
communicated it subsequently before debiting the charges and therefore were
to refund Rs 5242/- to the complainant.