BEFORE DISTRICT CONSUMER DISPUTE REDRESSAL

COMMISSION, INDORE, MADHYA PRADESH

Consumer Complaint No. 245/2022

Between
Sparsh Goyal ----- Complainant
Versus

Jeeves Consumer Services Pvt. Ltd. ----- Opposite Party

EVIDENCE BY WAY OF AFFIDAVIT REPLY TO THE COMPLAINT ON

BEHALF OF THE OPPOSITE PARTY (JEEVES CONSUMER
SERVICES PVT. LTD.)

AFFIDAVIT OF MR. PRADEEP REDDY, S/O. LATE D.SUDARSHAN

REDDY, AGED ABOUT 39 YEARS, AUTHORISED SIGNATORY OF

OPPOSITE PARTY NO. 1 (JEEVES CONSUMER SERVICES PVT.

LTD.)

I the above named deponent do hereby solemnly affirm and declare as

under:

1. That I say that I am the authorised signatory of the opposite party

No. 1 (Jeeves Consumer Services Pvt. Ltd.) and I am well converse

with the facts and circumstances of the case and able to depose the

same.

MOST RESPECTFULLY SHOWETH

PRELIMINARY OBJECTIONS:

The Opposite Party seeks to submit the following Preliminary

Submissions, each of which has been taken in the alternative and is

without prejudice to the other. Nothing contained in the Preliminary

Submissions and in the Reply on Merits below may, unless otherwise

specifically admitted, be deemed to be direct and tacit admission of

any allegations made by the Complainant in the present Complaint.

The Opposite Party hereby denies all the allegations, contentions,

submissions and statements of the Complaint which are inconsistent

with what is stated herein below.

2. That at the very outset, it is submittedThat I say that the

Complainant has cooked all crooked stories of sufferings. The

Opposite party has already provided the refund to the complainant

as per the terms of extended warranty. Hence, the present

complaint is not maintainable and liable to be dismissed without

any further consideration.

3.

4. That it is submitted hereI say that the whole grievance of the

Complainant pertains to alleged non refund of the Television under

extended warranty (Hereinafter referred as “product”). The fact

needs to be recorded here that the Complainant is making all false

stories against the Opposite Party. The complainant is cooking all

crooked stories based on whims and fancies. The facts need to be

recorded here that when the complainant raised his grievance, the

Opposite party duly sent an expert technician to the address as

provided by the complainant. The expert technician duly

investigated the product and confirmed that the product of the

complainant is not in repairable condition. Thus as per the

extended warranty terms, the Opposite party requested the

complainant to share the bank details to provide refund. It is

 pertinent to mention here that the Opposite Party duly provided the

refund to the bank account as provided by the complainant. Thus

the grievance of the complainant has already been resolved as

refund has already been provided to the complainant as per the

terms of the extended warranty. Therefore there is no cause of

action present in the instant matter as the grievance of the

complainant has already been resolved. The present complaint has

been filed against the Opposite Party so as to extort money from the

Opposite Party in an illegal manner. Therefore the Opposite Party

submits that there is no deficiency in services on the part of

Opposite Party and by no stretch of imagination, it can be said that

the Opposite Party is involved in any unfair trade practices for the

reasons enumerated above.

5. That I say that the Opposite Party, Jeeves Consumer Services

Private Limited is a company engaged, among others, in providing

one stop service point for all electronics, electrical and IT products.

Jeeves helps households deal with their electronics and appliances

related problems by offering cost effective, reliable & quick

solutions and that makes Jeeves the preferred trouble shooting

partner for over 1 million homes. The Opposite Party also provides

after sales support to major brands/online portal / Large Retails

store, like installation, Repair Services during Warranty & Out of

Warranty Period for Electronics Appliances (Small & Large),

Furniture, Cycle etc

6. That Ms. Sanchi Chhabra, D/o Mr. Arun Chhabra aged about 26

Years, Authorised Signatory of the Company is authorized to sign

 and verify the Reply/Written Statement, Vakalatnama etc. and

appoint advocate(s) on behalf of the Opposite Party.

7. That I say that the Opposite Party only acts as an independent

third party service provider who provides aftersale services for

household products. The Opposite Party does not manufacture or

sell any product on its own or provides any kind of medium to the

public at large to facilitate transaction for sale & purchase of any

product.

8. That it is submitted that no dispute, as contemplated under the

Consumer Protection Act, is caused to have arisen between the

Complainant and the Opposite Party as the refund has already

been provided to the complainant.

9.

PARAWISE REPLY ON MERITS:-

That the content of Para No. 1 and 2 of the present complaint so far as the

details of the complainant being the consumer of the Opposite party is

matter of record and needs no specific reply. Rest of the content is False,

frivolous and misleading hence denied. It is submitted that the Opposite

Party duly provided the refund to the bank account as provided by the

complainant. The Opposite party has duly played its part of the transaction.

Thus the grievance of the complainant has already been resolved as refund

has already been provided to the complainant as per the terms of the

extended warranty. There has been no deficiency in services on the part of

Opposite Party and by no stretch of imagination, it can be said that the

Opposite Party is involved in any unfair trade practices with the

complainant. The Opposite party has not caused harassment, mental

tension, agony, pain or hardship of any sort to the complainant. The

Opposite Party corroborates with the content of preliminary submissions and

the same is not repeated herein for the sake of brevity.

1. That the contents of Para No. 3 of the present Complaint so far as

the details pertaining to the purchase of extended warranty by the

complainant is matter of record and needs no specific reply. Rest

of the content is False, frivolous and misleading hence denied. It is

submitted here that when the complainant raised his grievance,

the Opposite party duly sent an expert technician to the address

as provided by the complainant. The expert technician duly

investigated the product and confirmed that the product of the

complainant is not in repairable condition. Thus as per the

extended warranty terms, the Opposite party requested the

complainant to share the bank details to provide refund. It is

pertinent to mention here that the Opposite Party duly provided

the refund to the bank account as provided by the complainant.

Thus the grievance of the complainant has already been resolved

as refund has already been provided to the complainant as per the

terms of the extended warranty. The Opposite Party corroborates

with the content of preliminary submissions and the same is not

repeated herein for the sake of brevity.

2. That the content of Para no. 4 of the complaint is mere statement

and needs no specific reply from the Opposite Party.

10.That the content of Para No. 5 of the present complaint is False,

frivolous and misleading hence denied. It is reiterated here that

the Opposite Party has duly provided the refund to the bank

account as provided by the complainant. The Opposite party has

 duly played its part of the transaction. ThusThat I say that the

grievance of the complainant has already been resolved. There has

been no deficiency in services on the part of Opposite Party and by

no stretch of imagination, it can be said that the Opposite Party is

involved in any unfair trade practices with the complainant. The

Opposite party has not caused physical pain, mental agony,

trauma or hardship of any sort to the complainant. The Opposite

party is not liable to provide compensation of any sort to the

complainant. The Opposite Party corroborates with the content of

preliminary submissions and the same is not repeated herein for

the sake of brevity.

11.That the content of Para No. 6 of the present Complaint is false,

frivolous and misleading hence denied. It is submitted here that

the Opposite Party has not received any legal notice from the

complainant. Further the complainant has failed to produce any

concrete evidence in support of his averments made against the

Opposite Party. The complainant must be put to strict proof for the

same.

12.

13. REPLY TO PRAYER CLAUSE

14. That I say As it is clear from the above mentioned that the

Complainant has failed to establish any cause of action under the

provisions of the Consumer Protection Act, against the Opposite Party

in the present Complaint as the refund has already been provided to

the complainant as per the terms of the extended warranty. Hence, the

relief claimed under the present Complaint is not maintainable against

the Opposite Party. Hence,

15. It is further submitted that the relief claimed under the present

complaint is untenable and unreasonable as the refund has already

been provided to the complainant as per the terms of the extended

warranty and the Opposite Party, under the circumstances and for the

reasons stated above, is not liable to pay any further amount as

refund, interest, compensation, cost or any other relief to the

Complainant as alleged in the Complaint.

PRAYER

It is therefore, most respectfully prayed that in the facts and

circumstances as submitted hereinabove, this Hon’ble Commission

may be pleased to:

a. Dismiss the complaint against Opposite Party with exemplary

costs awarded to Opposite Party and,

b. to pass such other order or further orders as this Hon’ble

Commission may deem fit and proper in the facts and

circumstances of the present case

The Complainant is also not entitled to claim any relief either in law or

in equity against the Opposite Party.

It is prayed accordingly.

DEPONENT

OPPOSITE PARTY
Jeeves Consumer Services Private Limited
Ms. Sanchi Chhabra
Authorized Signatory

Through:
Advocate for Opposite Party
Date: ………., 2022
Place:

VERIFICATION

Verified that the contents of Para No. 1 to 8 6 of the Foregoing

Evidence preliminary objections and contents of 1 to 5 of Para wise

reply on merits are true and correct to my knowledge derived from

official record and no part of it is false and nothing material has been

concealed therefrom.

Verified at _______________ on this _____ day of _____, 2022.

OPPOSITE PARTYDEPONENT
 BEFORE DISTRICT CONSUMER DISPUTE REDRESSAL
COMMISSION, INDORE, MADHYA PRADESH
Consumer Complaint No. 245/2022

Between
Sparsh Goyal ----- Complainant
Versus

Jeeves Consumer Services Pvt. Ltd. ----- Opposite

Party

AFFIDAVIT
Affidavit of Ms. Sanchi Chhabra, D/o Mr. Arun Chhabra, aged about
26 Years Opposite Party, Buildings Alyssa, Begonia &
Clover, Embassy Tech Village, Outer Ring Road, Devarabeesanahalli
Village, Bengaluru–560103, Karnataka, presently at
_________________.
I, the above named deponent do hereby solemnly affirm and declare
as under:-
That the deponent is the duly Authorised Signatory of the Opposite
Party in the aforesaid complaint and is well conversant with the facts
of the present case.

That the contents of the accompanying Reply to the Complaint are

true and correct to the best of my knowledge and as per the records
available, and the same are not being reproduced herein for the sake
of brevity.

Deponent
VERIFICATION:
Verified at _______________ on ______ day of _________, 2022 that the
contents of Para No. 1 and 2 of my above affidavit are true and
correct to the best of my knowledge. No part of it is false and nothing
material has been concealed there from.
Deponent