BEFORE THE STATE CONSUMER DISPUTES

REDRESSAL COMMISSION, NEW DELHI

(ORIGINAL JURISDICTION)

CONSUMER COMPLAINT NO. __________OF 2013

IN THE MATTER OF :-
MR. PAWAN PURI & ANR
.....COMPLAINANT(S)
VERSUS

TDI INFRASTRUCTURE LTD.

.......RESPONDENT

CONSUMER COMPLAINT UNDER

SECTION 17 OF THE CONSUMER
PROTECTION ACT, 1986 (AMENDED
UPTO DATE) FOR UNFAIR TRADE
PRACTICE AND GRAVE DEFICIENCY
AND DISCREPANCY IN SERVICES ON
THE PART OF THE RESPONDENT
ALONGWITH COMPENSATION FOR
HARASSMENT AND MENTAL AGONY

To,
The Hon’ble President,
& Other Members of the
State Consumer Dispute Redressal Commission,
New Delhi.

THE COMPLAINANT MOST RESPECTFULLY SUBMITS AS

UNDER:-

1. That the present complaint has been preferred by Mr. Pawan

Puri and his wife Mrs. Leena Puri, herein after referred to as

the Complainants. That the Complainants are Consumers as

defined under Section 2 (d) (ii) of the Consumer Protection

Act, 1986 and are permanent residents of Delhi at the

aforesaid address. That the Complainants are peace loving

citizens and have a good reputation in the Society.

2. That the Respondent, TDI INFRASTRUCTURE LTD. is a

Limited Company incorporated under the Companies Act,

1956, popularly known as TDI Developers, having its

registered office in Delhi. That formerly the Respondent was

known as INTIME PROMOTORS PVT. LTD. and TDI

INFRASTRUCTURE PVT. LTD. as per the records available

with the Complainants. That the Respondent is engaged in

the business of real estate such as construction of buildings,

malls, complexes, etc. for residential and commercial

purposes throughout India.

That facts and circumstances leading to to filing of the

present petition are briefly stated as follows:-

3. That in the year 2006, the Respondent publicly announced

that it was setting up an Integrated Township under the

name and style of TDI City at Kundli, Sonepat, Haryana

Project. Thereafter, the Respondent announced to build a

mall-cum-multiplex under the project named RODEO DRIVE

at TDI City, Kundli, Sonepat, Haryana.

4. That the Respondent announced sale of the constructed

shops/ units in the said complex to its prospective buyers.

5. That the Complainant no. 1 and Complainant no. 2 have jobs

in the private sector in New Delhi and in view of no security

of job in the private sector due to cut throat competition they

decided to purchase a shop in the aforesaid project of the

Respondent in Kundli, Sonipat for opening a grocery shop.

 It is humbly submitted that booking of the shop was solely

for the personal purpose and livelihood of the Complainants.

6. That the Complainants being interested in the location,

design and concept of the said complex / project decided to

invest their hard earned money towards the purchase of one

commercial shop in the said complex. It is submitted that the

Complainants approached the Respondent and showed their

interest to buy a shop /unit in the said complex, located on

the Ground Floor and bearing shop/unit no. 196, having

covered area of 335.00 sq.fts. and super built up area 500.00

sq.ft at Rodeo Drive, TDI City, Kundli, Sonepat, Haryana

(hereinafter referred to as “Said Shop”). That the Respondent

agreed to sell the Said Shop for a consideration of Rs.

27,50,000/- (Twenty Seven Lac Fifty Thousand Rupees)

being an amount calculated at Rs. 5500/- (Five Thousand

Five Hundred Rupees) per square feet.

7. In furtherance of the aforesaid, the Complainants made an

advance payment of Rs. 5,50,000/- (Five Lakh Fifty Thousand

Rupees) to the Respondent at the time of booking of the Said

Shop. That the Complainants issued a cheque of Rs.

2,00,000/- (Two Lakhs) dated 09/05/2006; Rs. 2,00,000,/-

(Two Lakhs) dated 12/05/2006, and Rs.1,50,000,/- dated

15/05/2006-, bearing cheque nos. 186970, 186971 and 186972

respectively, drawn on ABN AMBRO Bank, New Delhi in

favour of the Respondent against the booking amount of the

Said Shop.
 The true copies of the said cheques issued by the

Complainants in favour of the Respondent have been

attached and annexed herewith as Annexure A/1.(Colly). The

said cheques were duly encashed by the Respondent.

8. That on 09/05/06, after advancing payment of booking

amount of the Said Shop, the Complainants requested for the

receipt of the same. It is further submitted that the

Respondent issued an acknowledgement receipt bearing no.

42456 of the total payment of Rs. 5,50,000/- (Five Lakhs Fifty

Thousand Rupees only) in respect of the booking amount of

the Said Shop. That the Complainants customer ID no. is

KCC-10110.

A true copy of the receipt bearing no. 42456 of the total

payment of Rs. 5,50,000/- issued by the Respondent has been

attached and annexed herewith as Annexure A/2.

9. It is further submitted that on 09/05/06, at the directions of

the Respondent, the Complainant filled in the Respondent’s

standard application form for registration of the Said Shop.

That as per the terms and conditions of the said registration

form the Respondent agreed to issue formal letter of

allotment within a stipulated period of 6 months from the

date of the registration application and undertook that the

sale deed would be executed and got registered in favour of

the Complainants within a “reasonable time” period.

A true copy of the advance registration form dated 09/05/06

is attached and annexed herewith as Annexure A/3.

10. That the Complainants further submit that after repeated

requests to issue the letter of allotment in respect to the Said

Shop, the Respondent did not issue the same. That finally on

31/08/2006, the Respondent issued a letter of allotment

pertaining to the Said Shop. That the said letter of allotment

was duly signed by the authorised signatory of the

Respondent.

A true copy of the letter of allotment dated 31/08/06 is

attached and annexed herewith as Annexure A/4.

11. That thereafter the Respondent started demanding from the

Complainants the next instalment towards the construction

of the Said Shop. It is pertinent to note that as demanded by

the Respondent, the Complainants paid the 2nd instalment

totalling Rs. 2,75,000/- (Rupees Two Lakh Seventy Five

Thousand) to the Respondent vide a cheque no. 428505 dated

06/12/06 for Rs. 90,000/- (Rupees Ninety Thousand), vide a

cheque no. 428506 dated 20/12/06 for Rs. 90,000/-(Rupees

Ninety Thousand) and vide a cheque no. 428507 dated

30/12/06 for Rs. 95000/- (Rupees Ninety Five Thousand),

drawn on Corporation Bank, New Delhi. Subsequently the

Respondent issued the acknowledgement receipt towards the

said consideration amount paid by the Complainants bearing

no. 54520, 54521 and 54522 respectively dated 05/12/06 as

part of the 2nd instalment qua the Said Shop.

The true copies of the said cheques and the respective

receipts given by the Respondent are attached and annexed

herewith as Annexure A/5. (Colly)

12. It is further submitted that the Complainants bonafidely

released the aforementioned amount in as much as to receive

the peaceful & timely possession of the Said Shop but

unfortunately the Respondent failed to inform the

Complainants as regards the progress of the construction

activities at the said project site. Further the Complainants

were under an impression that the construction activities

would have commenced after the said letter of allotment was

issued in their favour by the Respondent and, therefore, in

furtherance of the same, they planned to visit the project site,

in order to have a look as to the present status of the said

project.

13. That in view of the aforesaid, the Complainants in or about in

the month of March 2007 (i.e. after approx. 10 months of

booking the Said Shop and paying the first instalment) made

a personal visit to the project site for the purposes of having a

feel of the construction activities. However, the Complainants

were utterly shocked to see that neither the construction had

commenced nor there was any indication to that effect.

Thereafter the Complainants inquired from the office of the

Respondent about progress at the project site to which they

were informed by the office bearers of the Respondent that

everything is in order and the construction activity would

begin shortly. That the Complainants were very much

optimistic about the completion of the project after an

assurance was given by the Respondent. However, still

doubts arose in their minds in view of their visit to the

project site wherein they had witnessed the absence of any

 proper construction activities. The Complainants even started

demanding a written confirmation from the Respondent’s

official to handover the timely possession of the Said Shop

but unfortunately all efforts failed.

14. That further it is submitted that on the basis of the express

representation and assurances by the Respondent that

construction shall commence forthwith and a formal Builder

Buyers Agreement will soon be executed, and on

Respondent’s insistence and undue threat of cancellation of

the whole arrangement and forfeiture of amounts already

paid, the Complainants had no option but to pay the 3rd

instalment towards the purchase of the Said Shop

aggregating to Rs. 2,75,000/- (Rupees Two Lakhs Seventy

Five Thousand). That the payment was made vide a cheque

no. 428509 dated 23/03/07 for Rs. 90,000/- (Rupees Ninety

Thousand) vide a cheque no. 428510 dated 01/04/07 for Rs.

90,000/-(Rupees Ninety Thousand) and vide a cheque no.

and a cheque no. 428511 dated 10/04/07 for Rs. 95000/-

(Rupees Ninety Five Thousand) drawn on Corporation Bank,

New Delhi. That consequently the Respondent issued a duly

acknowledged receipts of the said payments towards the 3rd

instalment vide receipt nos. 62585, 62586 and 62587 dated

23/03/07 respectively.

The true copies of the cheques issued by the Complainants

alongwith duly acknowledged receipts given by the

Respondent are attached and annexed herewith as Annexure

A/6.(Colly)
15. That thereafter, the Complainants was under an impression

that the Respondent will proceed further towards completing

the project, executing the Builder Buyers Agreement but to

their utter dismay the Respondent further informed the

Complainants that there were some additional charges also

to be borne and paid by the Complainants in addition to the

said payments, the Complainants have paid to the

Respondent. The Respondent also informed the

Complainants that since the payments received till then by

the Respondent from the Complainants had not added up to

40% of the total consideration price of the Said Shop, the

Builder Buyers Agreement could not be executed. The

Respondent insisted on further payment and threatened to

cancel the arrangement if payment was not made. It is

pertinent to mention herein that the Complainants in view of

such remarks made by the Respondent, released a further

part payment of Rs. 1,00,000/- (Rupees One Lakh). That the

Complainants issued a cheque of Rs. 50,000/- (Rupees Fifty

Thousand) vide a cheque no. 093522 and Rs. 50,000/-

(Rupees Fifty Thousand) vide a cheque no. 523013

respectively drawn on Deutsche Bank, New Delhi in favour

of the Respondent. That consequently the Respondent upon

issuance of the said cheques in its favour by the

Complainants issued a duly acknowledged receipts of the

payments vide receipts no. 63009 and 64571 dated 02/04/07

and 07/05/07 respectively.

 The true copies of the duly acknowledged receipts as against

the said cheques given by the Respondent are attached and

annexed herewith as Annexure A/7.(Colly)

16. Further the Complainant submits that despite several

reminders given to the Respondent, Builder Buyers

Agreement was not executed and every effort of the

Complainants towards the execution of the said Agreement

went in vain. That afterwards the Complainants regularly

met the authorised representatives of the Respondent in

respect of the development of the Project and execution of the

Builder Buyers Agreement but no satisfactory information

was provided to them. However, in one of the meetings, the

Respondent’s representative communicated to the

Complainant No. 1 that for the moment the Respondent’s

focus, primarily, was on the residential projects and they

would take up commercial projects only upon the completion

of the residential projects. It is important herein to mention

that the Respondent was invariably giving false assurances

to the Complainants qua the commencement and completion

of the project and complete formalities of the formal Builder

Buyers Agreement and further to give physical possession of

the Said Shop. That by not executing the said agreement with

the Complainants on the part of the Respondent and

unnecessary delay in handing over the physical possession of

the Said Shop to the Complainants, clearly establishes the fact

that the Respondent always had an ill intention to harass &

grab the hard earned money of the Complainants. It is

further submitted that the representatives of the Respondent

 have always been evasive in giving correct justification

and/or explanation for the delay in the development of the

Project and execution of the Builder Buyers Agreement.

17. In furtherance, shamelessly, the Respondent started

demanding the balance payment from the Complainants

towards the purchase of the Said Shop. Nevertheless the

Complainants refused to pay any further amount till there

was substantial progress in the implementation of the project

and execution of the formal Builder Buyers Agreement. The

Respondent threatened to forfeit the amounts paid by the

Complainants and cancel the arrangement if the payment

was not made. By now the Complainants had made 40% of

the purchase price and the Said Shop was nowhere in sight.

Undue threat of cancellation, the Complainants had no

option but to pay under protest the remaining amount

pursuant to the 4th instalment of Rs. 1,75,000/- (Rupees One

Lakh Seventy Five Thousand). That the Complainants

released a cheque of Rs. 1,37,500/- (Rupees One Lakh Thirty

Seven Thousand Five Hundred) vide cheque no. 428520

drawn on Corporation Bank, New Delhi and a cheque of Rs.

37,500/- (Rupees Thirty Seven Thousand and Five Hundred)

vide cheque no. 290449 dated 10/12/07 drawn on ABN

AMRO Bank, New Delhi in favour of the Respondent. That

consequently the Respondent issued a duly acknowledged

receipt of the payment towards the remaining amount of the

4th instalment vide receipts no. 70057 and 70056 dated

26/11/07 respectively.
 The true copies of the cheques issued by the Complainants

with duly acknowledged receipts given by the Respondent is

attached and annexed herewith as Annexure-A/8.(Colly)

18. Further, it is submitted that despite the payment of 50% of

the total consideration amount, the Respondent had not

executed the Builder Buyers Agreement and further even

after several reminders, the Respondent failed to hand over

the physical possession of the Said Shop. That thereafter, the

Complainants had no other option and/or remedy than to

stop making any further payments to the Respondent.

19. That on 23/11/2009, the respondent had sent a letter to

execute the Builder buyer’s agreement of shop no. GF-196 in

rodeo drive mall at Kundali Sonipat with the complainants. It

is to submit that the respondent in its letter has admitted that

the complainant had made payments to them towards the

said shop and the Builder buyer’s agreement still has not

been executed. Therefore, the respondent asked to make a

visit to their office not later than one week for the execution

of the said agreement. As per respondent assurance the

complainant visited to their office for the execution of the

said agreement but the respondent failed to perform its

obligation and returned the complainants with bare hands.

A true copy of the letter of the Respondent to execute the

builder buyer’s agreement dated 23/11/2009 is attached and

annexed herewith as Annexure-A/9.

20. That shockingly the complainants received a demand letter

dated 08.01.2010 where the respondent company requested

to remit the remaining payments towards the purchase of the

Said Shop. It is pertinent to note that the respondent

company was demanding money for the ulterior motive and

to grab the money of the complainant since the respondent

company never executed the builder buyer’s agreement.

Undisputedly the complainant had already made payment of

50% of the total consideration and neither the builder buyer’s

agreement was executed nor the construction of the said

complex was completed therefore, the complainants decided

not to remit balance payment until the respondent execute

the builder buyer’s agreement and to complete the

construction of the said complex.

A true copy of the demand letter of the Respondent dated

08.01.2010 is attached and annexed herewith as Annexure-

A/10.

21. Furthermore, the Complainants submit that after repeated

requests to execute the said agreement the Respondent

started cooking up new stories and surprisingly sent

reminder letters to the Complainants for overdue payments

towards the purchase of the Said Shop. That the Respondent

demanded 80% payment of the total consideration. As the

complainant had already made payment of 50% of the total

consideration amount and there was no progress visible on

the site towards construction of the Said Shop and the issue

of execution of the Builder Buyers Agreement was being

 ignored by the Respondent, therefore the question of

payment of 80% of the total consideration did not arise.

22. That thereafter, the Complainants made various attempts to

enquire about the progress of the project but was again

utterly shocked and surprised when they came to know that

though the construction activities were on, the same was too

slow to be completed in near future. It is now six years since

the Said Shop was agreed to be sold to the Complainants.

That it is further submitted that even after six long years the

construction work is still going on at a very slow pace and

the same appears to be an astonishing fact to the

Complainants but helplessly the Complainants were eagerly

waiting for the reply of the Respondent. Further the

Complainants made a surprise visit to the project site in and

around in the months of June & July, 2012 wherein they took

photographs of the ongoing construction activities at RODEO

DRIVE at TDI City, Kundli, Sonepat, Haryana. It is relevant

to submit that some of the photographs taken by the

Complainants are evidentiary in nature showing thereby that

the project had started but was nowhere near to completion

even in the months to ensue. Even the Respondent has

uploaded on its website in the form of newsletters, the actual

status of their project which admittedly establishes the fact

that the said commercial project is nowhere near to

completion in near future. That some photographs of the

project site of Respondent’s Newsletters uploaded on its

website and web pages showing the Project as underdeveloped

and claim by the Respondent that they have consistent track record
 of timely completion have been duly attached with the

complaint for the kind perusal of this Hon’ble Commission.

The true copies of some of the photographs of project site

dated 23/06/12, copies of the relevant pages of newsletters

relative to May 2008, April 2011 & April 2012 and Web pages

dated 25/07/2012 are attached and annexed herewith as

Annexure-A/11.(Colly).

23. That on 25/05/12, after making all possible efforts to resolve

the issue amicably, the complainant wrote a letter to the

Respondent for the refund of Rs. 13,75,000/- (50% of the

total consideration) along with an interest @ 24% thereof, 15

days of the date of this letter failing which the complainant

will be forced to take any legal recourse. It is informed that

the said letter was duly served to the Respondent. That as

usual the Respondent failed to act on the grievances of the

Complainants and has been enjoying the hard earned money

of the complainant for last six years. It is submitted that the

complainant demanded refund of deposited money since

there was no anticipation of completion of project and owing

to a fraud committed by the respondent by not executing the

builder’s buyers agreement.

A true copy of the letter dated 25/05/12, along with receipt is

attached and annexed herewith as Annexure-A/12.

24. It is humbly submitted that the complainant had filed the

present complaint earlier on 22/08/2012 vide Diary no. 4372

which came up for hearing before this Hon’ble Commission

 on 12/12/2012. That the Hon’ble commission had raised

some technical objections to the complaint therefore counsel

for the Complainant had withdrawn the complaint. That vide

Order dated 12/12/2012 the Hon’ble Commission had given

liberty to the counsel for the complainant to file a fresh

complaint.

An original copy of the Order dated 12/12/2012 passed by

the Hon’ble Commission in Complaint Case no. C-302/12 of

2012 filed by the present Complainant is attached and

annexed herewith as Annexure-A/13.

25. That the Respondent had already accepted the 50% payment

of the total consideration for the purchase of the Said Shop,

and had still not executed the Builder Buyers Agreement /

Construction Agreement since last six years, therefore, it not

only amounts to unfair trade practice on the part of the

Respondent but also to deficiency of services. It is further

submitted that the Complainants have been waiting for an

indefinite period to have the physical possession of the Said

Shop which the Respondent has failed to deliver the same

even in six long years thereby causing wrongful loss of time,

money, mental agony and harassment to the Complainants

and further making their life miserable.

26. In these circumstances, the Respondent is under obligation to

refund the total sum of Rs. 13,75,000/- (Thirteen Lakhs

Seventy Five Thousand Rupees) i.e. 50% of the total

consideration paid by the Complainants to the Respondent

as on date of filing alongwith 18% simple interest p.a. i.e.

 14, 51,358/- from the date of payment of each instalment till

the disposal of the present complaint. A total sum of Rs.

28,26,358/- (as calculated in Annexure A/14) is therefore due

and payable on July 31, 2012 from the Respondent to the

Complainants.

A true copy of the calculation sheet is attached and annexed

herewith as Annexure-A/14.

27. That the first cause of action for filing the present complaint

arose on 26/11/2007 when the present complainant had

released 50% of the total consideration however the builder’s

buyer agreement was not executed by the respondent.

Further on 23/11/2009 when the respondent sent a letter to

execute the said agreement and in spite of this failed to

perform its obligation. That again a cause of action arose

when the respondent demanded 80% of the total

consideration without executing the said agreement. And

finally on 25/05/2012, when the Complainants wrote a letter

to the Respondent which was duly served upon the

Respondent, stating therein to refund the 50% payment made

to the Respondent of the total consideration amounting to

Rupees 13,75,000/- (Rupees Thirteen Lakhs Seventy Five

Thousand) alongwith an interest of 24% per anum, within 15

days from the date of the receipt of the said letter and in the

event of Respondent’s failure to do so, the Complainants

would be forced to initiate legal proceedings against the

Respondent. That the cause of action is still continuing and

subsisting as no amount has been refunded to the

 Complainants and the same is due and payable by the

Respondent.

28. That the Complainants are the residents of Delhi and the

registered office of the Respondent is within the jurisdiction

of this Hon’ble court and further the cause of action for filing

of the present complaint also arose within the jurisdiction of

this court.

29. That the court fee for an amount of Rs. 2,000/- has already

been paid as per the value of the complaint i.e. Rs.

______________/- approx. vide Pay Order bearing no. 317052

dated 14/08/12 drawn on Deutsche Bank, K.G. Marg, New

Delhi. The same has been affixed with the case no. C-302 of

2012 as filed by the complainant.

30. That the present complaint has been filed within the

limitation period as stipulated under Section 24 A of the

Consumer Protection Act, 1986.

31. That no other such complaint has been filed by the

complainant in any other court of law.

PRAYER

In view of the facts and circumstances stated hereinabove, the

Complainants most humbly and respectfully pray that this Hon’ble

Court may graciously be pleased to:

(a) direct the Respondent to pay / refund to

the Complainants, the 50% of the total admitted

consideration amount for the Said Shop paid by the

 Complainants to the Respondent amounting to Rupees

13,75,000/- ( Rupees Thirteen Lakhs Seventy Five

Thousand) with interest @ 18% p.a. calculated as per

Annexure A.11 continuously from the date of payment of

each instalment and calculated upto July 31, 2012 which

amounts to Rs. 28,26,358/- ;

(b) direct the Respondent to pay 18% interest

p.a. on the above sum of Rs. 28,26,358/- from August 1,

2012 till the date of disposal of the present complaint;

(c) direct the Respondent to pay an amount of

Rs. 5,00,000/- as a compensation for the mental agony,

harassment and extreme hardships faced by the

Complainants for six long years.

(d) Direct the Respondent to pay

Complainants the cost of present litigation expenses;

(e) Pass any such other and further

orders/directions, which this Hon’ble Court may deem fit

and proper in the facts and circumstances of the present

case.

AND FOR THIS ACT OF KINDNESS THE PETITIONERS

SHALL AS IN DUTY BOND EVER PRAY.

COMPLAINANT

THROUGH

DELHI:
DATED:
PRATEEK TEWARI & ASSOCIATES
18, CENTRAL LANE,
BENGALI MARKET, NEW DELHI 110001
TEL +91 8800576518
 BEFORE THE HON’BLE STATE CONSUMER DISPUTES

REDRESSAL COMMISSION, DELHI.

(ORIGINAL JURISDICTION)

ORIGINAL COMPLAINT NO OF 2012

IN THE MATTER OF: -

MR. PAWAN PURI & ANR
.....COMPLAINANT(S)
VERSUS

TDI INFRASTRUCTURE LTD.

.......RESPONDENT
AFFIDAVIT
I, Pawan Puri R/o D-41A, Single Storey, Vijay Nagar, Delhi-11009,
Occupation Service, do hereby solemnly affirm and declare as under :-

1. That the Deponent is the Complainant in the above noted case

and is fully conversant with the facts and circumstances of this
case, hence competent to swear this affidavit.

2. That the contents of accompanying complaint has been drafted

and filed under my instruction by our counsel. The same is read
over to me in its vernacular and I have understood the same to
be true and correct to the best of my knowledge.

3. That the Deponent has not filed any other similar petition
seeking similar relief, either before this Hon’ble court or before
the Hon’ble Supreme court of India or any other Court.

DEPONENT

VERIFICATION:

Verified at Delhi on this day of August 2012 that the contents of the
above affidavit are true and correct to the best of my knowledge and
nothing material has been concealed therefrom.

DEPONENT
 BEFORE THE HON’BLE STATE CONSUMER DISPUTES

REDRESSAL COMMISSION, DELHI.

(ORIGINAL JURISDICTION)

ORIGINAL COMPLAINT NO OF 2012

IN THE MATTER OF: -

MR. PAWAN PURI & ANR
.....COMPLAINANT(S)
VERSUS

TDI INFRASTRUCTURE LTD.

.......RESPONDENT
AFFIDAVIT

I, Leena Puri R/o D-41A, Single Storey, Vijay Nagar, Delhi-11009,

Occupation Service, do hereby solemnly affirm and declare as under :-

4. That the Deponent is the Complainant in the above noted case

and is fully conversant with the facts and circumstances of this
case, hence competent to swear this affidavit.

5. That the contents of accompanying complaint has been drafted

and filed under my instruction by our counsel. The same is read
over to me in its vernacular and I have understood the same to
be true and correct to the best of my knowledge.

6. That the Deponent has not filled any other similar petition
seeking similar relief, either before this Hon’ble court or before
the Hon’ble Supreme court of India or any other Court.

DEPONENT

VERIFICATION:

Verified at Delhi on this day of August 2012 that the contents of the
above affidavit are true and correct to the best of my knowledge and
nothing material has been concealed therefrom.

DEPONENT