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IN THE HON’BLE DISTRICT COSUMER DISPUTES

REDRESSAL FORUM, KADAPA.

CC No. 51 OF 2024

Bandlepalli Sree Sandhya … Complainant

V/s

1. State Bank of India, Rep by its Manager


Yerramukkapalli Branch.
2. State Bank of India, Rep by its Regional Manager,
Kadapa City.
3. State Bank of India, Rep by its Zonal Manager,
Tirupati.
4. Bandlepalli Sarada
5. Bandlepalli Sudhir Kumar Reddy … Opposite Parties

WRITTEN VERSION FILED ON BEHALF OF THE


OPPOSITE PARTY No.5

1. It is submitted that the complaint filed by the complainant is neither


just nor maintainable, either in law or in facts of the case.

2. It is submitted that, all the averments mentioned in the complaint,


are devoid of truth and fabricated, for the purpose of filing this complaint
with ultivare motives only.

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3. It is absolutely false to say that, the complainant and OP No.4 jointly
gave representation to OP No.1, for freezing the locker.

4. It is absolutely false to that, OP No. 4 and 5 were allowed by OP


No.1 to operate the locker, without the knowledge of the complainant in
spite of giving several representations by the complainants.

5. It is also false to say that on 02.03.2023, the OP No.1 gave reply


with unstainable averments. The complainant supressed the true facts, and
not approached the Hon’ble Commission with clean hands.

6. It is submitted that, the relationship between the complainant and


OP No. 4 and 5 was Co-Applicant in respect of the locker No. 6/13 in OP
No.1 bank, till the marriage of the complainant which took place in or
around the year 2008. After fixation of her marriage, the complainant had
taken another locker in The HDFC Bank, Yerramukkapalli circle, Kadapa
City. After that she moved out all her belongings from the OP No.1 banks
bearing No. 6/13. At the time of moving her belongings from the locker
6/13, the complainant gave an application to OP No.1 bank, with request
to delete her name from the ownership of the locker No.6/13. Accordingly,
based on the application given by the complainant, her name was duly
removed from the bank records books, including register extract, the name
of the

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complainant was rounded off, and the signatures of OP No.4 and 5 are
alone remained and the operational instructions are recorded as anyone or
survivor. Thus, for the past 16 years, i.e., from 2008 onwards the
complainant is not Co-Applicant to the locker 6/13, and the same is bear
out by the bank records maintained by OP No.1. since then, the Opposite
parties 4 and 5 are maintaining the locker, by paying the annual rent
amount regularly to the OP No.1. in the meanwhile, some internal family
differences developed between the complainant and the OP No.5. The
Complainant began to act adversely to the interests of OP No.5 in all
aspects, in order to wreak vengeance against OP No.5, the complainant
managed to take advantage of OP No.4 ill-health, as she is suffering from
dementia. The complainant obtained the signatures of OP N0.4 on blank
white paper, and misused the same and submitted to the bank on
22.07.2022, as if it is meant for closing the locker on verifying the same
the bank staff made it clear, that the complainant is not the locker hirer as
for the bank records books as such they did not allow her to close the
locker, due to lack of consent from OP No5, who is one of the locker hirer
as per the bank records.

7. It is further submitted that, due to health reasons the OP No.5


decided to stay with her son i.e., OP No.5, who is her son in the Bengaluru
city, and so both of them approached OP No.1 and gave an application to
close the locker on 27.1.2023. The

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concerned bank staff verified the records, including the locker rent
register, and upon conformation that OP No.4 and 5 are the locker hirers,
the OP No.1 closed the said locker on 27.01.2023, as per the rules and
regulations of the bank. From the aforesaid facts and circumstances, it is
very clear that, the complainant had not at all accessed the bank locker for
more than 15 years, as per the bank records. Hence, the complainant is
legally estopped from making any claims or grievances or complainant
because he has no locus standi, and her name was duly removed from the
names of hirers of the locker, as per the bank records on the basis of her
application after lapse of more than 15 years, the complainant resorted to
file this complaint with all the false and untenable allegations as part of
personal grudges only which is not admissible in law. Thus, the claim of
the complainant is hopelessly barred by law of limitation. There is no
merit in the complaint, and same is filed with an oblique motive to harass
the Opposite Parties only. The question for deficiency of service, or
causing mental agony to the complainant do not arises at any stretch of
imagination. Filing of present complaint, is a classic example of abusing
the process of law. The complaint is filed without bonafides, and without
any genuine intentions but with malafide intention, to malign the banking
process, which were perfectly discharged by the OP No.1 to 3 without any
flaws, in the entire process of closing the bank locker, as per the banking
rules and regulations, as such there is no merit in the complaint filed by the
complainant. The complainant is thus, bereft of bonafide grounds and
liable to be dismissed.

It is, therefore, prayed, that the Hon’ble Commission


may be pleased to dismiss the complaint with exemplary costs.

CONFIRMATION
The facts stated above are true and correct to the best of my knowledge
belief and information and I signed this on day of July of 2024 at
Kadapa.

Advocate for OP No.5

IN THE HON’BLE DISTRICT


COSUMER DISPUTES
REDRESSAL FORUM,
KADAPA.

CC No. 51 OF 2024

Bandlepalli Sree Sandhya


… Complainant
V/s
1. State Bank of India, Rep by its
Manager Yerramukkapalli Branch.
2. State Bank of India, Rep by its
Regional Manager, Kadapa City.
3. State Bank of India, Rep by its Zonal
Manager, Tirupati.
4. Bandlepalli Sarada
5. Bandlepalli Sudhir Kumar Reddy
… Opposite Parties
WRITTEN VERSION FILED
ON BEHALF OF THE
OPPOSITE PARTY No.5

Filed by: -

Sri K. Vijay Krishna

Advocate, Kadapa

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