Consumer Complaint (Khyber Pakhtunkhwa)

BEFORE THE LEARNED CONSUMER COURT, district, Khyber Pakhtunkhwa

Consumer Complaint No. _____ of year

complainant_name, son/daughter of complainant_father, resident of complainant_address, holding CNIC No. complainant_cnic ... Complainant

VERSUS

respondent_name, resident of respondent_address ... Respondent

CONSUMER COMPLAINT

Respectfully submitted:

1. That the Complainant is an aggrieved consumer as defined under the Khyber Pakhtunkhwa Consumer Protection Act 1997, having purchased product_or_service from the Respondent on purchase_date for Rs. purchase_price.

2. That the Respondent is a trader, manufacturer, or service provider engaged in the business of business_description.

3. That the product_or_service supplied by the Respondent defect_or_issue.

4. detailed_facts

5. That the aforesaid violation_type constitutes an unfair trade practice or breach of the Respondent's obligations under the Act.

6. That as a direct consequence of the Respondent's violation_type, the Complainant suffered loss and damage quantifiable at Rs. amount_claimed (amount_in_words).

7. That the Complainant made a written demand to the Respondent on demand_date for relief_sought, but the Respondent has respondent_response.

8. That the Complainant filed the present complaint within the period prescribed by law and this Consumer Court has jurisdiction to entertain the same under the KP Consumer Protection Act 1997.

9. That no other forum or remedy is available to the Complainant for redressal of the grievance.

That the cause of action has accrued wholly within the territorial jurisdiction of this Honourable Court at territorial_jurisdiction_basis, and the value of the subject-matter of the suit is within the pecuniary jurisdiction of this Honourable Court. The suit has been valued at Rs. suit_valuation for purposes of court fee and jurisdiction.

That the requisite court fee of Rs. court_fee_paid has been duly affixed on the plaint in accordance with the Court Fees Act 1870. The suit is properly stamped and is otherwise maintainable in form and substance.

That the Plaintiff has approached this Honourable Court with clean hands, has made full and frank disclosure of all material facts, and has not concealed anything that might be relevant to the just decision of the suit.

That the Plaintiff has not previously instituted any suit, application, or other proceedings in respect of the same cause of action before any other forum, and there is no other suit, appeal, or revision pending between the same parties on the same subject-matter, save and except as expressly stated above.

PRAYER

It is, therefore, humbly prayed that this Honourable Court may be pleased to:

(a) relief_prayer_1;

(b) Award compensation of Rs. amount_claimed (amount_in_words) in favour of the Complainant;

(c) Award costs of this proceeding; and

(d) Pass such other order as may be deemed just and proper.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of the above complaint are true and correct to the best of my knowledge and belief.

TERRITORIAL JURISDICTION

This Honourable Consumer Court has territorial jurisdiction to entertain the present complaint as the cause of action has arisen, the Respondent carries on business, and the Complainant resides within the territorial limits of this Court, in terms of the Khyber Pakhtunkhwa Consumer Protection Act 1997.

LIMITATION

The present complaint is filed within the prescribed period of limitation under the Khyber Pakhtunkhwa Consumer Protection Act 1997. The cause of action arose on cause_of_action_date.

_____________________________ complainant_name Complainant Through: _____________________________ counsel_name Advocate