Insurance Claim Petition before Insurance Tribunal

IN THE INSURANCE TRIBUNAL, jurisdiction

Petition No. petition_number of petition_year

claimant_name, aged claimant_age years, claimant_designation, CNIC No. claimant_cnic, resident of claimant_address PETITIONER(S) vs. insurance_company_name, a company incorporated under the Insurance Ordinance 2000, having principal office at insurer_address RESPONDENT(S)

VERSUS

PETITION UNDER SECTION 122 OF THE INSURANCE ORDINANCE 2000 FOR DETERMINATION OF DISPUTED INSURANCE CLAIM

Respectfully Sheweth:

1. The petitioner hereby humbly submits that he/she is deeply aggrieved by the arbitrary, unjustified, and unlawful decision of the respondent insurance company dated dispute_decision_date by which the respondent has unjustly rejected, denied, repudiated, and refused to pay the legitimate and valid insurance claim of the petitioner filed under the insurance policy bearing policy number policy_number issued on policy_issue_date. The repudiation is entirely without merit and contrary to law.

2. The petitioner took out a comprehensive insurance policy with the respondent company for the insured amount of PKR insured_amount for the period commencing coverage_start_date and expiring coverage_end_date. The policy was issued in accordance with the Insurance Ordinance 2000 and all regulations made thereunder. The policy document, comprising policy_pages pages, contains the full terms and conditions which are binding on both parties. The petitioner has complied with all requirements of the policy.

3. The petitioner duly paid all insurance premiums as required by the policy without any default or omission. Premium payments of PKR total_premium were made on premium_payment_dates, well within the due dates. The insurance contract was valid, subsisting, and in full force and effect at the time of the loss occurrence or claim event. No policy exclusion or limitation applies.

4. On loss_date, a covered loss event occurred as expressly defined and covered under the insurance policy. loss_description_details. The petitioner promptly submitted a formal claim dated claim_submission_date for compensation in the sum of PKR claim_amount, along with all necessary supporting documentation including claim_supporting_docs. The claim was submitted within the time limit prescribed by the policy.

5. The respondent company, upon receiving the claim, engaged in prolonged and vexatious correspondence spanning correspondence_period months and made multiple requests for further documentation, investigation reports, and clarifications. The petitioner provided every piece of information, document, and evidence requested by the respondent. Despite this full cooperation, the respondent arbitrarily rejected the claim on dispute_decision_date.

6. The respondent's grounds for rejection are wholly unjustified, factually incorrect, and legally unsustainable. grounds_for_rejection. The loss that occurred clearly and unambiguously falls within the scope of coverage stipulated in the policy. The petitioner's loss is covered by the policy terms and is not subject to any applicable exclusion or limitation.

7. Section 122 of the Insurance Ordinance 2000 vests exclusive jurisdiction in the Insurance Tribunal to hear and determine disputes between insureds and insurers. The dispute herein is squarely within the ambit of this jurisdiction. The Insurance Tribunal is the competent forum to redress this grievance and ensure compliance with statutory obligations imposed by the Insurance Ordinance 2000.

8. The petitioner has suffered considerable loss and financial hardship due to the wrongful repudiation of the claim by the respondent. financial_hardship_details. The petitioner is entitled to receive the full claim amount along with interest and costs as matter of right.

9. The respondent's conduct in repudiating the claim constitutes a clear breach of the contract of insurance and a flagrant violation of the obligations imposed by the Insurance Ordinance 2000. The respondent has acted with gross negligence and in bad faith in rejecting a valid and covered claim.

PRAYER

WHEREFORE, the petitioner respectfully prays that this Hon'ble Insurance Tribunal may be pleased to: (a) Determine and declare that the petitioner is entitled to the full claim amount of PKR claim_amount under the insurance policy; (b) Direct the respondent insurance company to pay the full claim amount of PKR claim_amount along with markup at the rate of markup_rate% per annum from the date of claim submission claim_submission_date until full realization and satisfaction of the award; (c) Award costs of this petition including counsel fees of PKR counsel_fees; (d) Award interest on the claim amount at the rate of interest_rate% per annum from the date of claim submission till date of payment; (e) Pass such other and further orders as deemed fit and proper in the circumstances of the case.

VERIFICATION

I, claimant_name, the petitioner above-named, do hereby solemnly affirm and declare that the contents of this petition are true to my knowledge and belief and have not been concealed or misrepresented in any manner. I understand that if any statement in this petition is found to be false, I shall be liable for prosecution under the relevant laws of Pakistan.

Signed and dated this _____ day of _____________, 20_____ at signing_city _______________________ claimant_name Petitioner _______________________ counsel_name Barrister-at-Law Bar Council Enrolment No. bar_number Advocate for Petitioner