AVM Jonnalagadda Rajendra, AVSM VSM, (Retd) Presiding Member

1. The present Consumer Complaint has been filed under Section 21 of the Consumer Protection Act, 1986 (for short "the Act") against the Opposite Parties (OPs) seeking the following:

                          a) This Commission be pleased to award an amount of Rs.2,36,95,578.81, along with interest thereon calculated @ 18% p.a. to the Complainants payable to the Complainants jointly and severally by the Opposite Parties.

                          (b) For cost of the present proceedings;

                          (c) For such further and other reliefs as this Commission may deem fit and proper."

2. Brief facts of the case, as per the Complainants, are that Complainant No.1, who an 82 year-old senior citizen, and his daughter, Complainant No.2, maintained "Premier" accounts with OP-1 Bank, where OP-3 was appointed as their Relationship Manager in December 2011. Over the years, OP-3 executed a systematic fraudulent scheme by abusing her position of trust to liquidate Complainant No.1‟s high- value portfolio, which included Aditya Birla Group equities, Mutual Funds valued and UTI Master Shares, to fund unauthorized insurance policies. The deception began in July 2013 with a Rs.5 lakh policy sold under misrepresentation regarding its recurring nature and 10 year lock- in period, and escalated throughout 2014 when OP-3 redeemed the Complainants' mutual funds by obtaining signatures on blank forms under the guise of "KYC compliance." This unauthorized liquidation caused a severe liquidity crunch, forcing her to divert business income to meet basic household expenses. By March 2016, the Complainants discovered that at least six life insurance policies Nos.0041351716, 0045467918, 0045649314, 0049971416, 0054450120 and 0042222220 were surreptitiously issued. These policies involved massive premiums, including individual sums as high as Rs.15,00,000, which were processed despite Complainant No.2‟s documented gross annual income being as low as Rs.10,422 to Rs. 13,014. The Complainants had meetings with OP-3 in March, 2016, wherein OP-3 and a senior official of OP-1 admitted the unauthorized redemptions undertaken by the Bank. Following a formal complaint vide Ref No.2603872529, the Complainants uncovered further gross discrepancies, including falsified marital status and misrepresented income data inserted into the policies by OP-3. Despite a formal complaint vide Ref No.2603872529 and appeals to the Banking Ombudsman, OP-1 remained non-responsive, eventually serving notices of policy discontinuance for the funds drained from their savings. The Complainants issued a legal notice to the OPs on 11.08.2016, and filed Criminal Complaints before the Azad Main Police Station in August, 2016, alleging fraud, breach of trust, and collusion. While OP-1 repeatedly sought extensions for their „internal investigation‟ through September 2016, no conclusive resolution was provided, compelling them to escalate the matter to the Joint Commissioner of Law and Order and the Assistant Police Commissioner in October 2016, categorically stating that OP-3 had redeemed their mutual funds solely to earn their commissions in the transactions, thereby cheating the complainants of their life savings and committing offenses punishable under Sections 420, 467 and 468 of the Indian Penal Code. After seeking relief through the IRDA and the Reserve Bank of India, and receiving a final refusal for compensation from the Banking Ombudsman in May 2017, the Complainants filed the present Consumer Complaint to recover their life savings and seek damages for their financial losses. The complainants sought the prayer made by them in the complaint be allowed.

3. Upon issue of notice, the complaint was resisted by OP-1 & 3 by filing their written statement denying any deficiency in service and raising preliminary objections. It was contended that the complainants had suppressed material facts and indulged in forum shopping by simultaneously approaching the Banking Ombudsman. The OPs further argued that no cause of action existed against OP-1&3, that allegations of fraud involved disputed questions of fact requiring detailed evidence beyond the scope of summary proceedings before this Commission, and that there was no privity of contract between the complainants and OP-1 & 3 in respect of the insurance policies. It was contended that the complainants voluntarily shifted their investments from stocks and mutual funds into insurance products after due consultation, while OP-1 merely facilitated the transactions upon written authorization and consent. It was also contended that no services were availed from OP-3 in her personal capacity nor any consideration paid to her. Therefore, her name deserved deletion from the array of parties. On merits, the OPs asserted that the complainants were fully aware that they were purchasing life insurance policies, which stood established from the pre- issuance medical examinations undertaken in relation to the policies. In this regard, reliance was placed upon medical tests conducted on 22.08.2013 and 30.08.2013 for Policy No. 0041351716, on 17.02.2015 in respect of Policy No.0049971416 wherein the daughter of Complainant No. 2 was the life assured, and on 26.11.2015 for Policy No.0054450120. According to the OPs, the complainants voluntarily signed the medical examination reports which specifically recorded that the tests were being conducted for issue of life insurance policies, thereby disproving the plea that they were unaware of the nature of the products purchased. The OPs further contended that the complainants consciously executed the proposal forms after due understanding of the terms, conditions, risks, premium amounts, policy term and sum assured, whereupon OP-2 issued and dispatched the policies to their registered addresses. It was contended that OP-2 also conducted "welcome calls" confirming the essential features of the policies and that the complainants were granted the statutory free-look period of 15 days to cancel the policies in case of dissatisfaction. However, no objection was raised within the said period and, on the contrary, the complainants continued paying renewal premiums and even purchased additional policies in the years 2014 and 2015, which, according to the OPs, clearly demonstrated conscious acceptance of the policies and falsified the allegation that signatures were obtained on blank papers or that the policies were issued without consent. The OPs further contended that the complaint suffered from material contradictions, inasmuch as the complainants simultaneously alleged non-receipt of policy documents while also admitting that the same had been handed over to their Chartered Accountant. It was contended that the complaint was hopelessly barred by limitation, as the cause of action in respect of Policy No. 0041351716 had arisen on 25.09.2013 upon receipt of the policy documents. Despite receipt of policy copies, welcome and validation calls, SMS alerts regarding premium deductions, letters and emails, the complainants remained silent for several years and did not raise any grievance within the statutory period prescribed under Section 24A of the Consumer Protection Act, 1986. Instead, after receipt of the first policy, they proceeded to purchase further policies bearing Nos. 0045467918 and 0045649314 in June 2014 and Policy No.0054450120 in November 2015. According to the OPs, such continued conduct in purchasing additional policies and paying premiums clearly contradicted the allegation of surreptitious issuance. It was also pointed that even though complainants filed multiple police complaints, no FIR or criminal case was registered, and no further proceedings were initiated before the competent Magistrate or Court, thereby indicating absence of any genuine grievance. The OPs additionally challenged the maintainability of the complaint on grounds of pecuniary and territorial jurisdiction, alleging that the complainants had artificially inflated their claims based on speculative and hypothetical losses allegedly suffered from sale of equity shares and mutual funds. The affidavit of one Mr. Chirag Gohil was also disputed as unreliable and incapable of cross-examination. It was further contended that OP-1 acted merely as a facilitator/ intermediary and had no role in issuance of the policies, while relationship managers only assisted clients in understanding investment options and did not take investment decisions on their behalf. Accordingly, they prayed for dismissal of the complaint.

4. OP 2 filed its written statement and challenged the maintainability of the complaint on both factual and legal grounds, asserting that the Complainants were guilty of suppressio veri and suggestio falsi by concealing material facts to harass and extort money from the OPs. OP-2 denied all allegations, specifically refuting the claim that mutual funds were redeemed and reinvested into life insurance policies without consent through forged signatures. It was contended that these allegations involving criminal intent fell outside the summary jurisdiction of this Commission, requiring adjudication by a court of competent civil or criminal jurisdiction. OP-2 raised a preliminary objection regarding forum shopping, noting that the Complainants had initiated multiple parallel proceedings before the Banking Ombudsman, RBI, IRDA, and various police authorities, including the Azad Maidan Police Station. Invoking the principle of uberrima fides, the company established that it had strictly complied with Regulation 6(2) of the IRDA (Protection of Policyholder Interest) Regulations, 2002. It was contended that the Complainants, being educated individuals, voluntarily applied for six insurance policies between August 2013 and November 2015. By signing the proposal forms, which included binding declarations, the Complainants confirmed that all statements provided were true and would form the basis of the insurance contract. To substantiate informed consent, OP-2 highlighted that Complainant No.2 and the life assured, Ms. Pearl Dastur, underwent pre-issue medical examinations between 2013 and 2015, signing reports that explicitly indicated the purpose was for life insurance issuance. The company further proved that policy packs were delivered via Blue Dart and that the Complainants were repeatedly briefed on the 15-day Free Look Period through documented welcome and validation calls. Despite being fully cognizant of their right to cancel, the Complainants chose to continue the policies and paid multiple annual premiums before defaulting on renewals. Following the non-payment of premiums within the five-year lock-in period, fund values were transferred to the Discontinued Policy Fund as per the agreed terms. Upon the termination of policies 0041351716 and 0042222220 in 2018, OP 2 transferred Rs.18,25,042 and Rs.17,57,359 respectively into the Complainants' bank accounts via NEFT. Finally, OP-2 contended that the claim was barred by limitation, as the cause of action first arose on 25.09.2013, yet the Complainants continued to purchase additional policies thereafter. Procedurally, the complaint was labelled bad in law due to mis-joinder and non-joinder of relevant parties, specifically the failure to implead Aditya Birla, and mis- joinder of cause of action against OP-1, who acted only as a facilitator. Asserting the alleged financial losses are "imaginary and pretentious,"

                          OP-2 prayed for the dismissal of the complaint with exemplary costs.

5. The Complainants had filed rejoinder to the Written Statement filed by the OP and reiterated the facts of the complaint.

6. The Complainants filed their evidence on Affidavit and relied on copy of Proposal Form bearing Proposal No. 1100330049 for Life Insurance in favour of Complainant No. 2 (Annexure P-42); Forensic Reports dated 18.09.2017 and 23.11.2017 issued by Titiksha Desai Kamble (Annexure P-43); Reply dated 12.01.2018 by Central Public Information Officer, RBI under the RTI Act, 2005 to the letter dated 08.12.2017 sent by the Complainant No. 2 (Annexure P-44), Order dated 29.07.2019 passed by the State Police Complaints Authority, Maharashtra State, Mumbai in SPCA/CC No. 579/2018 (Annexure P-45), FIR No. 268/2019 dated 12.11.2019 registered at PS Azad Maidan, Mumbai by Complainant No.2 against OPs (Annexure P-46); Application for condonation of delay on behalf of complainants for filing affidavit, and Proof of Service by way of evidence.

7. OP-1 filed its evidence on by Affidavit and relied on Authority Letter dated 30.06.2020 (Exh.OPW1/1). OP-2 filed its evidence by way of affidavit and relied on copy of Authority Letter dated 15.07.2019 (Exh. OPW2/1); emails to the Complainant (Exh. OPW 2/2); policy packs sent by OP-2 to the Complainants which was admittedly received by the Complainants (Exh. OPW 2/3); and chart showing the date of commencement of policies, number of premiums paid, date of delivery of policy and other particulars regarding the policy (Exh. OPW 2/4).

8. The learned counsel for the Complainants reiterated the averments made in the complaint and contended that the acts of OP-1 to OP-3 constituted gross deficiency in service, unfair trade practice, fraud, misrepresentation and reckless misselling of financial products. It was argued that the OPs, instead of acting fairly and transparently, unauthorizedly liquidated the complainants‟ mutual fund investments and diverted the proceeds into multiple insurance policies, thereby causing substantial financial loss. The learned counsel asserted that OP-3, who had been managing their financial portfolio since December 2011, was fully aware of their age, financial profile and dependence on income generated from mutual funds. Yet, she induced them into purchasing six insurance policies solely for earning commissions, despite there being no insurable necessity. He argued that the complainants reposed complete faith in OP-3 and had signed documents in good faith without understanding their contents. They came to know only during the meeting dated 19.03.2016 that most of the mutual funds of Complainant No.1 had already been redeemed and invested in insurance policies without their informed consent. It was also alleged that OP-3 had represented that only a one-time investment of Rs.5 lakhs was required for one policy and obtained signatures on blank forms without proper disclosure. Reliance was also placed on the letter dated 22.09.2016 issued by OP-1, which acknowledged that OP-3 had guided them regarding affixation of signatures on the proposal forms. He argued that there was no justification for liquidating stable mutual fund investments and equities to invest their life savings in six insurance policies with long lock-in periods and poor returns. He reiterated that OP-1 and OP-3, in collusion with OP-2, mis-sold the policies solely to earn commissions. It was further argued that OP-3 instructed them to answer "Yes" during verification calls, that the proposal forms contained discrepancies and unauthorized particulars, and that false information and forged signatures were inserted in the insurance documents in breach of the OPs‟ fiduciary obligations. The complainants also relied upon the order dated 29.07.2019 passed by the State Police Complaints Authority, Maharashtra, wherein certain observations were made regarding the suspicious conduct of OP-1 and OP-3 and the apparent wiping out of the complainants‟ savings through unauthorized insurance policies. It was argued that although the said order and consequential FIR were quashed subsequently on the grounds of jurisdiction, the findings recorded therein on merits were never disturbed. Reliance was further placed upon the affidavit of Mr. Chirag Gohil, Financial Advisor with Aditya Birla Finance Ltd., who allegedly corroborated the unusual insistence of OP-3 upon liquidation of equity holdings while concealing redemption of mutual funds already undertaken by her. It was further argued that this consumer complaint was maintainable notwithstanding criminal or other proceedings initiated before different forums, as the remedies under the Consumer Protection Act were in addition to remedies available under other laws. The learned counsel for the complainants asserted that due to the fraudulent liquidation of their investments, they suffered wrongful financial loss, deprivation of regular income from dividends and interest, as well as severe mental, physical and financial hardship, whereas the OPs wrongfully benefited through commissions earned from the insurance policies. He sought that OP-1 to 3 be directed jointly and severally to restore and compensate the complainants for the losses.

9. On the other hand, the ld. Counsels for OP 1 & 3 raised preliminary objections regarding maintainability, limitation, jurisdiction, and absence of deficiency in service. It was argued that the complaint involved complicated and disputed questions of fact, including allegations of forgery, misrepresentation, obtaining signatures on blank papers, and fabrication of documents, which required detailed trial, oral evidence, and cross-examination of witnesses and thus could not be adjudicated in summary proceedings under the Act. With respect to the allegations of forgery of signatures and getting signatures on blank papers by misrepresentation, it was contended that neither the alleged forensic reports relied on by the Complainant dated 18.09.2017 and 23.11.2017 nor copies thereof nor affidavit/evidence of the concerned expert had been furnished on record. The learned counsel further argued that OP-1 and OP-3 were neither necessary nor proper parties, as OP-3 was merely an employee and relationship manager of OP-1, while the insurance policies was admittedly issued by OP-2. It was also submitted that there existed no privity of contract between the complainants and OP-1, which acted only as an intermediary/facilitator. He argued that the complaint filed on 12.03.2018 was barred by limitation and that the complainants had complete knowledge of the policies since inception, as welcome letters, proposal forms, policy documents, renewal notices, SMSs, validation calls, and medical examinations had taken place during 2013 and 2015. They admittedly paid renewal premiums and never exercised the free-look cancellation option. Reliance was also placed upon Section 45 of the Insurance Act, 1938 to contend that the policies could not be questioned beyond three years from issuance. The complainants were educated and seasoned investors who consciously invested in the policies and had ultimately received surrender value exceeding the premium amount paid, besides enjoying insurance coverage during subsistence of the policies. The learned counsel also alleged that the complainants had indulged in forum shopping by approaching the Mumbai Police, State Police Complaints Authority, IRDA, RBI, and Banking Ombudsman prior to filing this complaint, while suppressing material facts and orders passed therein. They exaggerated the claims solely to invoke the pecuniary jurisdiction of this Commission. They paid Rs.40,50,000 as premium and already received Rs.47,15,738.64 as surrender value. The complaint suffered from non- joinder of necessary parties, namely Chirag Gohil and Aditya Birla Finance Ltd, who managed their investments. The sale of equity shares was made jointly by them and their financial advisor, for meeting personal liabilities. It has no nexus with purchase of insurance policies.

10. The learned counsel for OP-2 vehemently argued that the complainants themselves admitted availing banking and financial services from OP-1 to 3 for management and expansion of their finances, yet subsequently alleged fraud, misrepresentation, misappropriation, cheating, forgery and fabrication of documents by the OPs. It was contended that the allegations were inherently improbable, particularly when the premiums had been debited from the complainants‟ own bank accounts and medical examinations and verifications had been conducted prior to issuance of the policies. He further argued that the complaint involved serious disputed questions of fact, fraud and forgery, which could not be adjudicated in the summary jurisdiction under the Act, 1986. Reliance was placed on Chairman and Managing Director, City Union Bank Ltd. and Another Vs. R. Chandramohan, (2023) SCC OnLine SC 341 and Oriental Insurance Co. Ltd. v. Munimahesh Patel, (2006) 7 SCC 655 and Post Office Vs. Ramesh Chand Bhatia, 2024 SCC OnLine NCDRC 411, to contend that such matters requiring detailed evidence and adjudication of rival expert reports were beyond the scope of consumer proceedings. The OP-2 further raised an objection regarding limitation and submitted that the policies had been issued between 2013 and 2015, whereas the complaint came to be filed only in March, 2018, without any application for condonation of delay under Section 24A of the Act, 1986. It was argued that the complainants continued with the policies without protest and had not exercised the "free look" option, thereby signifying acceptance of the contracts. Reliance was placed upon State Bank of India v. B.S. Agricultural Industries, (2009)5SCC121, Kandimalla Raghavaiah & Co v National Insurance Co. Ltd., (2009) 7 SCC 768 and Haryana Urban Development Authority v. B.K. Sood to contend that limitation under Section 24A is mandatory and a time-barred complaint cannot be entertained in absence of a reasoned order condoning delay. It was also argued that the dispute arose out of investment and redemption of mutual funds and ULIP policies undertaken with a view to earn profits and appreciation in value, which constituted commercial transactions outside the purview of the Act. It was contended that persons engaging in speculative investment transactions cease to be "consumers" within the meaning of the Act. He placed reliance on Ram Lal Aggarwalla v. Bajaj Allianz Life Insurance Co. Ltd., NCDRC RP no. 658 of 2012 and Surendra Kapur vs. M/s Puja Construction Ltd., C.C. No. 307 of 2013. The learned counsel OP-2 painstakingly argued that the complainants had not approached the Commission with clean hands, inasmuch as they had enjoyed life cover of approximately Rs.1.50 crores during subsistence of the policies and, upon discontinuation thereof, already received an aggregate amount of about Rs.47,15,735 as surrender value between 07.09.2018 and 09.12.2020, which fact had not been properly disclosed. Reliance was placed upon Canara Bank & Ors. vs. Debasis Das & Ors., AIR 2003 SC 1561, to contend that a party seeking equitable relief must approach the Court with clean hands. He sought the complaint be dismissed with exemplary costs as being false, frivolous, speculative and an abuse of the process of law.

11. We have examined the pleadings and the associated documents placed on record and rendered thoughtful consideration to the arguments advanced by the learned counsels for both the parties.

12. The principal grievance of the complainants is that OP-1 to OP-3, by abusing the fiduciary relationship reposed in them, unauthorizedly liquidated the complainants‟ mutual funds and equity investments and diverted the proceeds into multiple insurance policies without informed consent, thereby causing severe financial loss and hardship to the complainants. On the other hand, the OPs have contended that the complainants consciously and voluntarily purchased the policies after due disclosures, medical examinations, welcome calls and receipt of policy documents, and that the present complaint is a speculative attempt to recover alleged market losses after the complainants became dissatisfied with their investments.

13. The first issue which arises for consideration is whether the present complaint is maintainable before this Commission in view of the objections regarding limitation, alleged forum shopping, jurisdiction and the plea that the dispute involves complicated questions of fraud and forgery beyond the scope of summary consumer proceedings.

14. The OPs have strongly contended that the complaint is barred by limitation since the first policy was issued in September, 2013 whereas the complaint came to be filed only in March, 2018. The complainants were fully aware of the policies from inception in view of the proposal forms, medical examinations, policy documents, validation calls and payment of renewal premiums. We are unable to accept the aforesaid contention in its entirety. The complainants consistently maintained that they became aware of the magnitude and nature of the impugned transactions only in March, 2016 when they discovered that substantial mutual fund investments had already been redeemed and diverted into multiple insurance policies. The record reveals that immediately thereafter they initiated complaints before the Banking Ombudsman, RBI, IRDA and police authorities. The continuous correspondence exchanged between the parties during the period 2016 - 2017 supports the complainants‟ contention that the grievance crystallized only upon discovery of the alleged unauthorized transactions. At the same time, it also cannot be ignored that the complainants admittedly underwent medical examinations in relation to several policies and signed proposal-related documents. The complainants also admittedly received policy documents and continued payment of certain premiums over a period of time. Thus, while the plea of complete ignorance regarding the existence of the policies cannot be accepted in absolute terms, the question whether the complainants had given free, informed and conscious consent to the entire transaction remains a matter requiring examination on merits.

15. The objection regarding maintainability on the ground that the complaint involves allegations of fraud and forgery also does not merit outright acceptance. Mere allegation of fraud does not automatically oust the jurisdiction of the Consumer Fora. The present dispute substantially concerns alleged deficiency in banking and insurance services, suitability of financial advice and misselling of insurance products, all of which can appropriately be examined on the basis of the material placed on record. The Consumer Fora are competent to determine whether there has been unfair trade practice or deficiency in service, even where incidental allegations of misrepresentation or unauthorized conduct arise. The contention regarding forum shopping is equally devoid of substance. The remedies available under the Consumer Protection Act are in addition to remedies available under other statutes. Merely because the complainants approached the Banking Ombudsman, RBI, IRDA and police authorities prior to filing the present complaint does not render the complaint non-maintainable.

16. We therefore hold that the present complaint is maintainable before this Commission and accordingly the first issue stands decided in favour of the complainants.

17. The second issue which arises for consideration is whether OP-1 to OP-3 had unauthorizedly liquidated the complainants‟ investments and induced them into purchasing the impugned insurance policies through misrepresentation and misselling of financial products? If so, what is the refund and compensation tenable?

18. It is not in dispute that Complainant No.1 was an elderly senior citizen and that OP-3 had functioned as the Relationship Manager of the complainants since December, 2011. It is also not disputed that the complainants reposed trust and confidence in OP-3 in relation to their banking and investment affairs. At the outset, it is necessary to note that the impugned insurance policies were admittedly issued in the name of Complainant No.2, who was approximately 53 years of age at the relevant time, while Complainant No.1 was nominee and holder of certain investments utilized towards payment of premiums. This factual position materially affects adjudication of the complainants‟ allegation that the policies were procured wholly without knowledge or consent. The complainants have alleged that OP3, acting as Relationship Manager, induced them to sign blank papers under the guise of KYC formalities and misrepresented that only a one-time investment of Rs.5,00,000 was required, whereas six insurance policies involving substantial recurring premium obligations were subsequently issued after unauthorized liquidation of mutual funds and equity investments.

19. On the other hand, the OPs contended that the complainants consciously and voluntarily shifted their investments after due consultation and applied for the policies after understanding their terms and conditions. The material placed on record reveals that Complainant No.2 admittedly underwent multiple medical examinations between 2013 and 2015 in connection with the impugned policies and signed the corresponding reports specifically recording that the examinations were being conducted for issuance of life insurance policies. Policy documents were admittedly dispatched to the policy holder/ complainant and welcome as well as validation calls were conducted by OP 2 informing the policy holder regarding the nature of the products and the 15 days free-look option available under the policies. The policy holder also admittedly continued with the policies over a considerable period of time, paid renewal premiums in relation to several policies and even purchased additional policies during subsequent years. In these circumstances, the allegation that the policies were issued entirely without the knowledge or consent of the policy holder cannot be accepted. Complainant No.2 was an educated adult person and active participant in the transactions and the continued retention of the policies, non-exercise of the statutory free-look option and payment of premiums over several years constitute significant circumstances demonstrating awareness regarding the nature of the products purchased. The evidence on record falls critically short of establishing the allegations of any misleading, fabrication or absence of consent in relation to the issuance of the policies. Evidently the OPs complied with procedural formalities such as medical examinations, validation calls and dispatch of policy documents. Therefore, there is no case of unauthorized issuance of policies that can be made out against the OPs The record further reveals that while the complainants invested Rs.40,50,000 towards premiums under the impugned policies, they subsequently received Rs.47,15,738 towards surrender/discontinuance value between 2018 and 2020. Thus, even after discontinuing from the insurance/ investment scheme, they recovered higher amount than the total premiums invested by them, besides enjoying substantial insurance coverage during subsistence of these policies.

20. Consequently, the claim of the complainants‟ seeking payment of Rs.2,36,95,578.81, is substantially founded upon speculations and based upon hypothetical future appreciation allegedly lost from mutual funds and equity investments and entirely untenable.

21. In view of the foregoing and after due consideration of the entire facts and circumstances of the case, including the detailed arguments advanced by the learned counsels for both the parties, we find no merit in the present complaint. The Consumer complaint No. 683 of 2018 is, therefore, dismissed for being devoid of merit.

22. There shall be no order as to costs and all pending Applications, if any, are also disposed of accordingly.