Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com
BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION, [DISTRICT]
Consumer Complaint No. ____ of 20__
MEMO OF PARTIES
COMPLAINT UNDER SECTION 35 OF THE CONSUMER PROTECTION ACT, 2019
Respectfully showeth:
- That the complainant [purchased goods / availed services] being [DESCRIPTION] from the opposite party on [DATE] for a consideration of ₹[AMOUNT] vide [INVOICE / RECEIPT No. __] (Annexure C-1), for personal use and not for any commercial purpose. The complainant is a consumer under Section 2(7) of the Act.
- That [DESCRIBE THE DEFECT / DEFICIENCY IN SERVICE / UNFAIR TRADE PRACTICE, with dates].
- That the complainant reported the issue on [DATES] vide [COMPLAINT / TICKET Nos. __] (Annexure C-2), but the opposite party failed to resolve it. A legal notice dated [DATE] (Annexure C-3) also went unanswered [or: was replied evasively].
- That the acts of the opposite party amount to [a defect under Section 2(10) / deficiency in service under Section 2(11) / an unfair trade practice under Section 2(47)] of the Act, causing the complainant financial loss, mental agony and harassment.
- That this Commission has pecuniary jurisdiction under Section 34(1), as the value of the goods or services paid as consideration is ₹[AMOUNT], and territorial jurisdiction under Section 34(2), as [the complainant resides or personally works for gain / the opposite party carries on business / the cause of action arose] at [PLACE].
- That the complaint is filed within two years from the date on which the cause of action arose, i.e. [DATE], as required by Section 69 of the Act.
- That the consideration paid is ₹[ ], on [dates], for [goods / services]. Consumer status under Section 2(7) is established by [purpose and use]; any commercial-purpose objection and livelihood/self-employment exception relied on are addressed by [specific facts].
- That the opposite party promised [contractual / statutory standard], but supplied or performed [actual defect / deficiency / unfair practice] on [dates]. Each allegation is linked to [invoice, warranty, communication, report or other evidence].
- That complaints and opportunities to rectify were given on [dates]; the responses were [ ]. Loss is calculated as refund ₹[ ], proved expenditure ₹[ ], other compensable injury ₹[ ] and litigation costs ₹[ ], without double counting.
- That pecuniary jurisdiction is determined by the value paid as consideration under the currently applicable jurisdiction rules, namely ₹[ ], rather than an inflated total compensation demand. Territorial jurisdiction under Section 34(2) rests on [specific clause and facts].
- That the cause of action accrued on [date and event]; the complaint is within Section 69’s two-year period on [calculation]. [If beyond time: state the full delay and file a separate sufficient-cause application.] A later representation alone is not treated as extending limitation.
- That expert evidence or testing, if required, concerns [issue and requested procedure]. Other proceedings and settlements are disclosed. The relief sought under Section 39 is [repair / replacement / refund / compensation / discontinuance of practice], justified by the proved deficiency.
PRAYER
It is, therefore, respectfully prayed that the opposite party(ies) may kindly be directed to: (a) [replace the product / remove the defect / refund ₹__] along with interest at [__]% per annum from [DATE]; (b) pay ₹[__] as compensation for mental agony and harassment; (c) pay ₹[__] as litigation costs; and (d) grant any other relief this Hon'ble Commission deems fit.
Date: [DATE]
Through
[NAME OF ADVOCATE] (or in person)
VERIFICATION
Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above complaint are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.
COMPLAINANT
Note: Complaints can also be filed online on the e-Daakhil portal. Attach the fee as prescribed for the claim value.
BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION, [DISTRICT]
Consumer Complaint No. ____ of 20__
Versus
AFFIDAVIT
Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].
I, the above-named deponent, do hereby solemnly affirm and declare as under:
- That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
- That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.
DEPONENT
VERIFICATION
Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.
DEPONENT
Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.
Preparation and judgment application — not part of the filing draft
Updated 11 October 2026. Complete every material fact, retain only supported alternatives, and renumber before filing. These notes support professional adaptation; they do not supply missing evidence or guarantee relief.
Filing and relief checks. Check the current forum thresholds, filing fee and statutory procedure on the actual filing date. Annex purchase/payment proof, complaint correspondence, loss schedule and any expert report. Use a fact-matched authority for the service involved rather than an unrelated general judgment.
Before relying on any authority, compare the material facts, procedural stage, statutory version and precise relief; check subsequent treatment and applicable local practice. Keep the authority note separate from the signed pleading. For criminal procedure, determine Section 531 BNSS savings rather than select the code solely from the alleged offence date.