BEFORE THE 4th ADDITIONAL DISTRICT CONSUMER DISPUTES

REDESSAL FORUM BANGALORE URBAN DISTRICT

Complaint No.2875/2013

COMPLAINANT: SREEJA PILLAI .

Vs.
OPPOSITE PARTIES: 1)

BAJAJ ALLIANZ GENERAL INSURANCE CO.LTD.

GRD FLR, NO.31, TBR TOWER, 1ST CROSS,
NEW MISSION RD NEAR BANGALORE STOCK EXCHANGE
BANGALORE - 560027
PHONE: (080) 22075301

2) THE MANAGING DIRECTOR

M/S. RAMANI CARS PVT.LTD.
COIMBATORE.

AFFIDAVIT

I SREEJA

PILLAI,

aged about _____ years, r/o

NO

257, SUPRABHATHA, ST

BED

LAYOUT, 4TH MAIN, 4TH BLOCK KORMANGALA, NEAR MANTRI CLASSIC APARTMENTS
BANGALORE 560034 KARNATAKA, do hereby state on oath as follows;

I submit that I am the complainant in the above case and fully aware of the case. I
had purchased Volkswagen polo 1.2tdi from the authorised showroom in
Bangalore on (19th Jan 2012) here after referred as opposite party number 2.
The vehicle was insured with Bajaj Allianz general insurance company .Ltd
here after referred as opposite party number 1.

I further submit that the vehicle came along with two year manufacturers
warranty and the insurance policy purchased was a first party comprehensive
insurance i.e., it covers both the vehicle and the persons in case of any

accident as stipulated by the terms and conditions of the insurance policy.

I further submit that I was heading towards Palakkad, Kerala on 29 th November
2013 from Bangalore via NH47, at Thekkalur, Coimbatore, Tamil Nadu along
with my family in the Volkswagen polo 1.2tdi Registration number
KA01 MH 5660, the vehicle hit an unmarked hump at around 4.45 am on 30 th
November/2013 accidently, I immediately parked the vehicle safely within 50
meters after the hump in order to check if the car had suffered any damage
and I noticed that the engine oil was leaking and did not try to start the engine
after I noticed the oil leak.

4.

I further submit that I had called the Volkswagen 24hrs road side assistance toll
free number 1801-00004183 for assistance (Request number RSB16548) and
the vehicle was towed to the nearby Volkswagen authorized service centre of
opposite party no 2.

5.

I further submit Opposite party number 2 has tried to manipulate the real facts
and caused the damage to the vehicle due to their negligence and also a

greater cost of RS 1, 15,600/- .

6. I further submit that opposite party number 1 denied approving the amount that
was quoted by the Volkswagen service station at Coimbatore contending it to
be a consequential damage but the damage was caused by an accident and
is within the terms of the insurance contract.

7. I further submit that I had sent an email informing the opposite party No 1
regarding the claim (l.muthupandi@bajajallianz.co.in ) regarding the same on
11th Dec 2013, and also contacted the opposite party number 1 customer

helpline number 1801-00004183 bearing request number 46727687. No

response was given to my grievances and I also contacted opposite party
number 2 via emails regarding the matter.
8. I further submit that I have followed all the terms and conditions mentioned in
the contract of insurance and accordingly insurance policy terms and
conditions it clearly lays down the liability of the insurance company according
to which the above incident is well within the purview of the policy and I am
eligible for the clam amount more than what was approved by opposite party
No 1.
9. I further submit that this case falls within the jurisdiction of this Honble Forum as the
compensation claimed does not exceed Rs.20,00,000 /- ; and this Honble Forum has
got the jurisdiction to adjudicate and decide the same as the opposite parties have their
head office in Bangalore.
10. I further submit that I have not filed any such or similar complaint before this Honble
Court. No such or similar complaint is pending adjudication before any competent
court of law. Hence I pray that this Honble Forum be pleased to direct the opposite
parties to compensate for the financial loss, cost towards this petition and mental
agony undergone by me as a result of the deficiency in service by the opposite parties.
11. I am herewith producing the following in support of my case for the kind perusal of
a
b
c
d
e

this Honble Forum:

Insurance policy ,
2 e-mails dated ____
Photos
Emails
Etc ?

VERIFICATION
I SREEJA

PILLAI

submit that this is my name and signature and the contents of this

affidavit in support of the plaint are true and correct to the best of my knowledge. No part of
it is false and nothing has been concealed there from.

Bangalore
Date:

Deponent
(SREEJA PILLAI)