Thursday, March 23, 2023

Brief notes of argument in Revision Petition / Consumer Case / M/s. Madhabi Service Station / Indian Oil Corporation / State Consumer Disputes Redressal Commission West Bengal

 

Before the Hon’ble State Consumer Disputes Redressal Commission, West Bengal

11A, Mirza Ghalib Street, Kolkata – 700087

Under the Consumer Protection Act 2019

 

Revision Petition No. 3 of 2021

(against the order dated 24th December’ 2020, in Complaint Number CC/48/2018, of the District Commission, South 24 Parganas)

 

In the matter of ;

Sr Abhijit Ghosh,

                   ________Revisionist

-      Versus –

M/s. Madhabi Service Station, and Others,

                   ________Respondents

 

Brief Notes of Argument on behalf of the Respondent nos. 4 & 4(a) being M/s. Indian Oil Corporation Limited;

 

The present Revisional application by the Revisionist who is Complainant in Consumer Complaint before the Learned District Commission, is misconceived which resulting in abuse of due process of law;

 

This Respondent appeared in the Consumer complaint upon receipt of the notices served by the Learned District Commission and submitted the Written Version, therein;

 

The notice on the respondents has given by the Learned District Commission, in pursuance of compliance of Order dated 22/10/2019, passed in First Appeal No. A/10/2019, by the Hon’ble State Commission, wherein it has been contended as “it was imperative to add this bank as a party to the case. Similarly, the versions of UBI, SBI, and Indian Oil in this matter too were of great significance.”

 

The present revision has been preferred by the Complainant challenging the Order no. 14, dated 24/12/2020, passed by the Learned District Commission, South 24 Parganas, in which the Learned District Commission was pleased to allow the amendment of certain relevant facts in written version of the respondent no.1, herein on payment of cost.

 

The amendment in written version of the respondent no.1, has allowed justifiable in the interest of administration of justice on payment of cost, so far. The pleading can be amend at any stage of the proceeding for the fair adjudication on necessary facts, so far.

 

In J. Samuel and Ors. V. Gattu Mahesh and Ors. 2012 AIR SCW 1035, Hon'ble Supreme Court has observed thus :-

"The primary aim of the court is to try the case on its merits and ensure that the rule of justice prevails. For this the need is for the true facts of the case to be placed before the court so that the court has access to all the relevant information in coming to its decision. Therefore, at times it is required to permit parties to amend their plaints. The Court's discretion to grant permission for a party to amend his pleading lies on two conditions, firstly, no injustice must be done to the other side and secondly, the amendment must be necessary for the purpose of determining the real question in controversy between the parties. However, to balance the interests of the parties in pursuit of doing justice, the proviso has been added which clearly states that application for amendment shall be allowed after the trial has commenced, unless the court comes to the conclusion that in spite of due diligence, the party could not have raised the matter before the commencement of trial."

 

The Court may at any stage of the proceedings allow both party to alter or amend his pleadings in such manner and on such terms as may be just and all such amendments shall be made as may be necessary for the purpose of determining the real question in controversy between the parties. Provided that no application for amendment shall be allowed after the trial has commenced, unless the Court comes to the conclusion that in spite of due diligence, the party could not have raised the matter before the commencement of trial.

 

In Vidyabai and others vs. Padmalatha and another – AIR 2009 SC 1433, Hon’ble Supreme Court has discussed the legisltative intent behind bringing the proviso to Rule 17 of Order 6 of CPC. At para 7 of the said judgment it was opined that the provisions of Order 6 Rule 17 of the CPC are in mandatory form. The court’s jurisdiction to allow an application under Order 6 Rule 17 of CPC is taken away unless the conditions precedent therefor are satisfied i.e., the court must come to a conculsuion that inspite of due diligence the parties could not have raised the matter before the commencement of trial. Thus, the proviso indicates that once the trial commences, no amendment.

 

Hon'ble Supreme Court in the case of Usha Balashaheb Swami and Ors. v. Kiran Appaso Swami and Ors.( AIR 2006 SC 1663) has held that : A prayer for amendment of the plaint and a prayer for amendment of the written statement stand on different footings. The general principle that amendment of pleadings cannot be allowed so as to alter materially or substitute cause of action or the nature of claim applies to amendments to plaint. It has no counterpart in the principles relating to amendment of the written statement. Therefore, addition of a new ground of defence or substituting or altering a defence or taking inconsistent pleas in the written statement would not be objectionable while adding, altering or substituting a new cause of action in the plaint may be objectionable. In the case of amendment of a written statement, the Courts are more liberal in allowing an amendment than that of a plaint as the question of prejudice would be far less in the former than in the latter case.

 

 

 

Photostat copy of the said Judgment of the Hon’ble Apex Court is enclosing herewith and marked as Annexure – “A”.

 

 

The present revision is questioning on allowing the amendment of written version of the respondent no.1, while the trial has not yet been commenced, is not sustainable to intervene into in the light of the decisions of the Hopn’ble Apex Court, as discussed above.

 

Therefore the present revision application should be dismissed with appropriate cost on the revisionist, who cause unnecessary delay in deciding the consumer matter before the Learned District Commission.

 

 

 

Through ___________

 

 

 

Advocate

For the Respondent no. 4 & 4(a);

M/s. Indian Oil Corporation Limited

Date : 1st day of August’ 2022;

Place : Kolkata

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