ગ્રાહક અપીલ મેમોરેન્ડમ

BEFORE THE [appellate_commission] APPEAL NO. ________ OF 20____ (Against the order dated [impugned_order_date] passed by the [lower_commission] in Complaint No. [original_complaint_number]) IN THE MATTER OF: [appellant_name] [appellant_address] ... APPELLANT VERSUS [respondent_name] ... RESPONDENT MEMORANDUM OF APPEAL UNDER THE CONSUMER PROTECTION ACT, 2019 MOST RESPECTFULLY SHOWETH: 1. That the Appellant is aggrieved by the order dated [impugned_order_date] passed by the [lower_commission] in Complaint No. [original_complaint_number], and prefers the present appeal against it. A certified copy of the impugned order is filed herewith. 2. AMOUNT INVOLVED Amount involved in the present appeal: Rs. [amount_involved] 3. That the Appellant submits that the present appeal is within the period of limitation prescribed by section 41 or section 51 of the Consumer Protection Act, 2019, as the case may be. If the Hon'ble Commission finds that there is any delay, the Appellant prays that it be condoned for the reasons set out in the application for condonation of delay filed with this appeal. 4. PRE-DEPOSIT (where the Appellant has been directed to pay an amount) Amount deposited, being fifty per cent of the amount ordered: Rs. ______________ Date and mode of deposit: ______________ Proof of the deposit is filed herewith. GROUNDS OF APPEAL [grounds_of_appeal] FURTHER GROUNDS A. That the impugned order is contrary to law, to the facts on record, and to the material produced before the learned Commission below. B. That the learned Commission below failed to appreciate the evidence and documents on record in their true perspective. C. That the learned Commission below has not recorded adequate reasons in support of its conclusions. D. That the findings recorded in the impugned order are perverse and unsustainable. E. That the relief granted or refused is disproportionate to the facts established. F. That the Appellant craves leave to urge such further grounds at the hearing as may be advised. PRAYER It is therefore most respectfully prayed that this Hon'ble Commission may be pleased to: (a) Allow the present appeal and set aside the order dated [impugned_order_date] passed by the [lower_commission]; (b) Grant the relief that ought to have been granted to the Appellant; (c) Award the costs of this appeal; and (d) Pass such other orders as this Hon'ble Commission may deem just and proper. AND FOR THIS ACT OF KINDNESS, THE APPELLANT SHALL EVER PRAY. Place: ______________ Date: [filing_date] [appellant_name] APPELLANT VERIFICATION I, [appellant_name], the Appellant above named, verify that the contents of paragraphs 1 to 4 above are true to my personal knowledge, that the grounds of appeal are submissions made on the basis of the record and advice received and believed by me to be correct, and that nothing material has been concealed. Verified at ______________ on [filing_date]. [appellant_name] APPELLANT ENCLOSURES 1. Certified copy of the order dated [impugned_order_date] 2. Copy of the complaint, reply and evidence filed before the Commission below 3. Proof of the pre-deposit, where required 4. Application for condonation of delay, if any