PRASHANT SHUKLA

Advocate
Supreme Court of India
Office:: CHAMBER: 17, M.C. SETALVAD BLOCK
C-253, DEFENCE COLONY, SUPREME COURT OF INDIA, NEW DELHI
NEW DELHI MOB: 9582835737

E-MAIL- prashantshuklaadv7@gmail.com

Dated: 08.04.2019

LEGAL COMPLAINT

To,
ECONOMIC & COMMERCIAL COUNSELLOR'S OFFICE
Gate No. 8, Chinese Embassy, 50-D, Shantipath, Chanakyapuri,
New Delhi-110021
Tel: 91-11-24672687(Trade disputes and contracted projects)
Fax: 91-11-26111101
Website: http://in.mofcom.gov.cn
E-mail: in@mofcom.gov.cn

Subject : Complaint regarding non compliance of delivery of goods (

700 units of Poly Solar Panel- 150w, 1480*670*35mm ) purchased by Mr.
Vishal Arora bearing Invoice No. JG20180604P19 dated 2018.06.04.

Sir,
Under instruction and on behalf of my client Mr. Vishal Arora,
Resident House No. , I do hereby serve you with the following notice:-

My client, Mr. Vishal Arora had placed an order with Ningbo

Polycrown Solar Energy Technology Co. situated at No. 363, Xiani Bridge,
 PRASHANT SHUKLA
Advocate
Supreme Court of India
Office:: CHAMBER: 17, M.C. SETALVAD BLOCK
C-253, DEFENCE COLONY, SUPREME COURT OF INDIA, NEW DELHI
NEW DELHI MOB: 9582835737

E-MAIL- prashantshuklaadv7@gmail.com

Xiaojia River Road, Beilun District, Ningbo, China for import and delivery of
700 units of Poly Solar Panels. The description of the products was 150w,
1480*670*35mm. An invoice dated 2018.06.04 was also generated
bearing invoice number JG20180604P19. The total amount of the
purchase was calculated to be USD 30,800. According to the terms of
payment agreed between the parties and mentioned in the proforma
Invoice as well 30 percent of the purchase amount (USD 9240) agreed
was to be paid in advance of the purchase and the rest 70 percent (2156
USD) was to be paid against the copy of Bill of Lading (BL).

Now on 14.06.2018 my client, Mr. Vishal Arora transferred Rs.

6,27,211 as an advance of 30% i.e. (USD 9240) as was agreed between
him and Ningbo Polycrown Solar Energy Technology Co. vide invoice
number JG20180604P19 dated 04.06.2018. As per invoice agreement the
abovesaid company was required to ensure its part of compliance by
providing Bill of Lading (BL) within 20 days. My client tried to contact the
company and apprised it several times to provide BL but to no avail. My
client has since long been in anticipation of the Bill of Lading and it has
caused him great financial hardships. It is noteworthy here that without the
Bill of Lading, my client was not required to pay the remaining balance
amount i.e., the rest 70 percent.

Ningbo Polycrown Solar Energy Technology Co. did not provide my

client the Bill of Lading on time regarding the consignment of the goods he
 PRASHANT SHUKLA
Advocate
Supreme Court of India
Office:: CHAMBER: 17, M.C. SETALVAD BLOCK
C-253, DEFENCE COLONY, SUPREME COURT OF INDIA, NEW DELHI
NEW DELHI MOB: 9582835737

E-MAIL- prashantshuklaadv7@gmail.com

ordered for. The business of my client suffered badly and as result of the
same he suffered mentally. Such non compliance on your part was a clear
violation of the terms of agreement entered into between my client and
you. It is relevant to mention here that as of now the goods agreed upon vide
invoice number JG20180604P19 dated 04.06.2018 cannot be imported
due to Indian government’s latest policy changes which occurred in
December 2018 and therefore my client wants his entire amount refunded
with interest due to non compliance on the company’s part.

I, therefore, request you through this complaint to immediately take

action regarding this and ask Ningbo Polycrown Solar Energy Technology
Co. (the company) to return/release the entire 30 % amount in the tune of
Rs Rs. 6,27,211 along with 18% interest per annum, within a period of 15
days, failing which my client has given clear instructions to me to file
criminal as well as civil suit in the competent court of law.

A copy of this notice is kept in my office for record and further necessary
action in a competent court.

Yours Sincerely,
(PRASHANT SHUKLA)
Advocate
SUPREME COURT OF INDIA
 PRASHANT SHUKLA
Advocate
Supreme Court of India
Office:: CHAMBER: 17, M.C. SETALVAD BLOCK
C-253, DEFENCE COLONY, SUPREME COURT OF INDIA, NEW DELHI
NEW DELHI MOB: 9582835737

E-MAIL- prashantshuklaadv7@gmail.com