IN THE COURT OF THE PRINCIPAL DISTRICT CONSUMER

REDRESSAL FORUM GURGAON DISTRICT AT GURGAON,

HARYANA

Complaint No.-C015/05/2018

BETWEEN

Mr. Acchayn,
Aged about 34 years,
S/o. Gangappa,
Residing at Block No. 41
Lovely Professional University,
Jalandhar-Delhi G.T. Road (NH-1)
Phagwara, Punjab , 144411 …. Complainant

AND

M/S Lufthansa Airlines Co. Ltd.

Tower-B, 12th Floor,
Phase-2, DLF Cyber City,
Gurgaon, Haryana
Pin Code- 122001 …. Opposite Party
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THE COMPLAINT UNDER SECTION 12 OF CONSUMER
PROTECTION ACT

The Complainant above named most respect fully submits herewith.

1. The address of the Complainant for the purpose of court summons,

notice, etc., are as shown in the cause title and that of his counsels SKS
Legal ,D-26 Jangpura Extension, New Delhi ,Pin Code-110022.

2. That the address of the Opposite party for similar purpose shown in
the cause title above.

BRIEF FACTS OF THE CASE

3. The Complainant most respect fully submits that, Complainant is the

customer of the Opposite party and he is the prospective purchaser of flight
tickets from the opposite party. The complainant booked flight tickets from
Amritsar to Australia on May 15, 2018 for himself and his family members
(in total 4 members).

4. The Complainant most respectfully submits that while the complainant

was booking the flight the following 3 broad categories of food as per the
Lufthansa Airlines Food Policy(marked as ANNEXURE A)were available
with the complainant -1.Dietary Meal 2.Vegetarian & whole meals,
3.Religion based meal, it is submitted that the complainant opted for the
category “Vegetarian and Whole Meals” for himself and his family.
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5.The complainant most respectfully submits that the tour was of 15 days till
30th may ,2018 and the quoted flight cost was Rs. 1,40,000 each person each
way , which implies the total cost of flight tickets payable to opposite party
was 11,20,000/- (Eleven lakhs twenty thousand only). The complainant
most humbly submits that the quoted amount was duly paid by the
complainant vide Oriental bank of commerce cheque (marked as
ANNEXURE B).

6. The complainant most respectfully submits that while the complainant

was travelling on 15th may,2018 along with his family they were provided
with the meals consisting chicken fritters.

7. The complainant most respectfully submits that after taking a bite the
complainant immediately realized that they have eaten something bad and
got disappointed. The complainant humbly submits that when objections
were raised by the complainant, the employee (air hostess) of the opposite
party replied that ‘this is the veg food available with them”.

8. The complainant most respectfully submits that complainant and his

family were not having any other thing to eat the whole journey. Hence, the
complainant along with his family has suffered famine for hours.

9. The complainant most respectfully submits that the complainant being a

devout Hindu, is traumatised by the incident and the mental agony suffered
by complainant and his family is beyond any explanation.
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10. The Complainant most respectfully further submits that, after returning
from the tour a Legal Notice of demand dated 06-09-2017 marked as
ANNEXURE - C which was sent through his advocate to the Opposite
parties to pay the compensation, even after the receipt of the notice marked
as ANNEXURE-D the Opposite party neither has agreed to pay any
compensation nor has sympathized for the mental agony of the
complainant’s family , for the reason better known to the Opposite party .
Hence, the suit filed before this Hon’ble Court to prosecute the Opposite
party in accordance with law.

11. The Complainant most respect fully further submits that, the premises
of the Opposite party is in Gurgaon city hence, this Hon’ble Forum has
jurisdiction to entertain the Complaint, the cause of action arose out bound
territory which though not inclusive but the head quarter of the Opposite
party is in Gurgaon thereby the jurisdiction would be in the Hon’ble Forum
of Gurgaon. The Complainant has not filed any suit or suits before any
forum the claim is for Two Lakhs Only and the adequate court fee Rs.200/-
is paid to this Hon’ble Forum.

Wherefore, the Complainant prays that this Hon’ble Forum may be pleased
to pass a judgment and decree in favour of the Complainant and against the
Opposite party.
(a) Directing the Opposite party to pay the compensatory amount of Rs.
2,00,000/- (Rs. Two Lakhs Only)
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b) The Hon’ble Court be pleased to issue process and secure the
presence of the Opposite party and to prosecute the Opposite party in
accordance with law.
c) Grant such other relief’s as this Hon’ble Court deems fit under the
circumstances of case, in the interest of justice and equity.

Advocate for Complainant Complainant

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VERIFICATION

I, the Complainant, in the above case, do hereby declare that this is

my name and signature, what is stated above are true and correct to the
best of my knowledge, information and belief.

Place: Gurgaon, Haryana

Date:13.09.2018 COMPLAINANT
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IN THE COURT OF THE PRINCIPAL DISTRICT CONSUMER
REDRESSAL FORUM GURGAON DISTRICT AT GURGAON,
HARYANA

Complaint No.:C015/05/2018

BETWEEN
Mr. Acchayn …... Complainant

AND

M/S Lufthansa Airlines Co. Ltd. ……. Opposite Party

VERIFYING AFFIDAVIT

I, Mr. Acchayn, Aged about 34 years, S/o. Gangappa, Residing at Block

No. 41,Lovely Professional University, Jalandhar-Delhi G.T. Road (NH-1)
Phagwara, Punjab , 144411, Do hereby solemnly affirm and state on oath as
follows:
1. I submit that I am the Complainant in the above said case and I am
well conversant with the facts and known the case. Hence I am
swearing to this affidavit.
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2. I submit that the averments made in the application from paragraphs 1
to 11 are true to the best of my knowledge, information and belief.

What is stated above is true and correct to the best of my knowledge,

information and belief and this is my name and signature.

Identified by me
Advocate. DEPONENT
SWORN TO BEFORE ME

Place: Gurgaon, Hrayana

Date: - 13.09.2018
No of corrections.
 -9-
IN THE COURT OF THE PRINCIPAL DISTRICT CONSUMER
REDRESSAL FORUM GURGAON DISTRICT AT GURGAON,
HARYANA

Complaint No.- C015/05/2018

BETWEEN
Mr. Acchayn …… Complainant
AND
M/S Lufthansa Airlines Co. Ltd. ……… Opposite party

LIST OF DOCUMENTS

PARTICULARS ANNEXURES
1) Lufthansa Airlines Food Policy A
2) Payment Cheque B
2) Legal Notice Dated 6.09.2018 C
4) By Hand Acknowledgment D

The undersigned counsel for the Complainant most respect fully

furnishing the Photo Copy the documents for kind perusal of this Hon’ble
Court, in the interest of justice and equity.

Place: Gurgaon, Haryana

Date:
ADVOCATE FOR COMPLAINANT