Consumer Complaint Drafting

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION AT [CITY], [STATE] CONSUMER COMPLAINT NO. ______ OF 2025 [NAME OF COMPLAINANT] S/o [Father's Name], R/o [Address] Mobile: [Number] | Email: [Email] ... COMPLAINANT VERSUS 1. [BANK NAME] Through Branch Manager, [Branch Address] 2. [BANK NAME] Through Nodal Officer, [Head Office] ... OPPOSITE PARTIES COMPLAINT UNDER SECTION 35 OF CPA, 2019 1. INTRODUCTION The Complainant is a "Consumer" under Section 2(7) of CPA 2019, maintaining Savings Account No. [XXX] with the Bank. 2. FACTS 2.1 Complainant is customer since [DATE] with Internet Banking. 2.2 On [DATE] at [TIME], unauthorized transactions: (a) ₹[Amount] to A/c [XXX] - [Time] (b) ₹[Amount] to A/c [XXX] - [Time] Total: ₹[AMOUNT] 2.3 Complainant did NOT share OTP/PIN/password. 2.4 Immediately reported: - Customer care at [TIME] - Branch complaint on [DATE] - FIR No. [XXX] at [PS] - cybercrime.gov.in Ack. No. [XXX] 2.5 Bank failed to block transactions, initiate chargeback, freeze recipient accounts. 3. DEFICIENCY IN SERVICE 3.1 Bank liable under Section 2(11) CPA 2019 for: - Failed security measures - No alert for new beneficiary - No prompt action on complaint 3.2 Per RBI Circular 06.07.2017, Complainant's liability is ZERO. 4. LOSS: Principal ₹[Amount] + Mental agony + Time lost 5. CAUSE OF ACTION: Arose on [DATE], continues till date. 6. JURISDICTION: Value under ₹50L; Branch in this district. 7. LIMITATION: Within 2 years of cause of action. 8. PRAYER: (a) Refund of ₹[Amount] (b) Interest @ 12% p.a. from [Date] (c) ₹[Amount] for mental agony (d) ₹[Amount] litigation costs (e) Any other relief deemed fit. 9. DOCUMENTS: [List attached] VERIFICATION I verify contents are true to my knowledge. Verified at [Place] on [Date]. [SIGNATURE] COMPLAINANT