NAME, AGE, ADDRESS………complainant                                                           

  Mobile no.                                               Aadhar no. ———————


COMPANY NAME AND COMPLETE ADRESS                                        …………….. Respondent

                                                                                                                     Complaint u/s 12 of consumer protection act, 1986


The complainant humbly submits as under: –
1. That the complainant is the resident of above said address and is a peace loving & law-abiding citizen. Whereas the respondent is an online shopping company which is use to sell as well as the business of electronic products, shoes, clothes, accessories, life style products etc. The respondent company has its registered office at the above given address. The respondent is doing its business in all over the India from above address.

2. That the complainant is the regular customer & consumer of the respondent. The complainant use to purchase goods online from the respondent from time to time for her personal use. The complainant purchased online goods from the respondent. The details of goods are as:    From the respondent at YOUR CITY. The respondent also gave money back guarantee and also has the return policy of the goods, if the item/goods are not as according to the will & wish, desires of the complainant. By way of purchase the above said goods with consideration, the complainant becomes a consumer.  

3). That after the online purchase of above said goods, the complainant gets the delivery of some products mentioned ORDER no. AND WORTH RS ——————. The complainant faced some issues with the above said goods. The above said goods did not satisfy the will & wish, desires of the complainant. Due to the reasons, the complainant sent a request to the respondent for refund of the money of goods mentioned ORDER NUMBER as the respondent gave money back guarantee with the above said goods. At the same time the complainant also made several requests to the respondent for delivery of goods mentioned at serial no. ——————————-.

4). But when the respondent did not pick up the goods as well as not deliver the products, then complainant again requested the respondent to pick the goods and refund the amount as well as deliver the products. Now the complainant came to know that the respondent is doing unfair trade practice with the complainant and the respondent will not pick up the goods and did not refund the amount.
5). That the respondent made several excuses for pick up the goods in the shape of that you have not bar code, product sticker, and tag of products and poly bag of product in which the product is wrapped. The respondent makes above excuses because they do not want to pick up and refund.

Although the complainant always gives all stickers, barcode, tag of product and wrapping of product and other relevant documents. When the complainant did not get any way to get her refund from the respondent, then the complainant make complain in consumer app portal against the respondent but all gone in vain.

7. That the complainant suffered a lot. Many illiterate people have no idea how to complain and how to take back money loss from the digital platform. The complainant cannot go outside the home to buy goods for herself, so the complainant prefers to buy goods online just to save time, money & family regulation. The complainant think digital shops are good so the complainant prefers online but due to harass policy and careless behavior, negligent services, torture behavior, the complainant totally lost her faith upon the digital world. The respondent gives grievances to the complainant every time whenever complaint purchased the goods. The complainant is deprived from family support and suffered a lot of mental agony. The e-shopping company i.e respondent forgets their responsibility, consumer respect.

8). That the respondent has been adopted unfair trade practice as well as the services given by them is suffered from deficiency. The respondent is duty bound to pick up and refund the amount of above said goods instantly to the complainant when she made a request in this regard. The respondent is also duty bound to deliver the products/goods to the complainant when she made an order in this regard. But the respondent intentionally, deliberately does not pick up the goods & refund the amount as well as not deliver the goods. The Company/respondent’s policy is too harassed for the customer/consumer for making them fool and to waste the time and to loot the hard core income of the consumers. The respondent said their company is best and not send any damage product to customer/consumer and its services are best. The respondent is not as the respondent described itself.

9). That the complainant is a student/JOB PERSON. The complainant purchased the above said goods with full of desires and aspects. The complainant spends her savings for purchase the above said goods. Due to the act & conduct & services of the respondent, the complainant suffers mental pain, agony. The complainant also wasted her precious time and money due to the deficient and negligent services of the respondent.

10). That the complainant is resident of house no. YOUR ADRESS AND CITY. The above said goods were purchase online by complainant at panipat. The above said goods were delivered at panipat. The payments for above said goods were made from panipat. The complainant made several requests to the respondent for refund of amount of above said goods from the panipat. Hence the cause of action arises at CITY WHERE YOU BUY . The cause of action against the respondent aroused on various dates and finally it was accrued on——————————- when the respondent rejected the refund request of the complainant. Hence the hon’ble forum has every jurisdiction to entertain, try and decide the present complaint.

11). That the complaint is well within time and is not barred by any law for the time being in force.

12). That no court fee is required for the present complaint.


  1.  It is therefore prayed to the hon’ble forum that the present complaint may kindly be admitted, the respondent be summoned, and the respondent be directed to refund the amount of goods mentioned at serial no. / product number                  along with Rs. 1,00,000/-(one lakh) as compensation for harassment, mental pain, for their negligent & deficient services.
  2.  Any other relief which this hon’ble forum thinks fit and proper in the above said circumstances.
  verification: – verified that contents of the above paras are true and correct to the best of my knowledge and belief and nothing has been concealed therein. Verified at Panipat on     …petitioner      You Address And City And Name

                                                  Through counsel                                                 


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