Complaint No. ______________________/2015



Mr. Muhammad Latif Qureshi son of Muhammad Anwar Qureshi Resident House No. 4 Street No. 2 Bilal Street Samanabad, Lahore








1.      UNITED MOBILES, Shop No. 234, 2nd Floor, Mera, Lahorej Plaza, Main Hall Road, Lahore, Through Its Manager.


2.      A.A. Mobiles, Shop No. 1, Usama Centre, 1st Floor, Hall Road Lahore.







Respectfully Sheweth:



1.      That the addresses of the parties have been given correctly for the services of summons and notices etc.

2.      That the brief facts leading to rise the present suit are that complainant purchased a Mobile” Bearing Model No. K&C V-40 IMEI: 357367034407306 with warrantee of one year from 05.04.2014 to 04.04.2015 in consideration of Rs. 13000/- on cash basis, vide invoice No. 3467 dated 25.02.2014. Copies of invoice and warrantee card attached herewith.

3.      That under the warrantee you are bound to repair the mobile or in case of un-repairable fault you are liable to replace the mobile set.

4.      That after three months of purchasing the said item is not working properly and the said item remained hang and showed the slow speed as well as during call it becomes off.

5.      That immediately complainant visited to respondent No. 2 for the replacement of the cell or removing the above said fault, but respondent No. 2 stated that the said fault be removed or replaced from the respondent No. 1.

6.      That thereafter complainant visited the concerned company on 03.01.2015 and informed about the fault, the staff of respondent No. 1 firstly asked complainant we will replace your set after 15 days.

7.      That on the fixed date, complainant again visited respondents No. 1 as well as respondent No. 2 the fault will be repaired otherwise the company will be bound to exchange with new mobile set.

8.      That thereafter on 11.03.2015, complainant visited the respondent No. 1 he also refused to repair or change the said mobile and did not pay any heed for replacement of the defects in manufacturing mobile set of complainant.

9.      That due to the manufacturing of the respondents the mobile set of complainant found defective and according to warrantee card the respondents are responsible for the replacement of the same but the respondents have declined to replace the defects found it in the mobile set of complainant.

10.    That complainant requested the respondents to replace the same in the light of para 3 but the respondents declining to accede the genuine request/ demand of the complainant for which the respondents are liable to be prosecuted before the Consumer Courts at Lahore.

11.    That apart from the refusal of the respondents have disreputed, degraded and ridiculed complainant which created mental torture, shock agony and financial loss and also misbehaved within the presence of staff and other consumers present at the same time for which complainant also reserves his right to claim damages from the respondents to the tune of Rs. 500000/- for each of the above act.

12.    That the complainant served the legal notices to the respondents but uptill now the respondents did not response the same.

13.    That the cause of action accrued in favour of the complainant and the respondents due to the above said facts and circumstances and finally when the respondents refused to accede the genuine request of the complainant, which is still continuing.

14.    That the parties to the petition are residing at Lahore, the cause of action also accrued at Lahore, therefore, this Honourable Court has got the jurisdiction to try and adjudicate upon the matter.

15.    That the requisite court fee has been affixed on the petition.


Under the above said mentioned circumstances, it is, therefore, most respectfully prayed that the complaint in hand may very kindly be accepted by passing an appropriate order may very kindly be passed in favour of the complainant and against the respondents directing him to replace the mobile set.


    Any other relief, which this Honourable Court deems fit and proper in the circumstances of the case may also be awarded.







Mudaber Hussain Qureshi

Advocate High Court

127-Disctrict Courts, Lahore.



Custody :


For More Legal Sample Drafts Please Visit Us and Share Website URL With Other Friends.