BEFORE THE PERMANENT LOK ADALAT FOR PUBLIC

UTILITY SERVICES, SONEPAT

Babli V/s The Manager, LIC

of
India & ors.

-Complainant --Respondent

In the matter of:-

Application U/s 22(c) of the Legal

Services Authority Act, 1987

WRITTEN STATEMENT ON BEHALF OF

RESPONDENTS NO. 1 TO 3

R/Sir,

The respondents no.1 to 3 most humbly and

respectfully submit as under:-

Preliminary Objections:-

1. That the present application of the

applicant/petitioner is not legally

maintainable in view of the fact that the

applicant/petitioner has not submitted the

claim intimation/forms and the required

documents with the respondents till date and

thus the application of the applicant/

petitioner deserves dismissal out-rightly on

this score only.

2. That the complainant has neither any cause

of action nor locus standi to file the

present application before the Hon'ble

Adalat.

3. That the applicant/petitioner has concealed

the material facts from the Hon'ble Adalat

and has not come to the Hon'ble Adalat with

clean hands, hence, the application of the

applicant/petitioner is liable to be

dismissed on this score alone.

On Merits:-

1. That the contents of para no.1 of the

application as stated are not disputed being

matter of record.

2. That the contents of para no.2 of the

application as stated are a matter of

record.

3. That the contents of para no.3 of the

application as stated are not disputed being

matter of record that a policy no.504684332

on the life of Sh. Ram Roop issued by the

answering respondents with the date of

commencement dt.28.04.2016 in the sum

 assured Rs.1,00,000/- mode of premium half

yearly under plan/term 814/21/21.

4. That the contents of para no.4 of the

application as stated are wrong and hence

denied. It is wrong and denied that at the

proposal stage, the husband of the applicant

completed all the medical examinations as

alleged. It is also vehemently denied that

at the stage of the proposal form the

husband of the applicant disclosed all the

material facts to the answering respondents

about his previous three policies as

mentioned in para under reply. In fact, the

life assured had not mentioned about any

previous policy in the proposal form against

policy no.504684332 as per the record of the

corporation. The copy of the proposal form

is annexed herewith for the kind perusal of

this Hon'ble Adalat. Rest of the contents of

this para are wrong and hence denied.

5. That the contents of para no.5 of the

application as stated are admitted to be

correct being matter of record.

6. That the contents of para no.6 of the

application as stated are wrong and hence

denied. It is wrong and denied that after

the death of the husband of the applicant,

the applicant informed the official of the

answering respondents and submitted all the

relevant documents for death claim of her

husband of all policies as alleged. The fact

of the matter is that the answering

respondents have not received any death

claim intimation and the required documents

from the applicant/petitioner for the

settlement of the claim against policy

no.504684332 till date. Thus, the

application filed by the

applicant/petitioner is pre mature and is

not maintainable against the answering

respondents for want of death claim

intimation and other required documents

against of the policy no.504684332. Rest of

the contents of this para as stated are also

wrong and hence denied.

7. That the contents of para no.7 of the

application as stated wrong and hence

denied. A false story has been concocted by

the applicant in this para. It is wrong and

denied that the applicant visited the office

of the answering respondents many times

regarding the death claim under the police

in question. Rest of the contents of the

para as stated are wrong and hence denied.

8. That the contents of para no.8 of the

application as stated are wrong and hence

denied. It is wrong and denied that the

applicant/petitioner fulfilled all the terms

and conditions of the respondents as

alleged. It is also wrong and denied that

the answering respondents knowingly,

intentionally and deliberately have not

released the death claim of the applicant

under the police in question as alleged. The

applicant has not submitted the required

documents regarding the death claim under

the policy in question till the date, hence

there is no deficiency and negligent in the

 services on the part of the answering

respondents.

9. That the contents of para no.9 of the

application as stated are wrong and hence

denied. The applicant concocted a false

story in this para. The detailed reply has

already been given in the foregoing para of

this reply.

10. That the contents of para no.10 of the

application as stated are wrong and hence

denied. It is wrong and denied that the

answering respondents have committed the

offence of criminal breach of trust of the

applicant as alleged. In this regard it is

submitted that the applicant has levelled

false allegations against the answering

respondents only with the intention to

tarnish the reputation of the officers of

the corporation. When the

applicant/petitioner has not submitted the

claim intimation/forms and the required

documents with the respondents regarding the

policy in question till date and thus, the

 applicant has no cause of action to file the

present application against the answering

respondents and hence the application under

reply is liable to be dismissed as pre-

mature.

11. That the contents of para no.11 of the

application as stated are wrong and hence

denied. The answering respondents have not

caused any tension, harassment and mental

agony, pain and financial loss to the

applicant as alleged. There is also no

deficiency in service on the part of the

answering respondents.

12. That the contents of para no.12 of the

application as stated are denied for want of

knowledge.

13. That the contents of para no.13 of the

application as stated are wrong and hence

denied. The Hon'ble Adalat has no pecuniary

and territorial jurisdiction to effect

conciliation between the parties and in the

event of their failure to settle the dispute

 amicably, to make an award on merits as the

matter in dispute is pre mature.

That the contents of prayer clause along

with sub para no.(a) to (d) of the

application as stated are wrong and hence

denied. The applicant/petitioner is not

entitled any of the relief claimed in view

of the facts and circumstances mentioned in

the written statement. Hence, it is, prayed

that the application of the

applicant/petitioner, which is based on

wrong, false and frivolous grounds may

kindly be dismissed with costs to meet the

ends of justice.

Verification Respondents no.1 to 3

Verified that the Life Insurance

contents of the corporation of India,
above written through its competent
statement are true authority
and correct to the
best of our
knowledge and
belief and based on
officials record. Through:- R.P. Antil
Verified at Sonepat Advocate,
On Sonepat