Other Item COMPLAINT UNDER SECTION 35 OF THE CONSUMER PROTECTION ACT, 2019

R

Raghav Krishna

New member
Dealer Name
Chandrakanth
Company Name
M.S. Golden Pets
Product Name
Pomeranian Puppy
Customer Care Number
99444 83298
Loss Amount
1004680
Ratings
1.00 star(s)
Opposite Party Address
Mettuthottam, Opp. Hindustan Petrol Bunk, Vannakovail, Periyanaikenpalayam, Coimbatore – 641 020.
The Complainant respectfully submits as under:

1. Particulars of Parties

  • The Complainant is a consumer residing within the district of Coimbatore who purchased a puppy from the Opposite Party for domestic companionship.
  • The Opposite Party is a commercial pet trader operating under the trade name "M.S. Golden Pets" in Periyanaikenpalayam, Coimbatore, engaged in the business of selling animals and pet merchandise to consumers for consideration.
2. Facts of the Case & Unfair Trade Practice

  • Fraudulent Inducement: On June 14, 2026, the Complainant visited the commercial establishment of the Opposite Party. The Opposite Party explicitly misrepresented a puppy as a fully weaned, healthy, vaccinated, and certified purebred dog fit for immediate domestic adoption.
  • Financial Consideration: Relying entirely on these solemn verbal representations and written medical documents provided by the Opposite Party, the Complainant paid a sum of ₹4,000/- (Rupees Four Thousand Only) to the Opposite Party.
  • Deficiency of Service & Latent Defects: Within hours of delivery, the puppy exhibited severe clinical distress, continuous vomiting, and acute lethargy. The Complainant immediately rushed the animal to an independent veterinary hospital. The registered veterinary practitioner certified that the puppy was critically ill, unweaned, prematurely separated from its mother, and suffered from a life-threatening, pre-existing disease.
  • Forgery of Medical Records: The independent veterinary examination conclusively proved that the vaccination records and health certifications provided by the Opposite Party were completely forged, fabricated, and backdated to mask a terminal illness, directly constituting an Unfair Trade Practice under Section 2(47) of the Consumer Protection Act, 2019.
3. Deficiency in Service and Product Liability

  • The Opposite Party knowingly sold a fatally compromised and unweaned animal, which amounts to selling a dangerous, defective product and a total failure of service.
  • Subsequent Misconduct: When the Complainant contacted the Opposite Party to present the independent vet reports and demand a medical refund/rectification, the Opposite Party completely refused, used abusive language, slandered the Complainant, and issued threats of physical violence.
4. Actual and Anticipated Financial Losses & Mental Agony

  • The Complainant has suffered immense mental trauma watching an innocent animal collapse from terminal illness due to the Opposite Party's fraud.
  • The Complainant has incurred an immediate initial amount of ₹680/- (Rupees Six Hundred and Eighty Only) in emergency veterinary ICU care trying to stabilize the unweaned pup.
  • Continuous Veterinary Liability: Because the puppy was sold unweaned, structurally compromised, and without authentic baseline medical immunizations, the Complainant faces heavy, ongoing financial liabilities. The animal requires an extensive therapeutic regimen, laboratory follow-ups, and a complete primary vaccination re-schedule to survive, creating predictable, ongoing financial damages directly caused by the Opposite Party's deception.
5. Jurisdiction and Limitation

  • The transaction took place within the territorial limits of Coimbatore, and the Opposite Party carries out commercial business inside Coimbatore, giving this Hon’ble Commission territorial jurisdiction.
  • The cause of action arose on June 14, 2026. The complaint is filed well within the statutory two-year limitation period.
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PRAYER FOR RELIEF

In light of the facts narrated above, the Complainant respectfully prays that this Hon’ble Commission may be pleased to command the Opposite Party to:

  1. Refund the full purchase amount of ₹4,000/- along with an interest rate of 18% per annum from the date of purchase till actual realization.
  2. Pay initial veterinary expenses amounting to ₹680/- along with all further medical, therapeutic, and vaccination costs incurred during the pendency of this litigation, to be verified by subsequent bills.
  3. Pay a sum of ₹100,000/- as compensation for the severe mental agony, harassment, and emotional distress caused to the Complainant and his family.
  4. Pay a sum of ₹10,000/- toward the litigation expenses and legal costs incurred by the Complainant in bringing this action.
 

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