MVnazarethe
New member
- Dealer Name
- ultimate power solutions Adoor.
- Company Name
- Hykon India Ltd
- Product Name
- Moon SS210LPD SL no. 25101879
- Customer Care Number
- 9020121121
- Loss Amount
- 34000
- Ratings
- Opposite Party Address
- Theverethu House, House No. 017/176 A, Kurichimuttom PO, pathanamthitta 689532
BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION, PATHANAMTHITTA, KERALA
CONSUMER COMPLAINT
Under the Consumer Protection Act, 2019
In the matter of:
Complainant:
Monnie Varugese
Theverethu House, House No. 017/176 A
kurichimuttom P.O 689532, Pathanamthitta District, Kerala
Mobile: 9778709642
Email: monniev96@gmail.com
Versus
Opposite Party No. 1 – Manufacturer / Brand Owner:
Hycon India Ltd., Hykon House, ikkanada Warrier Road, Thrissur-1, phone: 2444183
Helpline: 9020121121
email: accounts@hykonindia.com
Opposite Party No. 2 – Seller / Dealer:
Ultimate Power Solutions Adoor, Bliz Buildings Vinobaji Road, Adoor 691523 Mob: 9744420010. Email: mailme2ups@gmail.com
COMPLAINT UNDER THE CONSUMER PROTECTION ACT, 2019
The Complainant respectfully submits as follows:
1. Details of the Product
The Complainant purchased a Haikon Moon SS-210 LPD Solar Water Heater on 2 January 2026 for a total consideration of ₹34,000/-.
The product was purchased for personal/domestic use at the Complainant’s residence and therefore the Complainant is a “consumer” within the meaning of the Consumer Protection Act, 2019.
A copy of the purchase invoice and warranty documents are produced along with this complaint.
2. Defect Developed During the Warranty Period
The solar water heater developed a serious leakage problem on or about 27 July 2026.
The leakage was not a minor cosmetic issue. Leakage continued from the tube-side/tank portion of the solar heater and affected the normal and safe use of the product.
As the product was under warranty, the Complainant contacted the Opposite Party and registered a complaint.
The complaint was registered under Complaint No.:
KOTH/2627/3389
3. Service Visit and Attempted Rectification
Following the complaint, a technician attended the installation and attempted certain repairs.
The technician:
1. Replaced the inlet washer;
2. Replaced the outlet washer; and
3. Rectified the air vent.
However, despite these repairs, the tube-side/tank leakage continued.
Therefore, the fundamental defect in the product was not rectified.
4. Technician Visit/Report dated 4 August 2026
A technician attended the complaint and reported/recorded the service work on 4 August 2026.
Although certain components were attended to, the leakage from the tube-side/tank portion continued.
The Complainant therefore continued to remain without a properly functioning solar water heater.
5. Technician Visit/Report dated 18 August 2026
The technician again attended/reported the complaint on 18 August 2026.
Even after this further service intervention, the leakage problem was not rectified.
In fact, the technician has closed the water inlet and outlet to the solar-heater tank, leaving the tank isolated because of the continuing leakage.
Consequently, the product purchased for ₹34,000/- has not been restored to normal working condition.
6. Failure to Provide Effective Warranty Remedy
The Complainant submits that repeated attempts at service have failed to rectify the principal defect.
The product is still leaking from the tube-side/tank portion, and the water supply to the solar-heater tank has been closed.
The Complainant purchased the product with the reasonable expectation that it would be of satisfactory quality, free from manufacturing/product defects, and that any defect arising during the warranty period would be effectively rectified by the manufacturer/service provider.
Despite the complaint being raised during the warranty period and despite repeated technician visits, the fundamental defect remains unresolved.
7. Deficiency in Service
The Complainant submits that the failure to effectively rectify the defect despite repeated warranty-service interventions amounts to deficiency in service.
Merely replacing washers and rectifying the air vent has not resolved the continuing tube-side/tank leakage.
The Complainant has therefore been deprived of the normal use and benefit of the product for which ₹34,000/- was paid.
8. Continuing Cause of Action
The defect first came to the Complainant’s notice on 27 July 2026.
The complaint was registered under Complaint No. KOTH/2627/3389.
Despite service attempts on 4 August 2026 and 18 August 2026, the defect continues.
The cause of action is therefore continuing as on the date of filing this complaint.
9. Loss, Inconvenience and Hardship
Because of the continuing defect:
● The solar water heater cannot be used normally.
● The water inlet and outlet to the tank have been closed.
● The Complainant has had to repeatedly contact the manufacturer/service personnel.
● Multiple service interventions have failed to resolve the principal defect.
● The Complainant has suffered inconvenience and loss of the benefit of the purchased product.
The Complainant therefore seeks appropriate compensation and costs as permitted under the Consumer Protection Act, 2019.
10. Jurisdiction
The Complainant resides in Pathanamthitta District, Kerala, and the transaction/product/service complaint has a connection with the territorial jurisdiction of the District Consumer Disputes Redressal Commission, Pathanamthitta.
The Complainant therefore approaches this Hon’ble Commission seeking appropriate relief under the Consumer Protection Act, 2019.
11. Limitation
The complaint is being filed promptly after the defect arose and while the product is under warranty. The complaint is therefore within the applicable limitation period.
RELIEFS / PRAYER
In view of the facts stated above, the Complainant respectfully prays that this Hon’ble Commission may be pleased to:
A. Replacement of defective product
Direct the Opposite Parties to replace the defective Haikon Moon SS-210 LPD solar water heater/tank with a new, defect-free product of the same or equivalent specification, at no additional cost to the Complainant.
OR, IN THE ALTERNATIVE
Direct the Opposite Parties to refund the purchase price of ₹34,000/- paid by the Complainant, together with such interest as this Hon’ble Commission considers appropriate.
B. Compensation
Direct the Opposite Parties to pay reasonable compensation to the Complainant for the inconvenience, hardship, loss of use and other consequences suffered due to the defective product and failure to provide an effective warranty remedy.
Compensation claimed: ₹Rs.38000/-
C. Litigation expenses
Direct the Opposite Parties to reimburse the Complainant for reasonable costs and expenses incurred in pursuing the complaint.
Litigation/other expenses claimed: ₹5000.00
D. Other appropriate relief
Grant any other relief that this Hon’ble Commission considers just and proper in the circumstances of the case.
LIST OF DOCUMENTS / ANNEXURES
The Complainant proposes to rely upon the following documents:
Annexure A – Copy of purchase invoice showing purchase of Haikon Moon SS-210 LPD solar water heater for ₹34,000/-.
Annexure B – Copy of warranty card/warranty terms.
Annexure C – Photographs showing leakage from the solar heater.
Annexure D – Videos/photos showing continuing tube-side/tank leakage.
Annexure E – Copy/screenshot of complaint registration bearing Complaint No. KOTH/2627/3389.
Annexure F – Technician/service report dated 4 August 2026.
Annexure G – Technician/service report dated 18 August 2026.
Annexure H – Records/messages/WhatsApp communications exchanged with the manufacturer/service personnel.
Annexure I – Photographs showing the inlet and outlet to the solar-heater tank having been closed/isolated.
Annexure J – Any additional service reports, communications, bills or expenses relating to the defect.
VERIFICATION
I, [Monnie Varughese] the Complainant above named, do hereby verify that the facts stated in paragraphs 1 to 11 of this complaint are true and correct to the best of my knowledge and belief and that I have not knowingly concealed any material fact.
Place: Pathanamthitta, Kerala
Date: 19/8/26
Signature of Complainant
Monnie Varughese
CONSUMER COMPLAINT
Under the Consumer Protection Act, 2019
In the matter of:
Complainant:
Monnie Varugese
Theverethu House, House No. 017/176 A
kurichimuttom P.O 689532, Pathanamthitta District, Kerala
Mobile: 9778709642
Email: monniev96@gmail.com
Versus
Opposite Party No. 1 – Manufacturer / Brand Owner:
Hycon India Ltd., Hykon House, ikkanada Warrier Road, Thrissur-1, phone: 2444183
Helpline: 9020121121
email: accounts@hykonindia.com
Opposite Party No. 2 – Seller / Dealer:
Ultimate Power Solutions Adoor, Bliz Buildings Vinobaji Road, Adoor 691523 Mob: 9744420010. Email: mailme2ups@gmail.com
COMPLAINT UNDER THE CONSUMER PROTECTION ACT, 2019
The Complainant respectfully submits as follows:
1. Details of the Product
The Complainant purchased a Haikon Moon SS-210 LPD Solar Water Heater on 2 January 2026 for a total consideration of ₹34,000/-.
The product was purchased for personal/domestic use at the Complainant’s residence and therefore the Complainant is a “consumer” within the meaning of the Consumer Protection Act, 2019.
A copy of the purchase invoice and warranty documents are produced along with this complaint.
2. Defect Developed During the Warranty Period
The solar water heater developed a serious leakage problem on or about 27 July 2026.
The leakage was not a minor cosmetic issue. Leakage continued from the tube-side/tank portion of the solar heater and affected the normal and safe use of the product.
As the product was under warranty, the Complainant contacted the Opposite Party and registered a complaint.
The complaint was registered under Complaint No.:
KOTH/2627/3389
3. Service Visit and Attempted Rectification
Following the complaint, a technician attended the installation and attempted certain repairs.
The technician:
1. Replaced the inlet washer;
2. Replaced the outlet washer; and
3. Rectified the air vent.
However, despite these repairs, the tube-side/tank leakage continued.
Therefore, the fundamental defect in the product was not rectified.
4. Technician Visit/Report dated 4 August 2026
A technician attended the complaint and reported/recorded the service work on 4 August 2026.
Although certain components were attended to, the leakage from the tube-side/tank portion continued.
The Complainant therefore continued to remain without a properly functioning solar water heater.
5. Technician Visit/Report dated 18 August 2026
The technician again attended/reported the complaint on 18 August 2026.
Even after this further service intervention, the leakage problem was not rectified.
In fact, the technician has closed the water inlet and outlet to the solar-heater tank, leaving the tank isolated because of the continuing leakage.
Consequently, the product purchased for ₹34,000/- has not been restored to normal working condition.
6. Failure to Provide Effective Warranty Remedy
The Complainant submits that repeated attempts at service have failed to rectify the principal defect.
The product is still leaking from the tube-side/tank portion, and the water supply to the solar-heater tank has been closed.
The Complainant purchased the product with the reasonable expectation that it would be of satisfactory quality, free from manufacturing/product defects, and that any defect arising during the warranty period would be effectively rectified by the manufacturer/service provider.
Despite the complaint being raised during the warranty period and despite repeated technician visits, the fundamental defect remains unresolved.
7. Deficiency in Service
The Complainant submits that the failure to effectively rectify the defect despite repeated warranty-service interventions amounts to deficiency in service.
Merely replacing washers and rectifying the air vent has not resolved the continuing tube-side/tank leakage.
The Complainant has therefore been deprived of the normal use and benefit of the product for which ₹34,000/- was paid.
8. Continuing Cause of Action
The defect first came to the Complainant’s notice on 27 July 2026.
The complaint was registered under Complaint No. KOTH/2627/3389.
Despite service attempts on 4 August 2026 and 18 August 2026, the defect continues.
The cause of action is therefore continuing as on the date of filing this complaint.
9. Loss, Inconvenience and Hardship
Because of the continuing defect:
● The solar water heater cannot be used normally.
● The water inlet and outlet to the tank have been closed.
● The Complainant has had to repeatedly contact the manufacturer/service personnel.
● Multiple service interventions have failed to resolve the principal defect.
● The Complainant has suffered inconvenience and loss of the benefit of the purchased product.
The Complainant therefore seeks appropriate compensation and costs as permitted under the Consumer Protection Act, 2019.
10. Jurisdiction
The Complainant resides in Pathanamthitta District, Kerala, and the transaction/product/service complaint has a connection with the territorial jurisdiction of the District Consumer Disputes Redressal Commission, Pathanamthitta.
The Complainant therefore approaches this Hon’ble Commission seeking appropriate relief under the Consumer Protection Act, 2019.
11. Limitation
The complaint is being filed promptly after the defect arose and while the product is under warranty. The complaint is therefore within the applicable limitation period.
RELIEFS / PRAYER
In view of the facts stated above, the Complainant respectfully prays that this Hon’ble Commission may be pleased to:
A. Replacement of defective product
Direct the Opposite Parties to replace the defective Haikon Moon SS-210 LPD solar water heater/tank with a new, defect-free product of the same or equivalent specification, at no additional cost to the Complainant.
OR, IN THE ALTERNATIVE
Direct the Opposite Parties to refund the purchase price of ₹34,000/- paid by the Complainant, together with such interest as this Hon’ble Commission considers appropriate.
B. Compensation
Direct the Opposite Parties to pay reasonable compensation to the Complainant for the inconvenience, hardship, loss of use and other consequences suffered due to the defective product and failure to provide an effective warranty remedy.
Compensation claimed: ₹Rs.38000/-
C. Litigation expenses
Direct the Opposite Parties to reimburse the Complainant for reasonable costs and expenses incurred in pursuing the complaint.
Litigation/other expenses claimed: ₹5000.00
D. Other appropriate relief
Grant any other relief that this Hon’ble Commission considers just and proper in the circumstances of the case.
LIST OF DOCUMENTS / ANNEXURES
The Complainant proposes to rely upon the following documents:
Annexure A – Copy of purchase invoice showing purchase of Haikon Moon SS-210 LPD solar water heater for ₹34,000/-.
Annexure B – Copy of warranty card/warranty terms.
Annexure C – Photographs showing leakage from the solar heater.
Annexure D – Videos/photos showing continuing tube-side/tank leakage.
Annexure E – Copy/screenshot of complaint registration bearing Complaint No. KOTH/2627/3389.
Annexure F – Technician/service report dated 4 August 2026.
Annexure G – Technician/service report dated 18 August 2026.
Annexure H – Records/messages/WhatsApp communications exchanged with the manufacturer/service personnel.
Annexure I – Photographs showing the inlet and outlet to the solar-heater tank having been closed/isolated.
Annexure J – Any additional service reports, communications, bills or expenses relating to the defect.
VERIFICATION
I, [Monnie Varughese] the Complainant above named, do hereby verify that the facts stated in paragraphs 1 to 11 of this complaint are true and correct to the best of my knowledge and belief and that I have not knowingly concealed any material fact.
Place: Pathanamthitta, Kerala
Date: 19/8/26
Signature of Complainant
Monnie Varughese