Dear Sir,

I am the Executive Secretary of the Worthy Chairman of FIL Industries Limited and am posted at Head Office, Srinagar. My Worthy Chairman had a BSNL Mobile phone bearing Cell No. 9419001333.

During the month of Feb 2009 his previous Mobile-Set became unserviceable and the Worthy Chairman directed me to purchase a new Nokia Mobile-set from any Authorized Dealer of the Company. Accordingly, I purchased a Nokia Mobile Phone of Model N-82 bearing IMEI No. 358984017307433 from one of your Authorized Agents namely M/s Links, situated at Shopping Mall, Residency Road, Srinagar-190001 Kashmir, for an amount of Rs.19, 300/- vide their Invoice No. 8563 dated 23-02-2009. (Photostat copy enclosed).

Immediately, after the purchase of this Mobile Set, it started giving trouble to the Worthy Chairman ---trouble by way of its erratic functioning, like “Improper Shutdown” while dialing---displaying “Emergency Calls only” and always showing “Insert SIM” though the SIM was being already inserted in it, besides switching off without our actions.

It was right from the date of its purchase after a call or during the call, the phone was going into hibernation, instantly without any action and finally switching it off. When I came to know the trouble, I contacted the dealer, from whom I had purchased it, who directed me to contact the Nokia’s authorized Service Centre, situated at Lal Chowk, Srinagar namely M/s Nokia Care, C-6, Municipal Building, 2nd Floor, Opp. Appna Bazaar, Lal Chowk, Srinagar.

The Service Centre-people who were very cooperative/kind enough, many times repaired it and on each occasion it was returned to me with the assurance that the problem will not be repeated in future. But the defect was never rectified and we had to face the same trouble.

After lying the Mobile set with the Service Centre for a pretty long time, they directed me to hand it over to them for its dispatch to their some higher office for necessary repairs or they would obtain a fresh set for me in its place. This practice was repeated three- four time and we went on through the same drill for about 6-7 months.

But each time when the mobile was returned to me, it was always giving the same troubles and I had to cut a sorry figure in presence of my Esteemed Boss. On each occasion to my surprise, it did not function properly and the said defects were still persisting there, as before. I also informed you to this effect vide my e-mail, dated 16-09-2009. (copy enclosed.)

Finally, the Nokia Care Centre, Srinagar advised me, again to hand over the Phone to them for its onward transmission to their Central Repair Centre, which was finally returned to me after a period of about 1 and a half month. This time the Company had sent its replacement bearing IMEI No. 35984012202266 (2nd hand), in Silver Colour.

After seeing the phone, my Esteemed Boss directed me to replace its cover as he had no liking for a Silver Colour and wanted it in a Black Colour. I contacted the Service Centre people, who told me that the replacement had come in the Silver colour and they cannot help us in providing a Black Colour Case. I placed an order for Original Black Case of the Mobile Set, who demanded me Rs.5000/- as cost of the case which was agreed to buy me and an advance of Rs.2000/- was also deposited with them.

In the meanwhile the SIM was inserted in this Silver Colour Set, Surprisingly; this set also did not function properly as it contained the same problems as the First one had with one more additional defect i.e. low voice having sound card defect. The same has been returned back to your Srinagar Nokia Centre vide their Jobsheet No. 2009121922. This futile exercise being played with us by your company amounts to Naked Cheating which is highly deplorable, necessitating a proper legal action to be taken against your Company on this Account.

My learned Boss is the Head (Chairman) of a Celebrated Company namely FIL Industries limited, whose annual turnover is around Thirteen Hundred Thousand Crores. We have our Head Office at Srinagar and Corporate Office at New Delhi. Our branch offices are scattered throughout the Country. As per the directives of my Esteemed Boss, all FIL Staff-people are using NOKIA Brand Mobile Sets. But with this shameful episode, we would be compelled to rethink on the contrary for the future.

Now, I have been directed by my Worthy Chairman to serve you this notice with the demand that the Company should immediately refund us the cost of Mobile with a lump sum amount of Rs. 50, 000/= as damages towards us. The Mobile Set bearing IMEI No. 358984017307433 purchased by us is within the Warranty Period.

In case The Company did not respond to our genuine demand within the stipulated time as indicated in this letter, we shall have no alternative but to file a Criminal Case against your Company and the Dealer besides instituting a Formal Case in the Consumer Court, for defrauding and cheating us by supplying a damaged defective phone, thereby causing tremendous losses to our business and putting an esteemed personality to embarrassment and inconvenience.

Waiting for your reply by or before 10th of January 2010.


Yours faithfully,

for FIL Industries Limited


(Showkat Mohi-ud-din)

Executive Secretary to the Chairman

Cell No.0091-9419001440