| Address: Paradise Club & Hospitality, Vadodara Office No. 201, 2nd Floor, Mindtree, Sunmoon Park, Akota,,Gujarat, Vadodara, 390020 |
The Complainant respectfully submits the following facts and grounds before this Hon'ble Commission:
1. Status of the Complainant
The Complainant is a consumer who entered into a membership/service arrangement with Paradise Club & Hospitality, Vadodara after relying upon the representations, assurances and benefits communicated by the Opposite Party.
The Complainant paid his hard-earned money towards the said membership/ service arrangement with the bona fide expectation that the services and benefits represented by the Opposite Party would be duly provided.
2. Representations and Assurances Made by the Opposite Party
The Opposite Party represented and/or assured the Complainant regarding various facilities, services, benefits and other advantages associated with the membership/programme.
Relying upon such representations and assurances, the Complainant paid a total amount of:
₹ 1, 20, 000/- (Rupees One lakh twenty thousand only).
Copies of the relevant receipts, bank statements and transaction records are being submitted along with this complaint.
3. Failure to Provide the Promised Services/Benefits
After making the required payment, the Complainant attempted to avail the services and benefits represented by the Opposite Party. However, the Complainant was not provided the promised services/benefits in the manner represented and expected.
Proof of Services were not provided, bookings were not honoured, promised facilities were unavailable, membership benefits were not provided, etc. attached. The above conduct has caused substantial inconvenience and financial loss to the Complainant.
4. Repeated Requests for Refund
The Complainant repeatedly contacted the Opposite Party and requested services for which membership fee in the form of Rs. 1, 20, 000/- paid. Such requests were made through telephone calls, WhatsApp messages, emails and/or other forms of communication. Despite repeated requests, the Opposite Party has failed to provide services as on the date of filing of this complaint. Copies/screenshots of the relevant correspondence are annexed with this complaint.
5. Deficiency in Service and Unfair Trade Practice
The Complainant submits that there is a material difference between the representations/assurances made by the Opposite Party and the services actually provided to the Complainant.
The failure to provide the promised services/benefits and the continued withholding of the amount paid by the Complainant, despite repeated requests for refund, constitute matters requiring examination under the applicable provisions of consumer protection law.
The Complainant therefore submits that the conduct of the Opposite Party amounts to deficiency in service and/or unfair trade practice, subject to determination by this Hon'ble Commission on the basis of the evidence placed on record.
6. Information Regarding FIR and Other Consumer Commission Proceedings
The Complainant has come to know of other complaints, criminal proceedings and consumer proceedings concerning Paradise Club & Hospitality, Vadodara which appear to involve allegations and circumstances relevant to the present complaint.
A. FIRs
As per the information available to the Complainant, FIR proceedings have been registered at Sayajigunj Police Station, Vadodara, including:
1. FIR No. [protected]; and
2. FIR No. [protected] dated[protected].
Copies/details of the relevant FIR documents, to the extent available with the Complainant, are being produced as supporting documents.
The Complainant relies upon these FIR details only as relevant information for consideration and verification by the appropriate authorities and does not seek to prejudge the guilt or criminal liability of any person.
B. Pravin Jadhav v. Paradise Club and Hospitality
The Complainant further relies upon the consumer proceeding:
Pravin Jadhav v. Paradise Club and Hospitality
Consumer Complaint No.: DC/446/CC/428/2024
Decision Date:[protected]
The said proceeding is relevant to the present complaint because it concerns the same Opposite Party, namely Paradise Club & Hospitality, Vadodara.
A copy of the relevant order/ judgment, if available, is being annexed with the present complaint.
C. Bhavyata Darshan Sheth v. The Paradise Club and Hospitality, Vadodara
The Complainant further brings to the notice of this Hon'ble Commission the following consumer proceeding:
Bhavyata Darshan Sheth v. The Paradise Club and Hospitality
Consumer Complaint No.: DC/447/CC/97/2025
Date:[protected]
The said proceeding is also relevant for consideration because it concerns The Paradise Club and Hospitality, Vadodara the same Opposite Party against whom the present complaint is being filed.
A copy of the relevant order/judgment, if available, is being annexed with the present complaint.
The Complainant respectfully submits that the above FIRs and consumer proceedings may kindly be taken on record and considered, subject to verification of the original records and their relevance to the facts of the present case.
The Complainant does not seek to prejudge the guilt, liability or legal consequences arising from any of the above proceedings. The information is brought before this Hon'ble Commission for a fair and complete appreciation of the circumstances surrounding the conduct of the Opposite Party.
7. Financial Loss Suffered by the Complainant
The Complainant paid ₹ Rs. 1, 20, 000/- from his hard-earned income relying upon the representations and assurances of the Opposite Party.
As the promised services/benefits were not duly provided and the amount has not been refunded, the Complainant has suffered direct financial loss.
The prolonged withholding of the Complainant's money has also caused considerable inconvenience, financial hardship, mental agony and loss of valuable time.
8. Cause of Action
The cause of action arose when the Opposite Party failed to provide the promised services/benefits and/or failed to refund the amount paid by the Complainant despite repeated requests.
The cause of action continues to subsist as the Complainant's money remains unpaid/refunded as on the date of filing of this complaint.
9. Documents and Evidence
The Complainant proposes to rely upon the following documents, as applicable:
1. Copy of membership/application form.
2. Membership agreement/contract and terms and conditions.
3. Payment receipts.
4. Promotional material, brochures and advertisements issued by the Opposite Party.
5. WhatsApp messages and chat records.
6. Emails and other correspondence.
7. Replies received from the Opposite Party.
8. Copy/details of FIR No. [protected].
9. Copy/details of FIR No. [protected] dated[protected].
10. Copy of the order/judgment in Pravin Jadhav v. Paradise Club and Hospitality, DC/446/CC/428/2024, decided on[protected].
11. Copy of the order/judgment in Bhavyata Darshan Sheth v. The Paradise Club and Hospitality, DC/447/CC/97/2025, dated[protected].
12. Any other documents relevant to the complaint.
10. Reliefs/Prayers
In view of the facts and circumstances stated above, the Complainant most respectfully prays that this Hon'ble Commission may be pleased to:
a. Direct the Opposite Party to refund the principal amount of ₹ Rs. 1, 20, 000/- paid by the Complainant;
b. Direct the Opposite Party to pay appropriate interest on the said amount from the date of payment or from such date as this Hon'ble Commission may deem appropriate until realization;
c. Award appropriate compensation to the Complainant for the financial loss, mental agony, inconvenience, harassment and loss of time suffered due to the acts and omissions of the Opposite Party;
d. Direct the Opposite Party to reimburse the litigation expenses and other reasonable costs incurred by the Complainant;
e. Hold, upon examination of the evidence, that the failure of the Opposite Party to provide the promised services and/or its conduct in relation to the transaction amounts to deficiency in service and/or unfair trade practice, as applicable under law;
f. Take into consideration, subject to verification and legal relevance, the aforementioned FIRs and consumer proceedings concerning the Opposite Party;
g. Pass such other order or direction as this Hon'ble Commission may deem fit and proper in the interest of justice.
11. No Unsubstantiated Allegations
The Complainant respectfully submits that this complaint is not intended to make any unsubstantiated allegation against any individual or entity.
The Complainant seeks only an impartial adjudication of the matter on the basis of the agreements, payment records, communications, promotional representations and other evidence available on record.
The Complainant seeks recovery of the money paid, appropriate compensation for the loss and inconvenience suffered, and such other relief as may be legally permissible.
VERIFICATION
I, Mr. Shrikant the Complainant herein, do hereby verify that the facts stated in paragraphs 1 to 11 of the above complaint are true and correct to the best of my knowledge and belief, based on the records and documents available with me, and that no material fact has been knowingly concealed.
Date: 27.08.2026
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