1. That I have been availing of cellular services from Vodafone company as a “postpaid customer” since the past more than 15 years.
2. That vide email from “vodafonebill.[protected]@vodafoneidea.com” dt. Fri. Apr. 26, 6.50 PM you raised a bill of Rs. 54, 936.32 ps. for Rs. 54, 936.32 ps. which is a false and bogus charge in consequence of the crimes committed by Vodafone.
3. That Vodafone has a criminal strategy made to fleece and blackmail international travellers to make wrongful gains. That Vodafone is guilty of luring vide their SMS dated 31st March 2019 sent my cell no. claiming that “i-RoamFree” roaming pack for Rs. 2, 999/- would give free cellular access to over 65 different countries and trusting such representations on the basis of trust built over the past several years I bought the said pack on 1st April 2019 through “Vodafone App” for Rs. 2, 999/-.
4. Vodafone is guilty for suppressing important information and also guilty for misrepresentation of facts and information vital to the services sold and this suppressed information was later misused and Vodafone took advantage of the same to raise false & huge usage charges and thereafter forced and blackmailed me to cough up monies to satisfy their claims failing which I faced disruption of my cellular services on the cell no.
5. That Vodafone deliberately and intentionally failed to perform its obligation as a contracted cellular service provider and further committed crimes viz. for conniving and colluding together to commit an offence AND for concealing a design to commit an offence punishable with imprisonment AND for entering into a criminal conspiracy to commit mischief, blackmail, extortion, wrongful restraint, forging electronic record, falsification of accounts, cheating, breach of trust, etc. and this modus operandi amounts to “deficiency of services” and “unfair trade practices” that are explained as under;
a. That I had a transit halt in Bahrain for about 5-6 hours beginning from 20:00 hrs. on 1st April[protected] till 01;55 hrs. on 2nd April 2019 Bahrain Standard Time and during the said transit halt, without suspecting any mischief I received full network coverage, whereby I unknowingly and unaware that the network available is not covered in the “i-RoamFree” pack covering 65 countries unsuspectingly made and received calls for about approximately 10-12 minutes, which usage could never amount to 40 MB of data as falsely alleged. In-fact, I was lured to use the cellular network in Bahrain as there were no pre-call warnings of any kind issued by Vodafone.
b. My simple questions are that when the Vodafone company did not have network coverage in Bahrain as alleged that Bahrain was not covered under the “i-RoamFree” pack then why was my cell no. allowed to be activated in Bahrain? Why didn’t Vodafone warn, verify and confirm by SMS or email the moment I landed in Bahrain that “i-RoamFree” pack was not available in Bahrain? Why did Vodafone system wait for a period of 5 hrs. to send the first SMS? Why was the I not warned or given the option to decide whether I wanted to use the Bahraini network coverage for a cost of Rs. 1000/- per MB of data on not? Why was such a costly network deceptively given free access to? Why did Vodafone allow me to make phone calls of about 10-12 minutes when Vodafone could have easily stopped me from making any calls after the first call from Bahrain was logged into Vodafone system? Why did Vodafone wait till I used 40 MB data as falsely alleged during transit in Bahrain? Why was I allowed to use network coverage in Bahrain without my asking and then why did Vodafone go on to falsely claim a huge amount? Why was I not warned that cellular services in Bahrain were costly and that cellular usage would result in huge bills which I would have to settle immediately or suffer discontinuation of service? Why did Vodafone send SMS’s to my cell phone at 1:00 Hrs. Bahrain Std. Time on 2nd April 2019 after I had already spent 5 hours in Bahrain and after I had as falsely alleged used 40 MB data as falsely claimed? And lastly why did Vodafone allow me to cross the credit limit of Rs. 9000/- allocated me without my asking or knowledge?
c. I was induced to use such network in Bahrain as there were no warnings of any kind issued by Vodafone and it was only a planned after-thought to commit the fraud and charge me illegally and unlawfully, criminally conspiring to allow the network get freely logged into my cell no. as I had never chosen or preferred manually any service provider in Bahrain and since my cell no. was automatically activated that with all logic I assumed that I received network covered by the “i-RoamFree” pack purchased from Vodafone who dishonestly trapped me to unsuspectingly use the automatic network that logged into my cell as if it was a trap set up by Vodafone Fraud Department to make wrongful gains.
d. That after deceptively allowing free cellular usage to me without any warning of any kind that Vodafone sent SMS’s to blackmail and extort monies from me and since I did not succumb to Vodafone’s blackmailing tactics to extort monies, hence Vodafone disrupted my cellular services to my cell no.
e. Vodafone’s acts stink of deceptive criminal intention and mischief and Vodafone are guilty of forging electronic record AND also for making claims on the basis of the forged record and treating the same as genuine AND Vodafone are also guilty for falsification of accounts as Vodafone conspired to falsify the usage charges on the basis of the forged electronic record alleged to be the usage logged in the cell no. and falsified the account with inflated charges to falsely claim Rs 42652/- to cause wrongful losses to me AND Vodafone is guilty for concealing a design to commit an offence by entering into this criminal conspiracy, by exercising deft deception to trap international travellers firstly by concealing the name of countries covered in roaming packs and then by allowing them to freely use cellular networks which are not covered in their roaming packs without any pre-warning and then to raise huge bills to make wrongful profits, and then to blackmail international travellers to pay up or face disruption which apart from crimes punishable under the Indian Penal Code also amount to a very serious case of “deficiency of services” and “unfair trade practices”.
6. That Vodafone has failed and neglected to comply with the contractual and statutory obligations and are guilty of providing “deficiency in service” and have committed “unfair trade practice”.
7. That Vodafone is guilty for causing colossal loss of my name and standing by adopting unfair trade practices that have caused tremendous mental and physical agony and unfathomable economic losses through your systematic corporate fraud by blackmailing international travelers.
8. That In light of the crimes committed by Vodafone through the distinct roles played by people employed under your fraudulent system as mentioned hereinabove, that I filed a criminal complaint dated[protected] against Vodafone along-with Goregaon Police Station officers under the Indian Penal Code and the said complaint is kept for verification.
9. I call upon Vodafone to immediately reinstate services to my cell no; [protected] within 24 hours, rectify the intended defects, tweaks and glitches in your system, software and services, send an apology for causing colossal loss of my name and standing by adopting unfair trade practices and for causing tremendous mental and physical agony failing which I shall be forced to file a Consumer Complaint against Vodafone for being guilty of “deficiency of services” and “unfair trade practices” as envisaged under the Consumer Protection Act, and further seek order and directions for compensation and damages totally amounting to sixty lakhs, hence this notice.
Vodafone India customer support has been notified about the posted complaint.
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