To,
1. General Motors India Private Limited
Chandrapura Industrial Estate, Halol – 389 351.
Dist. Panchmahals, Gujarat, India.

2. General Motors India Private Limited
Plot No. 15, Echelon Institutional Area,
Sector 32, Gurgaon – 122 00, Haryana, India.

3. M/s. S. C. Auto Corporation
Modi House No.1, Opp. LIC Building,
Naupada, Eastern Express Highway,
Thane (West), Thane - 400 602.

Dear Sirs,
We are concerned for our clients Mr. Nitin S. Jagdale, having his address at 601, Avior Kabra Galaxy Star II CHS, Opp. Dhamacha pada, Brahmand, Azad Nagar, G. B. Road, Thane (West) - 400607 and under his instructions, we have to address you as under :-
1) You are aware that our clients have purchased a vehicle being model name Chevrolet SAIL UVA TC (hereinafter referred to as said vehicle) from you Addressee No.3 for the sum of Rs. 7,26,910/- (Rupees Seven Lacs Twenty Six Thousand Nine Hundred and Ten Only). Our clients booked the said car on 10th May, 2013. And the same was delivered to our clients on 16th May, 2013. The details of the said vehicle are as under –

a. Registration No. MH04 GE 158
b. Chasis No. MA6SFBCADDT007648
c. Original Engine No. 10B7YZ130820162

2) You are aware that our client is a loyal customer of Chevrolet Motors (You Addressee No.1). Our client states that prior to the present vehicle, our client owned a Chevrolet Vehicle Model Optra LS 1.6 (Petrol) bearing Registration No. MH 03 Z 5716, bearing Chasis No. 1967544 (Year of Manufacture 2005). Our client states that he used the said vehicle upto 2013, and thereafter being a loyal customer of you Addressee No. 1, decided to purchase another vehicle of the same brand. Therefore, our clients visited you Addressee No.3 being authorized dealer of you Addressee No.1, somewhere in the first week of May, 2013. Our client states that after understanding needs and requirements of our clients, the sales representatives (MR. Anand Singh) of the Addressee No. 3 suggested our client to purchase a Chevrolet car being model SAIL UVA TC. At that time it was represented to our clients by the said representative that the said vehicle will give best performance without any cost of maintenance at least for five years. Our client states that the Indian 4 (Four) Wheeler market is dominated by Japanese, German and Indian Companies and though it was advised by his friends to purchase vehicles of any such other brands, he being a loyal customer of you Addressee No. 1 upon representation of the sales representatives of the Addressee No. 3 our client decided to purchase said vehicle. Our client states that while booking the vehicle, our client expected the best product from you Addressee No. 1 being International brand.

3) Our client states that accordingly our client purchased the vehicle on 10th May, 2013 for Ex-Showroom Price of Rs. 6,24,538/- (Six Lacs Twenty Four Thousand Five Hundred Thirty Eight Only). Our client paid sum of Rs. 7,26,910/- (Seven Lacs Twenty Six Thousand Nine Hundred Ten only) toward total consideration (On-Road Price). Our client states that the said car was purchased in exchange of his old vehicle after completing the formalities.

4) Our client states that along with the delivery of the car, the dealer handed over our client a Owner’s Manual interalia giving instruction with respect to operation, safety and maintenance of the vehicle. It is pertinent to mention herein that in the said instruction manual, it is mentioned as under:-
“Naturally, these Chevrolet retailer know everything about your car and provides you with the best service possible. In fact, every retailer is equipped with the most advanced technology, technicians specially trained by us and genuine spares. Needless to say, they are also committed to ensure your complete satisfaction.”

5) Our client states that after purchase of the said vehicle, our client started using it and experienced that the vehicle was not performing as expected and normal. It was expected by our client that the vehicle should give seamless performance and its driving should be as smooth as any other newly purchased vehicle. Unfortunately the engine of the vehicle was not smooth and was creating lot of unused noise during starting as well as while driving.

6) Our client states that as per the said Owner’s Manual and as advised by you Addressee No. 3, I lodged my vehicle for the first service checkup on 3rd June, 2013. Our client states that at that point of time it was brought to the notice of you Addressee No. 3 that the engine of the vehicle was creating unusual sound. The engineer of you Addressee No. 3 at that point of time informed our clients that since the vehicle is new, minor tuning of the engine will fix the problem. Our clients relying on the assurance of the service engineer, our client took the delivery of the vehicle after first checkup on 3rd June, 2013. Our client states that for the said service checkup, you Addressee No. 3 raised your Invoice dated 3rd June, 2013 bearing Invoice No. 002570 for Job No. 002597. Thereafter on one fine morning despite of several attempts (self-start) the vehicle could not start. The vehicle started only after around repeated attempts for around 30-35 minutes. Our client expected that it was a temporary problem but was surprised to get the said problem time and again though the monsoon was not started. Thereafter, the starting problem of the vehicle was usual headache for our client and the said problem was faced by our client everyday. Our client states that even after starting of the vehicle (after repeated attempts) i.e. during the driving of the vehicle, our client faced extremely unpleasant experience such as the vehicle has no power or the vehicle running, as old as used for more than 5-7 years. Disappointed by the said experience, our client reported the said problem to you Addressee No. 3. On 24.06.2013 the said vehicle was again given for rectifying the same problem to you Addressee No. 3 however, after doing investigation and checking of the vehicle, you Addressee No. 3 could not able to find or identify the problem in the vehicle. Our client states that thereafter, as advised by you Addressee No. 3, the said vehicle was taken back by our client as was represented by the engineer of you Addressee No. 3 that our client can use the vehicle and it will not give any further problem. Our client states that despite of the said assurance the vehicle continued to give problem and therefore again the vehicle was given to you Addressee No. 3 for repairs. Our client states that on this occasion also you Addressee No. 3, was unable to rectify the problem.

7) Our client states that thereafter on or about 4th or 5th July, 2013 when our client was driving the vehicle in heavy traffic on Thane, Ghodbunder Road, Maharashtra, suddenly the engine of the vehicle stopped running. Due to this breakdown the vehicle was towed to the service station i.e. you Addressee No. 3. The vehicle was thereafter delivered to our client on 6th July, 2013 under Invoice No. 004041 dated 6th July, 2013 for Job No. 004096. It was assured while giving the vehicle to our clients that the problem is now rectified and our client will have hassle free driving of the vehicle. Our client states that, the said assurance was totally false and our client continued to have said same problem frequently. Our clients therefore realized that the vehicle has manufacturing defects which cannot be rectified. Our client states that therefore the vehicle was again given for repair on 8th July, 2013. On or about 13th July, 2013, under Invoice No. 004287 dated 13th July, 2013 for Job. NO. 004164, our client was shocked to notice that the engine of the vehicle is replaced. Our client states that this is undoubted proof of manufacturing defect in the vehicle. Our client states that at that time our client realized that you Addressee Nos. 1, 2, 3 are trying to conceal the manufacturing defects in the vehicle. Our client was infact shocked to see that the engine was replaced. Our client states that the replacing of engine without following due procedure is infact offence under the Motor Vehicles Act as the details of the engine is already mentioned on the vehicle record maintained by the Government of Maharashtra and on R.C. Card. Our client states that the replacing of the engine unilaterally without our client’s consent without following the due procedure is a fraud played by you Addressee No. 3 and also amounts to tampering of government record. Our client states that he has all reason to believe that you Addressee No. 3 has not followed the due procedure for allegedly replacing the old engine with the new one. Our client states that he has reasons to believe that either you Addressee No. 3 has not replaced the engine or if the engine is replaced, the same is not done after following the due procedure as required under law. Our client states that while taking the delivery on 13th July, 2013, our client was unaware, being a layman about the serious repercussions of the violation of the law by you Addressee No. 3. While delivering the vehicle on 13th July, 2013 when our client inquired the reasons for replacement of the engine, it was informed by you Addressee No. 3 that the engine had defect and therefore the same is replaced by you. You must be undoubtedly aware that the engine is a main part of the vehicle. All other equipments are required to be turned up and synchronized with the engine. Assembling of a vehicle’s parts including is highly systematic technical procedure. Such procedure is undertaken by extremely sophisticated, automatic and computerized machines and mechanism. It is highly impossible to get the setting of vehicle at service station as it is done while its manufacture it especially when the engine is replaced. It is obvious that the defect in the vehicle continued. Our client had purchased a vehicle as whole and not only the engine, therefore it is duty on you to replace the entire car.

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