OPEN LETTER THE HON BLE CHIEF JUSTICE OF INDIA, APPEAL TO RESTORE THE RIGHTS OF THE TELECOM CONSUMERS IN THE COUNTRY AND OR FOR SUO MOTU

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1 1 OPEN LETTER To THE HON BLE CHIEF JUSTICE OF INDIA, SUPREME COURT OF INDIA, TILAK MARG, NEW DELHI APPEAL TO RESTORE THE RIGHTS OF THE TELECOM CONSUMERS IN THE COUNTRY AND OR FOR SUO MOTU REVIEW OF THE HON BLE SUPREME COURT ORDER TITLED GM TELECOM VS M. KRISHNAN BEARING CIVIL APPEAL NO. 7687/04 DATED I, Ramesh Kumar Rohilla, a telecom consumer, most respectfully submit before the Hon ble Supreme Court this appeal as follows which is related to maintainability of the complaint of millions of individual consumers before consumer fora: 1. BRIEF FACTS OF THE CASE The Hon ble Apex Court vide order dated in General Manager, Telecom vs M. Krishnan & others bearing Civil Appeal no. 7687/04 has ousted the jurisdiction of the telecom disputes before consumer fora while reversing the order of full Bench of Kerala High Court. The true typed copy of this order is annexed as ANNEXURE P/1 (Page 30-32).

2 2 The origin of this case was the disconnection of the telephone of a subscriber M. Krishnan in 2001, for outstanding dues against the telephone of his landlord TK Reghunath and on the complaint of the consumer, the Hon ble Kozhikode District Consumer Forum directed BSNL to restore the connection and pay compensation. In response, BSNL filed a writ petition before the High Court of Kerala, challenging the jurisdiction of the consumer court in view of Section 7B of the Telegraph Act, The single bench as well as full bench of the Kerala high court dismissed it. The full bench has relied on the view that the remedies under the CP Act, 1986 are in addition to and not in derogation of the provisions of any other law in force. This full bench order further said that The special law always overrides the general law. However, the question is - which is the special law? In our view, the 1986 Act having been enacted with the object of providing 'better protection', the statute would be the special law in so far as the rights and remedies of a 'consumer' against the wrongs committed by the provider of a service are concerned. The doubt, if any, was clarified by the Parliament by enacting the provisions contained in sections 1(4) & 3. Thus, even if the principle of special law overriding the general law is

3 3 invoked, we have no hesitation in holding that in a matter like the present one, the 1986 CP Act would operate as the special law. The copy of this order of the Hon ble Kerala High Court order is annexed as ANNEXURE P/2 (Page 33-48). But the Hon ble Supreme Court in this ex-parte order reversed the above said order of full bench of High Court of Kerala and considered the Telegraph Act, 1885 as the special law and CP Act, 1986 as general law and reliance was placed upon the judgment in Chairman, Thiruvalluvar Transport Corporation vs Consumer Protection Council (1995) 2 SCC 479 wherein it was held that the National Commission has no jurisdiction to adjudicate upon claims for compensation arising out of motor vehicles accidents. The Hon ble Supreme Court ruled that when there is a special remedy (arbitration) provided in Section 7B of the Indian Telegraph Act regarding disputes in respect of telephone bills, then, the remedy under the Consumer Protection Act is by implication barred. The Hon ble Supreme Court further ordered that if any dispute concerning any telegraph line, appliance or apparatus arises between the telegraph authority and the person for whose benefit the line, appliance or apparatus is, or has been provided, the dispute shall be determined

4 4 by arbitration under section 7B of the telegraph act, The award of the arbitrator appointed shall be conclusive between the parties to the dispute and shall not be questioned in any court. 2. REPERCUSSIONS & IMPLICATIONS OF THIS CASE The above verdict of Hon ble Supreme Court has shaken the foundation of the consumer justice system and just after it; thousands of the genuine consumers with pending complaint before various consumer courts of the country were forced to face the wrath of dismissal of the complaints for the simple reason that it is a telecom dispute. Every day, one and the other complaints are being dismissed without any valid reason and a long queue has lined up. The height of rejection of such complaints due to jurisdiction can be gauged from a common order of Hon ble State Commission, Chennai, where 60 complaints were dismissed on a single day on which reminds a saying shoot the maximum with one bullet. Various orders by Hon ble National Commission are being passed where complaints of individual consumers are being rejected straightway. It appears that the protection granted to consumers by Consumer Protection Act, 1986 has become meaningless because those who

5 5 are entrusted with the job of doing justice are not delivering quality orders towards consumers problems. It is truly a travesty of the justice that consumers are being forced to bear such pain & unfair trade practice and all the telecom service providers are celebrating on such erroneous orders. Since mobile/telephone users are huge, thus, even an iota of misappropriation is a big gain e.g. ` 1 per person per day can fetch over 90 Crore which is alarming. It appears that this is how various telecom service providers have become richest and most profitable organizations in the country. Today the scenario is that justice is out of the bounds for the general public in the country to redress the grievances of an individual telecom consumer because of the mess and confusion about jurisdiction due to the above verdict. The consumers are thus forced to approach various forums one and the other and presently there is no clarity rather it is an ambiguity where to file the complaint for justice. 3. INTEREST OF THE PUBLIC & THE APPELLANT The said order of Hon ble Supreme Court has taken away rights of over 900 million telecommunication consumers to sue telecom companies in consumer courts and thus has caused turmoil in the consumer

6 6 justice system. Millions of complaints are pending before various forums as on date against almost all the service providers including 1.28 Lac against BSNL alone. And further, due to the above ruling, the appellant is also a victim of a telecom giant who challenged the authority of consumer court on the basis of provision (7B) of the telegraph act, 1885 that did not apply to it at all. The appellant had filed an exemplary Revision Petition No. 190/2012 titled RK Rohilla vs Bharti Airtel Limited before Hon ble National Commission relying on the latest TRAI Act, 1997 applicable to adjudicate such telecom disputes but the Hon ble National Commission dismissed the revision petition and held that the judgment of Hon ble Supreme Court namely GM Telecom vs M. Krishnan is binding on us and we respectfully follow the same and further the scope of revisional jurisdiction is very limited. The history of the telecom matters shows how such small issues which hardly require ten minutes for explanation are being dragged and the consumers are deprived of their legitimate rights. The Hon ble Nation Commission and various State Commissions are deciding the matters barring the jurisdiction before consumer fora. A few examples are :

7 7 i. Hon ble State Commission, Chennai, a common order dated having 60 appeals filed by the Telecom Service Providers like BSNL, Reliance, Bharti Telenet, Vodafone & Tata Tele. ii. Hon ble State Commission, Bhopal, order dated titled Reliance Telecom Ltd. Versus Jay Kumar Jain. iii. Hon ble State Commission Haryana, order dated titled Bharti Airtel vs Anil Harnikiya. iv. Hon ble State Commission Haryana, order dated titled Bharti Airtel vs Karan Singh. v. Hon ble State Commission Chennai, order dated titled M. Gunasekaran vs Reliance. vi. The Hon'ble National Commission order dated titled Prakash Verma vs Idea Cellular. vii. The Hon'ble National Commission order dated titled Mani Ram Pareek vs BSNL. viii. The Hon'ble National Commission order dated titled Ziyauddin Alvi vs Bharti Airtel. ix. The Hon'ble National Commission order dated titled Lokesh Parashar vs Idea. x. The Hon'ble National Commission order dated titled RK Rohilla vs Bharti Airtel Ltd., the true typed copy of this order is annexed as ANNEXURE P/3 (Page 49-55).

8 8 The plain reading of all the above cases will reveal how all telecom service providers are using the said order of the Hon ble Supreme Court as a safe and great tool to question the maintainability of a consumer complaint under the Consumer Protection Act. Ironically, various State Commissions and the National Commission without referring TRAI Act & wrongly interpreting the order of the Hon ble Apex Court, are straightway dismissing the complaints of the genuine consumers without giving any valid reason or merely saying that the dispute is related to telephone where the Hon ble Apex Court has ousted the jurisdiction of the consumer fora. Due to the dismissal of telecom complaints of the consumers, an irreparable loss and damage is being caused to the public in large which cannot be compensated at all. Therefore, the appellant hereby submits this appeal to restore the rights of telecom consumers and or for an urgent Sue Moto Review of the above Hon ble Supreme Court order titled GM Telecom vs M. Krishnan. 4. QUESTIONS OF LAW : The following substantial questions of the law of general telecom consumer importance arise for kind consideration by this Hon ble Supreme Court:

9 9 i) Whether the views taken on maintainability of the consumer complaint by the Hon ble Supreme Court in the verdict dated relying on section 7B of Indian Telegraph Act, 1885 are correct and fulfills the object of judiciary in the light of latest amendments given in section 14 of TRAI Act, 1997 itself? ii) Whether the Hon ble Supreme Court should pass any ex-parte verdict relying solely on Telegraph Act, 1885 while deciding any telecom matter without referring even the definitions of the TRAI Act, 1997 & further Telecom Consumers Protection and Redressal of Grievances Regulations 2007 which are relevant and latest acts to decide any dispute between a consumer & the service provider in the country? iii) Whether the telegraph authority mentioned in the verdict and defined under section 3(6) of telegraph act has the responsibility to provide telephone connections to any of the consumer in the country as on date especially when it has a new role of a policy maker or a licensor as defined under section 2 (1)(ea) of TRAI Act,

10 who grants a license under section 4 of the Indian Telegraph Act, 1885? iv) Whether the Appellant (BSNL) in that verdict being a Govt. undertaking company has purposely concealed the fact about its true identity before the Hon ble Supreme Court and or misrepresented the status of a service provider and telegraph authority? If yes, then whether any penalty be imposed to them or not? If yes, to what extent? v) Whether the Hon ble Supreme Court has committed an error by that verdict as the complete provisions of TRAI Act, 1997 and the facts were not placed before it or were overlooked by it? If yes, whether the consumers who suffered due to that verdict are entitled to any relief, quantum and how? 5. GROUNDS & REASONS OF THIS APPEAL Whereas the views which were not explored and discussed in the above verdict by the Hon ble Supreme Court, inter alia, on the grounds as follows needs to be reviewed:

11 11 i. That the Hon ble Supreme Court verdict dated , an ex-parte order judgment does not discuss TRAI Act, 1997 anywhere while deciding the telecom dispute of an individual consumer, therefore, it cannot be said to be correct and not per incurium because of the amendments and empowerments given in latest telecom TRAI Act, 1997 itself, as explained below : That the Indian Telegraph Act, 1885, a preindependent act is amended from time to time to suit various advancement in telecommunication. Originally, the telecommunication was under the exclusive control of the Government and considering the global development business and the necessity of private parties also participating, the Telecom Regulatory Authority of India Act, 1997, a post-independent act, was enacted in the year 1997 in order to effectively control the advance telecommunication services without superseding the original telegraph act, 1885 and further eventually covering all those aspects which were not specifically covered in the 112 years old telegraph act at that time. The Telegraph Act, 1885 was not surely sufficient to cover all such advance telecommunication issues

12 12 specially the control of the licensee, hence, the TRAI Act, 1997 and other regulations came into existence. Now the meaning, expression & role of Telegraph Authority have been entirely changed. Telecom Regulatory Authority of India (TRAI) is the Telecom Authority or watchdog and Licensor is the Telegraph Authority or the Central Government. The Department of Telegraph has been separated from the earlier common Department of Post & Telegraph and the Government of India has further separated its policy wing (known as Department of Telecom) from operation wing (now named as Bharat Sanchar Nigam Limited - BSNL which operates as a public sector) and now a new chapter of Telecom Service Providers both private & Government as a service provider has been added and as per the latest statute, all complaints against any of the telecom service provider including Government as a service provider are to be decided as per TRAI Act, And further Telecom Consumers Protection and Redressal of Grievances Regulations 2007 is also another appropriate regulation made by TRAI for deciding the complaints against service providers. As per section 1(3) of Telecom

13 13 Consumers Protection & Redressal of Grievances Regulations, 2007, these regulations shall apply to all service providers including Bharat Sanchar Nigam Limited and Mahanagar Telephone Nigam Limited, being the companies registered under the Companies Act, 1956 providing basic telephone services, unified access services and cellular mobile telephone services. As per brief statement of objects and reasons of the TRAI Act, 1997, it can be implied that there is a felt need to separate regulatory functions from service providing functions which will be in keeping with the general trend in the world. In the multi-operator situation arising out of opening of basic as well as value added services in which private operator will be competing with Government operators, there is a pressing need for an independent telecom regulatory body for regulation of telecom services for orderly and healthy growth of telecommunication infrastructure apart from protection of consumer interest. In view of above, it was proposed to set up an independent Telecom Regulatory Authority as statutory body and for that purpose the Indian Telegraph (Amendment) Bill, 1995 was

14 14 introduced and then passed by Lok Sabha which is now known as TRAI Act, 1997 and further it was amended in 2000 which includes various new provisions made for establishment of a Tribunal known as the Telecom Disputes Settlement and Appellate Tribunal for adjudicating disputes between a licensor and a licensee, between two or more service providers, between a service provider and a group of consumers, and also to hear and dispose of any appeals from the direction, decision or order of the Authority. The section 14 of this TRAI Act, 1997 covers the disputes related to the service providers and further Proviso B of this section specially empowers that the complaint of an individual consumer is maintainable before Consumer Disputes Redressal Forum or a Consumer Disputes Redressal Commission or the National Consumer Redressal Commission established under section 9 of the consumer protection act, The old Telegraph Act, 1885 does not mention anywhere to adjudicate disputes in case of consumer complaints against service providers. However, an exception in the form of section 7-B covers limited jurisdiction to decide the case if the dispute between the

15 15 telegraph authority & a consumer arises for technical matters. Therefore, from the above it can be clearly implied that the telecom disputes are to be adjudicated under TRAI act, 1997 where the complaint is maintainable before the consumer fora in case of dispute between the licensee/service-provider and an individual consumer. It is also implied that the regulation of the licensee, not being a telegraph authority, comes under the TRAI act, 1997 and not directly under the telegraph act, Therefore, any order to adjudicate consumer dispute with any service provider cannot sustain if the telegraph act, 1885 is solely relied upon. ii. The Hon ble Supreme Court in the said order said it is well settled that special law overrides general law and considered Telegraph Act overrides Consumer Protection Act. Now if the same dictum is followed further, then, TRAI Act, 1997 supersedes by default the Telegraph Act, 1885 in the matters not covered in the original telegraph act because TRAI Act, 1997 is the purpose of the Indian Telegraph Act (Amendment) Bill, Further TRAI Act being

16 16 latest statute applicable in the telecom matters as per proviso (B) section 14 empowers that the complaint of an individual consumer is maintainable before Consumer Fora. So, ultimately Consumer Protection Act overrides the Telegraph Act & TRAI Act both as per the above special empowerment given in the TRAI Act, 1997 itself which is a special law. Therefore, by all means the views taken by the Hon'ble Supreme Court in the order dated are in itself contradictory in view of the latest amendment & empowerment given in the TRAI act which was not considered and discussed at that time. iii. Further if the relevancy of section 2 (1) (e, ea, j) {definition of licensee, licensor & service provider} & section 14 (Tribunal Jurisdiction) of the TRAI Act, 1997 along with section 3(6) {definition of Telegraph authority} of the Indian Telegraph Act, 1885, could have been discussed and explored in this ex-parte order of Hon ble Supreme Court titled GM, Telecom vs M. Krishnan, then, surely the decision and views of the Hon ble Supreme Court would have been different because the telegraph authority & licensee are two different entities under the act

17 17 and have different powers & functions. The Hon ble Supreme Court passed the verdict in a dispute between telegraph authority and the consumer but the Appellant (BSNL) in that case was not a telegraph authority as explained herein: As per TRAI Act, a new chapter of service providers as per section 2(1) (j) has been added which include Government as service provider and licensee. Further, as on date Director General of Telegraph including its all officers (of telegraph authority) does not provide any telephone connection to any of the consumers in the country. It is absolutely necessary here to mention that the appellant (BSNL) in that case concealed the very fact of its true identity before the Hon ble Supreme Court. If the BSNL in that case could not have concealed the material fact that the Government of India has separated policy wing from operation wing and this operation wing is now functioning w.e.f. 01 October, 2000 as BSNL as a service provider (not as a telegraph authority) which is the true identity of the appellant in the case on that date and today also, then, for sure the decision of the Supreme Court would have been different. The

18 18 history of BSNL is annexed as ANNEXURE P/4 (Page 56). The appellant (BSNL) in that case has purposely concealed the material fact before the Hon ble Supreme Court by not disclosing its true identity of Government as service provider under section 2(1) (j) of the TRAI Act, Further the BSNL was successful in posing him-self as a telegraph authority and took the advantage of his birth position as being separated from the telegraph authority. The fact that the BSNL got separation from the telegraph authority was not brought into the knowledge of the Hon'ble Supreme Court by the appellant (BSNL). Hence, the fact that the BSNL was not a telegraph authority remained a secret in that case at that time. And as on date, no service provider at their own because of their ulterior motive is revealing this truth. iv. Further, a plain reading of the above Hon ble Supreme Court order dated undoubtedly proves that the said dispute was between General Manager-Telecom (seems to be an officer on behalf of department of telecom being Telegraph Authority), appellant in the case and M. Krishnan, a consumer or otherwise, it is

19 19 specifically mentioned in the said order itself that if any dispute concerning any telegraph line, appliance or apparatus arises between the telegraph authority and the person for whose benefit the line, appliance or apparatus is, or has been provided, the dispute shall be determined by arbitration. Therefore, it implies that the dispute was between the telegraph authority and the consumer. However, the dispute in that case was not between telegraph authority and the consumer but the Hon ble Supreme Court assumed the dispute between telegraph authority and the consumer. Further, there is no possibility of deviating from the said ruling and the option available is straight to the point that in view of section 7B, the jurisdiction of consumer fora is ousted if any dispute arises between the telegraph authority and the consumer. In other words, all the contents of this ruling points towards the telegraph authority thereby leaving no room to deviate or to widen the scope of the telegraph authority. The definition of the telegraph authority has been well defined under section 3(6) of the Telegraph Act which does not include licensee or service provider at all. Whereas Central Government can grant a license

20 20 as per section 4(1) of the telegraph act but the licensee does not have the powers of the Telegraph Authority as per section 19B of the Telegraph Act and further control of the licensee or service provider comes under TRAI Act, 1997 as defined in the act itself. Therefore, any licensee cannot take the advantage of the powers of the Telegraph Authority unless the powers of Telegraph Authority are so vested to the licensee by the licensor or by the Central Government through notification. Thus, a single judgment cannot be taken for granted for all cases without proper discussion or for the simple reason that the dispute is related to telephone matters being similar in every case. v. That as and when arbitration is conducted under section 7B of Telegraph Act, 1885, the civil court s jurisdiction (including consumer fora) is barred. The view that the disputes with regard to the matters covered by section 7B should be adjudicated upon by the arbitrator is a view which is the right way of looking at the matter. This is because the arbitrator so appointed can properly appreciate the technical and non-technical matters. As to whether there is any defect in the

21 21 instrument or in the installation of the same, is a technical matter and can be more appropriately dealt with by the arbitrator. This technical knowhow may not be available with any other authority. Thus, it proves that Section 7B is applicable only for the matters of technical nature and surely not for non-technical matters such as administrative lapses in billing etc. And even further, the privilege of arbitrator under Section 7B for technical matters is exclusively enjoyed by the telegraph authority only and certainly not by any licensee or service provider. The Hon ble Supreme Court does not mention anywhere in the said order that the disputes between service provider and the consumer are to be decided under section 7B because the word service provider was beyond the imagination of that Telegraph Act at that time and even the word service provider is nowhere mentioned in the dictionary of 128 years old Telegraph Act. vi. That the Consumer Fora have failed to consider the detailed speaking and well reasoned orders which are much relevant in case of dispute between the service provider and a consumer. Further these orders have attained its finality and

22 22 are not purposely questioned by the service provider. In the order dated passed by Hon ble District Forum-Central Mumbai, it is clearly indicated that the Consumer Fora has jurisdiction to entertain telecom disputes and further the verdict of the Hon ble Supreme Court titled GM-Telecom vs M. Krishnan has been discussed properly and judiciously to prove that the same is not applicable when the dispute is between the consumer and the service provider. The copy of order of District Forum, Mumbai is annexed as ANNEXURE P/5 (page 57-67). Recently in the judgment of Delhi High Court decided on titled JK Mittal vs Union of India and Bharti Airtel Limited, it is clearly held that the impugned order dated passed by the State Commission, Delhi cannot be sustained, as it erroneously holds that the consumer complaint of the petitioner was barred by Section 7B of the Indian Telegraph Act. The copy of order of the High Court of Delhi is annexed as ANNEXURE P/6 (page 68-75). vii. That the Hon ble National Commission and various State Commissions are wrongly interpreting and blindly following the above

23 23 Hon ble Supreme Court order judgment dated The reason seems to be that the said order is open to two interpretations. The order states that dispute between the telegraph authority and the consumer can be resolved by arbitration. But the appellant in that case was not the telegraph authority. As on date in the country Department of Telecom (DOT) is the telegraph authority or the licensor which does not provide any telephone connection to any consumer in the country, however, earlier DOT was providing connections and now the onus of connections has been transferred to BSNL. The DOT is acting as the policy maker or licensor which means the Central Government or the Telegraph Authority who grants a license under section 4 of the Indian Telegraph Act, Therefore, any case between the consumer and the telegraph authority under section 3(6) of Telegraph Act or licensor under section 2(1)(ea) of TRAI Act is to be decided through arbitration as per section 7B of the Telegraph Act, 1885 which was reconfirmed in the latest amendment under Proviso C section 14 of the TRAI Act, But in reality, the appellant in that case who was successful in posing himself as a telegraph

24 24 authority before the Hon ble Supreme Court is a public limited company, BSNL and a service provider with undertaking of Government. And if it is a service provider, then, the consumer can surely file the complaint before Consumer Fora as per Proviso B section 14(a) of TRAI Act, Further, the Hon ble Supreme Court did not discuss or explore the complete identity of the BSNL. The telegraph authority (or licensor) and service provider (or licensee) both cannot exist into one authority because by default it is not possible that the licensor and licensee both are one and the same. These two identities of the appellant in that case are creating great confusion in the minds of all consumer courts in the country. Therefore, in this imbroglio, the consumer courts without applying their mind, keeping in view the dignity of the Supreme Court or otherwise knowingly/unknowingly or as a matter of law under article 141 of the constitution, are preferring to dismiss straightway the consumer complaints thus defeating the objects and reasons of the consumer protection act, Thus, as per the explanations and submissions given above, the following can be firmly concluded:

25 25 That the complaint of an individual consumer for all matters is very much maintainable before consumer fora if the dispute is between a consumer and licensee/service provider because Proviso B of section 14 of the TRAI Act, 1997 specifically empowers that complainant of an individual consumer is maintainable before Consumer Fora as per the Consumer Protection Act, That section 7B of Telegraph Act, 1885 does not undermine the right of an individual consumer to file the complaint before any of the civil courts & consumer fora in the country when the dispute is between the consumer and the licensee or any of the service providers including Government as a service provider. That section 7B as an exception does not bar the right of a consumer to approach any courts when the dispute between the consumer and the telegraph authority is related to non-technical matters because the telegraph authority has the privilege to invoke section 7B of the Telegraph Act only when the dispute arises concerning any telegraph line, appliance or apparatus etc. being

26 26 technical matter and certainly not for any administrative lapses or billing dispute etc. That TRAI Act, 1997 does not bar the rights of an individual consumer to approach the Civil Courts also for redressal of his grievances as the jurisdiction of the Telecom Disputes Settlement and Appellate Tribunal (TDSAT) established under this Act for this purpose is well defined under section 14 of this act. That BSNL is a service provider and not a telegraph authority. That any judgment passed solely relying upon Telegraph Act, 1885 cannot be sustained without referring the relevant and latest TRAI Act, 1997 in case of dispute between a consumer and the licensee/service provider. 6. PRAYER In view of the facts, circumstances & submissions made above, it is most respectfully prayed before the Hon ble Supreme Court : i) That pass an order to restore the rights of individual telecom consumers as per TRAI Act, 1997 and Consumer Protection Act, 1986 to approach any consumer court and or civil court.

27 27 ii) That the appeal for suo motu review of the order dated of Hon ble Apex Court may please be allowed and the matter be decided as early as possible because it involves the right of millions of needy telecom consumers in the country who are running from pillar to post to get redressal of their genuine grievances. iii) That vacate all order(s)/judgments of any court or consumer court which have been passed relying solely on the above order dated of the Hon ble Supreme Court titled GM Telecom vs M. Krishnan. iv) That pass necessary instructions to all courts and consumer fora to decide telecom disputes cases between the individual consumers and service providers within maximum three months. Such matters of phone connections should be given priority because such communication services among general public are essential now-a-days to run a normal life. v) That an exemplary order be passed against all those service providers who concealed this very fact of status/identity between licensee and licensor before various courts/forums and

28 28 betrayed millions of the common telecom consumers in the country. vi) That any other order/relief/direction may also kindly be passed in favour of telecom consumers as this Hon ble Supreme Court may deem fit, just and proper according to the facts and circumstances of the present appeal. I hope that your Excellencies would consider my appeal and suggestions just in the larger public interest, democratic values and also in the larger interest of the efficacy of the judiciary. With best regards, Yours sincerely, Ramesh Kumar Rohilla Address : , Bhanot Bhawan, Commercial Complex Azadpur, Delhi Phone : Place : Delhi. Dated : 17 th Oct., 2013.

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