How to draft a consumer complaint: structure and sample wording

A consumer complaint under section 35 of the Consumer Protection Act, 2019 is a numbered, dated story with proof: cause title, your details, facts, the ground (defect, deficiency or unfair trade practice), cause of action and limitation, jurisdiction, fee, a statement that no other case is pending, and a specific prayer, signed and supported by an affidavit and annexures. Plain language is enough. Every fact should point to a document.

The structure, part by part

1. Cause title. “Before the District Consumer Disputes Redressal Commission, [district]”. Then “Consumer Complaint No. ____ of [year]”. Below it, your name, age, occupation and address, then “Versus”, then each opposite party with its full legal name and registered or branch address.
2. Heading. “Complaint under Section 35 of the Consumer Protection Act, 2019.”
3. Introduction. Two or three lines on who you are and why you are a consumer: you bought the goods or hired the service for a price, for personal use or for livelihood by self-employment. This answers the “commercial purpose” objection before it is raised.
4. Facts. Numbered paragraphs in date order. One event per paragraph, with the annexure that proves it.
5. Grounds. Say which wrong applies: defect (s.2(10)), deficiency in service (s.2(11)), unfair trade practice (s.2(47)) or product liability (ss.82 to 87).
6. Cause of action and limitation. The date it arose, and a sentence that the complaint is within two years (s.69), or that an application to condone delay is attached.
7. Jurisdiction. Pecuniary: the price paid and the 2021 Rules. Territorial: the clause of s.34(2) you rely on.
8. Fee. Nil, or the amount paid under rule 7.
9. No other proceedings. That no complaint on the same facts is pending before any court, ombudsman or forum.
10. Prayer. Numbered reliefs.
11. Signature and verification with place and date.

Writing the facts so the bench follows you

Write as if you were explaining to a busy stranger. Use the sequence: purchase, promise, problem, complaints, refusal. A model paragraph:

4. That on 14 June 2026 the complainant’s refrigerator stopped cooling. The complainant lodged complaint no. [number] with the opposite party no. 2 on the same day. A copy of the confirmation message is Annexure C-3.

Do not copy long clauses from the agreement into the facts. Quote a clause only where it matters, in double quotation marks, and refer to its annexure. Avoid adjectives such as “shocking” or “fraudulent” unless the documents prove them. Keep the dates exactly as in your papers. A contradiction between your dates and your documents is the quickest way to lose credibility.

Add a one-page list of dates and events as a table. Busy benches love it, and later orders sometimes follow it almost line by line.

The prayer clause

A vague prayer such as “grant suitable relief” invites a vague order. Section 39(1) lets the Commission grant remedies such as refund, replacement, removal of defects, compensation and costs. Ask for what you want, in numbers:

1. Direct the opposite parties to refund ₹[amount] with interest at [rate]% per annum from [date] until payment.
2. Direct payment of ₹[amount] as compensation for mental agony and harassment.
3. Direct payment of ₹[amount] as costs of litigation.
4. Any other relief the Commission considers fit.

Keep the figures reasonable. The Commission decides the interest rate, and a moderate request is more persuasive. Remember that the forum is decided by the price paid and not by the sum you claim.

The affidavit

Because complaints are heard on affidavit and documents (s.38(6)), the affidavit matters. It is a sworn statement that the facts are true. A typical affidavit:

• carries the same cause title as the complaint;
• gives the deponent’s name, age, parentage or spouse’s name, and address;
• says the deponent is the complainant and knows the facts;
• confirms that the stated paragraphs are true to personal knowledge and that the annexures are true copies;
• ends with a verification clause with place and date; and
• is signed and attested by a Notary or Oath Commissioner, as local practice requires.

Never swear to anything you cannot support. A false affidavit can invite prosecution and will damage the whole case.

Supporting papers and annexures

• Index with page numbers.
• List of dates and events.
• Memo of parties with full names and addresses; notice goes to these.
• Annexures marked C-1, C-2 and so on, legible and in date order: invoice, payment proof, warranty, complaint emails, replies, notice and postal receipts.
• Applications if needed: condonation of delay (s.69(2)), interim relief (s.38(8)), permission to sue for several consumers (s.35(1)(c)).

On e-Jagriti you upload these as PDFs with size limits per file, so scan clearly and merge into sensible sets. For the portal steps, see the guide on filing on e-Jagriti. If you sent a notice first, attach it as described in the guide on the legal notice before a consumer complaint.

A short model of the opening pages

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION, [DISTRICT]

Consumer Complaint No. ____ of 2026

[Name], aged [age] years, [occupation], resident of [address] … Complainant
Versus
1. [Legal name of seller], [address]
2. [Legal name of manufacturer], [address] … Opposite Parties

Complaint under Section 35 of the Consumer Protection Act, 2019

1. The complainant is a consumer under section 2(7), having bought the goods for personal use for ₹[amount].

2. [Facts in numbered paragraphs, each with an annexure.]

10. The cause of action arose on [date], and the complaint is within two years under section 69.

11. The consideration paid is ₹[amount], so this Commission has pecuniary jurisdiction under the 2021 Rules, and territorial jurisdiction under section 34(2)(d). The fee is [nil or amount].

12. No other proceeding on the same facts is pending.

PRAYER … [as above]

Common drafting mistakes

• Not saying why you are a consumer.
• Naming the brand and not the legal entity.
• Annexures that cannot be read.
• Forgetting to sign the complaint, the affidavit or the verification.
• Claiming wild compensation without basis.
• Leaving out the limitation paragraph when the case is near two years.

Frequently asked questions

Do I need a lawyer to draft it?

No. You can draft and file yourself. A lawyer helps in complex or high-value cases.

Can I write the complaint in Hindi?

Many Commissions accept the local language, but practice varies, so check with the registry. Keep an English translation for higher forums.

Is an advance copy to the other side required?

Practice varies between Commissions. The Commission itself issues notice after admission. Sending an advance copy is a good habit, so ask the registry.

How long should the complaint be?

Short and clear. Often 4 to 8 pages plus annexures is enough for an ordinary refund case.

What if I miss a document?

You can seek permission to file additional documents, but the first set is the strongest. Collect everything before you file.

Quick quiz

Full course with model formats: Filing a Consumer Complaint, ₹199.

Sources

• Consumer Protection Act, 2019: ss.2(7), 2(10), 2(11), 2(47), 34(2), 35, 38(6), 38(8), 39(1), 69 and 82 to 87
• Consumer Protection (Consumer Disputes Redressal Commissions) Rules, 2020, rule 7 (fee)
• Consumer Protection (Jurisdiction of the District Commission, the State Commission and the National Commission) Rules, 2021

This page is for education and general information, not legal advice for a specific case. Law as on 7 November 2026. The sample is a model only; adapt it to your facts.