LEGAL NOTICE

(SPEED POST/ E-MAIL)

TO,

1. ICICI BANK LTD, ICICI BANK TOWERS,

BANDRA KURLA COMPLEX,
BANDRA (EAST), MUMBAI,
MAHARASHTRA,400051
2. ICICI LOMBARD GENERAL INSURANCE
COMPANY LIMITED,
ICICI LOMBARD HOUSE,
414, VEER SAVARKAR MARG,
NEAR SIDDHI VINAYAK TEMPLE,
PRABHADEVI,
MUMBAI -400025
3. ICICI PRUDENTIAL LIFE INSURANCE CO. LTD.
ICICI PRULIFE TOWERS,
1089 APPASAHEB MARATHE MARG,
PRBAHADEVI, MUMBAI-400025

SUBJECT: LEGAL NOTICE W.R.T FAILURE OF

REFUND AFTER PRE-PAYMENT OF THE HOME
LOAN INSURANCE

Sir/Madam,

Under instructions from and on behalf of my client, Sh.

Surender Kumar, R/o A-26 Surajmal Vihar, Delhi-
110092(hereinafter referred to as “my client”, who is also
acting as the legal representative of his brothers, namely,
Sh. Krishna Gopal and Sh. Baldev Raj(hereinafter referred
to as brothers), under the Special Power of Attorney, dated
____________, do hereby serve you with the following
notice, the contents of which are said forth here in the
below:-
1. That my client, along with his brothers, obtained a
home loan insurance policy bearing loan account
no.LBDEL00005245798 dated 24.02.2020 amounting
to Rs. 15,72,364/-( Fifteen Lakh seventy-two thousand
three hundred sixty-four only) for the coverage of the
home loan dated 26.12.2019 amounting to
Rs.4,66,00,000/-(Four Crores sixty-six lakhs only ).
The breakdown of the aforementioned amount is as
follows: -

A. ICICI BANK LTD. (hereinafter referred to as

Addressee 1)- Issued a Home loan bearing
account no. LBDEL00005198784 of
Rs.4,66,00,000/- to my client and his respective
family for the construction of the property.
B. ICICI LOMBARD GENERAL INSURANCE
COMPANY LIMITED (hereinafter referred
to as Addressee 2)- Issued a home loan
insurance policy for coverage of the
aforementioned home loan amounting to
Rs.7,31,453/- (Rupees seven lakh thirty-one
thousand four hundred fifty-three)
C. ICICI PRUDENTIAL LIFE INSURANCE
CO. LTD. (hereinafter referred to as
Addressee 3)- Issued a home loan insurance
policy for coverage of the aforementioned home
loan amounting to Rs.8,40,911/- (Rupees Eight
Lakh forty thousand nine hundred eleven)

2. That you, Addressee 1, misrepresented the entire

situation, concealed the material facts concerning the
home loan and asked my client, after the disbursement
of the home loan, to purchase a home loan insurance
policy by giving the ostensible reason that it is
necessary and it is fruitful for my client to cover his
home loan from its subsidiary insurance companies, i.e.
Addressee 2 and Addressee 3. It is pertinent to mention
that my client consented to the proposal given by Mrs
Anchal Jaggi, who was then the branch manager of
 ICICI Hargovind Enclave, Delhi-110092, which is
controlled/headed by you, the addressee 1. It is
pertinent to mention that my client was told by you, the
addressee 1 that my client would get back the refund
after a minor deduction was never intimated about the
requisites of the guidelines, which is itself in violation
of the principle of utmost good faith, consumer laws
and IRDAI guidelines.
3. That my client fully prepaid the home loan on
26.04.2021, thereby settling the outstanding amount
with Addressee 1. It is further submitted that the loan
for which the insurance coverage was taken has been
fully closed, and no further risk remains for the insurer
regarding this loan. It is pertinent to mention that NOC
dated 26.04.2021 was issued by you, the addressee 1.
4. That my client made the prepayment of the outstanding
amount of Rs. 15,27,000 against the respective share of
the Home Loan Insurance policy issued by Addressee 2
and 3 on 15.04.2021, which is 13 months from the
commencement of the policy dated 24.02.2020.
5. Given the prepayment and full settlement of the home
loan insurance policy, my client is entitled to a refund
of the unutilised portion of the premium paid towards
the insurance policy, as per the terms of the policy and
applicable guidelines issued by IRDAI. It is pertinent to
mention that the total amount of refund which was
made by Addressee 2 and 3 is Rs.6,24,022 out of the
total refund i.e Rs.15,27,000
6. My client made several reminders via email dated
22.01.2024,2.02.2024,9.02.2024 and even did branch
visits with you, the addressee 1, concerning the refund
but were never guided properly, nor were they provided
with the exact calculation/guidelines concerning how
the refund was made.
7. That you, the addressee 1, after several reminders,
made a refund amounting to Rs 27,852 after three years
of prepayment and annexed a policy calculation via
email dated 15.02.2024, which is inappropriate and
apprised methods of refund calculation to my client,
 which are incomplete and are not transparent and are
thus misleading in nature.
8. The failure to respond to my client’s grievances clearly
shows that you have indulged in gross violation of the
service rules, and unfair trade practices and your
services are deficient.
9. There has been no response from the end of the
aforementioned addressees on the issue elaborated
above, and neither is the amount credited, shocked at
the callous attitude of such a big banking and insurance
company, my client feels distraught and harassed.
10.That my client is entitled to know the full
process/calculation concerning the refund as per the
IRDAI guidelines and relevant consumer laws.
11.That by way of this notice you are hereby called upon
to pay our client:
a) A sum of Rupees 9,02,978 as the refund promised,
along with the interest @18% under the guidelines
of IRDAI.
b) A sum of rupees of Rs.50,000 towards the cost of
this legal notice rendered to our client.

That if there is no satisfactory response from your side within 15

days from the date of receipt of this notice, then it shall be
assumed that you are not interested in servicing the needs of my
client and we will be left with no option but to initiate
appropriate legal proceeding against you to safeguard the rights
of my client, and you shall be solely responsible for all the costs
and consequences thereof, which you may please note.

We hope for a prompt resolution to the abovementioned issue

and look forward to a positive response from your side.

A copy of this notice has been preserved in my office for record.