On 02,June 2011 I purchased a Volkswagen Jetta 2.0 trendline car bearing Registration number UK07AK7979, Chassis number WVWK101K8AA554565 and Engine number CLC023302 from VOLKSWAGEN HALDWANI, the authorize dealer of Volkswagen India Private Ltd. That about 7-8 months of the purchase of the said vehicle I found that the color of the wheel (Alloy) to the right side is fading and black spot are appearing in the same. That I immediately complained the issue to the Service Manager, Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) orally and asked them to change the wheel (alloy) under warranty. That Service Manager, Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) informed me that for clamming warranty they have to report the matter to higher authorities and any action for change of the wheel (alloy) under warranty shall be communicated after receiving necessary instruction from the higher authorities. That Service Manager, Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) also took the photographs of wheel (alloy). That however a few days after I was telephonically informed by the Service Manager, Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) that they cannot replace the wheel (alloy) under warranty but they can paint the wheel (alloy) for free of cost under warranty. That I believing in good faith that Volkswagen India is a reputed concern and may not cheat me agreed to paint the wheel (alloy). That unfortunately after a few months thereafter I observed that there was a problem in vehicle steering wheel whenever the vehicle was being driven at a normal speed of 60-70 km/hr and the vehicle was waving and shaking and there was danger of accident. That I thought that the vehicle is waving and shaking because either vehicles wheel alignment is not proper or vehicles wheels are not properly balanced. So for wheel alignment and wheel balancing I went to a garage. But when vehicle was checked I was shocked to know that all the four wheels (Alloy) are damaged and they were deformed and vehicle was not capable of being plied on the road and may endanger the life of myself and the public in the road. That on same day i.e. 29/08/2012 I registered insurance claim and got the claim number OC-13-1307-1801-00000142 from the Insurance Company. That my vehicle was inspected by the surveyor on 30/08/2012 at Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd). That on 1/9/2012, I got an e-mail from insurance company that the wheel rims cannot get deformed in a single event when there is no other apparent visible accidental damage to any other part and this can only lead to normal wear and tear and same does not fall under the purview of insurance contract. That I contacted service manager of Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) and told him the reply of Insurance Company and requested orally to the service manager of Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) to change the alloys under warranty. The service manager took the photographs of deformed wheels (alloys) and e-mailed the matter to higher authority for approval. That I sent several email to Volkswagen India and Volkswagen Haldwani (Maa Sheetla Autowheels Pvt Ltd) about the issue but I did not got any response. That on 05/09/2012 I got an e-mail from Mr Abhishek Yadav, Service Manager, Volkswagen Haldwani, (Maa Sheetla Autowheels Pvt Ltd) that after long discussion with VW team they came in conclusion that it is an external impact case & hence the same cannot be covered under warranty. That it is patently wrong and illegal because the vehicle has run only about 15000 kms approx and had there not been any manufacturing defect there was no question of wheels (alloys) being bend. That on 06/09/2012 I got a e-mail from Abhishek Yadav, Service Manager, Volkswagen, Haldwani stating as below Dear Sir, This has reference to your Jetta vehicle with Regn number UK07AK7979 & further to your complaint number VWH2947 addressed to Volkswagen. We would like to inform you that all the wheel rims in your vehicle are bent. This has happened due to external impact & not due to any manufacturing defect. External impact cases are not covered under warranty as per Volkswagen warranty terms & conditions. Thanks with Regards Abhishek Yadav Service Manager. Volkswagen Haldwani

That the said vehicle remained standing in the Garage of my client for a period of one month. That however on repeated complains the company agreed to replace the four alloy wheels on the payment of Rs. 25000=00 (i.e. which of represented to the cost of one alloy wheel). That since I did not want to indulge into unnecessary litigation he accepted the offer of the company to replace the all four alloy wheels on the payment of Rs. 25000=00. That it is unfortunate that only after a journey of nearly 7000.00 K.M., after the alloy wheels were replaced, they have again deformed and the vehicle is again standing in the garage and is not capable of plying on the road. That it is patently wrong that the alloy wheels have been deformed due to any external impact and the same cannot be covered under the warranty. It is made clear that had there been not a manufacturing defect in the vehicle there was no question of deforming alloy wheels in ordinary driving. The vehicle never meet any accidents such the question of deforming all the alloy wheels within a short span of time That if it not been a manufacturing defect in the wheel (alloys) then the vehicle would not have been to Volkswagen Haldwani, (Maa Sheetla Autowheels Pvt Ltd) three times for the wheel (alloy) problem only in a short period of time since its purchase. That it is cleared from the above facts that there is some manufacturing defect in the vehicle and unless the vehicle is changed, it is not capable of being plied on the road. That at the time of purchase of the said car the dealer represented to me that Volkswagen Jetta is one of the best cars and if any defect is detected the same will be repaired free of cost within the warranty period. That it is clear there is a manufacturing defect in the car otherwise there was not occasion to deform all the wheels (alloys) when the car has only taken the journey of nearly 15000 kms. That it is also clear that Volkswagen falsely represented me to purchase the said car knowingly that there is a manufacturing defect in the same and had I known that the company will not remove the defect free of cost under warranty, I would have never purchased the said car. That the said vehicle is standing and is not capable of plying on road and may endanger the life if used. That on account of the facts that the car cannot be plied in the road I am suffering great mental and financial agony.