Questionnaires by HDFC ERGO in CC-353-2022

I received the Questionnaires from HDFC ERGO on the 10th of July 2024 and replied to them on the 12th of July 2024.

I had to submit two documents on 12 July 2024. One of them is “Objection and Response to OP HDFC ERGO 10 July 2024 Petition under the provision of the Consumer Protection Act praying for rejection of the present complaint on the grounds mentioned below.” of case CC-354-2022. Another one is “Reply to HDFC ERGO by Ratul Aich, on Written questionnaires put to Complainant as Cross Examination on behalf of the Opposite Party above named.” of case CC-353-2022.

At the time of the hearing on 10th July 2024. I’ve been instructed by the President to submit the notarized copy of the document.

I thought the “Objection and Response to OP HDFC ERGO 10 July 2024 Petition under the provision of the Consumer Protection Act praying for rejection of the present complaint on the grounds mentioned below.” of the case, CC-354-2022 needs to be notarized.

However, on the 12th of July, it was clarified to me at approximately 4:20 PM that on the 10th of July 2024, I had rather been instructed to submit the notarized copy of the “Reply to HDFC ERGO by Ratul Aich, on Written questionnaires put to Complainant as Cross Examination on behalf of the Opposite Party above named.” of case CC-353-2022.

So I rushed to the Session Court of Barasat. Get the document notarized and returned to the DCDRC at approximately 5:29 PM only to find it closed. Therefore, I took some photos of the closed gates. The next day, I sent the documents by registry post RW780882399IN.

Written questionnaires put to Complainant as Cross Examination on behalf of the Opposite Party above named received on 10th of July 2024.

The questionnaires have been converted from hard copy to soft copy using Optical Character Recognition.

District- North 24 Parganas
Before the District Consumer Disputes Redressal Commision at Barasat

C.C. №353/2022

Ratul Aich
……….Petitioner/Claimant

Vs.

HDFC ERGO General Insurance Co. Ltd.
……….Opposite Party

Written questionnaires put to Complainant as Cross Examination on behalf of the Opposite Party above named

1. Whether you received the Policy Kit containing Policy Copy along with term & conditions of Your Optima Restore Individual Policy bearing №110103/11119/AA01265980 for the period 30/11/2019 to 29/11/2020 from this O.P. Insurance Company? Please answer in yes or no.
2. Whether You renewed the said Policy from this O.P. Insurance Company voluntarily? Please answer in yes or no.
3. Whether you received the said renewed Policy Kit containing Policy Copy along with term & conditions of Your Optima Restore Individual Policy bearing №2805 2035 5354 0501000 for the period 30/11/2020 to 29/11/2021 from this O.P. Insurance Company? Please answer in yes or no.
4. Whether you verify and examine the benefits, terms and conditions mentioned in the Policy Bond? Please answer in yes or no.
5. Whether You ever contacted/approached the O.P. Insurance Company regarding any information given in the documents contained within the Policy Kit was incorrect, incomprehensible or unacceptable to You within the free look up period i.e. 15 days from the receipt of the said Policy document? Please answer in yes or no.
6. Whether You lodged complain before the Insurance Ombudsman at West Bengal on 22/02/2022 in respect of repudiation of Helth Check up claim & Denial of discount on policy for steps covered? Please answer in yes or no.
7. Whether the Insurance Ombudsman in the Award dated 17/05/2022upheld that the decision of this O.P. Insurance Company was in order, in respect of your aforesaid both allegations? Please answer in yes or no.
8. Whether the said Insurance Ombudsman in the said Award dated 17/05/2022, held that since the complainant has failed to prove the completion of required parameter for getting the discount, the denial of discount on policy renewal is in order? Please answer in yes or no.
9. Whether in Your petition of complaint before this Ld. Commission mentioned the aforesaid Complaint before the Insurance Ombudsman at West Bengal dated 22/02/2022 and also the said Award dated 17/05/2022 of the said Insurance Ombudsman? Please answer in yes or no.
10. I suggest that you are well aware about the completion of required parameter for getting the discount in the Policy renewal.
11. I suggest you that you have failed to completion of required parameter for getting the discount in the Policy renewal as you had completed around 3433 steps against a minimum step count of 5000.
12. I suggest you that there arises no deficiency on the Part of this O.P. Insurance Company for allowing discount on policy for steps covered.
13. I suggest you that the present complaint filed by you is entirely vague, false, vexatious and frivolous without any merits and the same ought to be dismissed with cost.
14. I further state that you that there is no deficiency in service on the part of this Opposite Party and You are not entitled to relief/s as prayed for.
15. I further suggest you that you have deposed totally falsely for the purpose of this case.

Replied to Questionnaires by the Complainant Ratul Aich.

District — North 24 Parganas
Before the District Consumer Disputes Redressal Commission at Barasat

CC/353/2022

Ratul Aich
Petitioner/Claimant

HDFC ERGO General Insurance Co. Ltd.
Opposite Party

Reply to HDFC ERGO by Ratul Aich, on Written questionnaires put to Complainant as Cross Examination on behalf of the Opposite Party above named.

Stay Active Discount of a maximum of up to 8% not received during the 29 Nov 2021 renewal.

1. Yes
2. Yes
3. Yes
4. Yes
5. No
6. Yes
7. Yes
8. Yes
9. I don’t remember w.r.t CC/353/2022. I’ve submitted the Ombudsman Documents in CC/354/2022 because HDFC ERGO lied to the Insurance Ombudsman. Contention of the Respondent, Complaint №1: Repudiation of Health Checkup Claim, point (vi).
10. Yes
11. Data Missing from HDFC ERGO System. Data partially calculated. The yearly data was properly tracked and registered in the Google Fit Application of Plaintiff Ratul Aich Mobile. HDFC ERGO app was properly installed in Ratul Aich Mobile. The Data is retrieved from the Google Fit app by the HDFC ERGO app. The data retrieval process is faulty. HDFC ERGO Software Testing (QC, QA) and Usability Testing are deficient. Various checkpoints were not created by the Dev Team, Quality Assurance, and Quality Control team to check the health of an installed signed-in app, resulting in such failure.
12. Disagree Objected.
    (a) Dark Pattern,
    (i) Ministry of Consumer Affairs, Food & Public Distribution. PIB Release ID 1936432. Heading — Department of Consumer Affairs urges online platforms to refrain from adopting ‘dark patterns’ harming consumer interest. Point 4 (ix) Hidden Costs. The stay active step counts quarterly data and subsequent quarterly discount, and total step counts and subsequent total discount are not visible in the checkout flow of renewal.
    (ii) Point 4 (vii) Interface Interference. UX Red Route Compromised. UX User Flow Compromised. I’ll explain it through an Anology (presumed story). Say HDFC ERGO has a district office in North 24 Parganas. Assume that all the sales activities are mailed to home by post. Assume that to find the answer to address any query of the insuree, they have to visit the HDFC ERGO district office. Assume to file for reimbursement and receive the amount the insuree has to visit Mumbai Head Office.
    In a similar manner, most of the sales transactions and Q&A are taken up online through the HDFC ERGO web or mobile app interface. But when it comes to discounts, the insuree is expected to email a few days before the renewal, such that the team can calculate and reply over email. This is time-consuming and a deliberate hindrance (speed breaker), created to reduce the number of insuree approaching for 8% discount to HDFC ERGO. 8% in Optima Restore policy, which is one of the highest selling policies of Apollo Munich/HDFC ERGO has a huge customer base. 8% yearly profit is a huge amount for a company. That amount could be used to manage competition. Therefore, class action, at scale investigation demanded, and if required Competition Commission of India involvement is prayed. I year later in Oct-Nov 2022 nothing improved (no UX improved), email conversation was submitted already.
    (b) HDFC ERGO Customer Care Executive lied on Official Communication.
    from: Care@HDFCERGO <care@hdfcergo.com>
    reply-to: care@hdfcergo.com
    to: ratul aich <ratulaich@gmail.com>
    date: Dec 3, 2021, 5:14 PM
    subject: RE:’Service ID=050–097–286'[EXT] Re: Discount on policy renewal for steps covered
    mailed-by: hdfcergo.com
    signed-by: hdfcergo.com
    Dear Ratul,
    Greetings from HDFC ERGO General Insurance.
    With reference to your e-mail dated 3rd December 2021 regarding stay active discount under policy number 2805203553540501.
    Kindly accept our sincere apologies, for the inconvenience caused to you.
    We wish to inform you that, as per update received form the concern unit that under policy number 2805203553540501 stay active discount was not applicable in policy period of 2020 to 2021.
    Wishing you good health and happiness!
    Thanks and Regards,
    Bittu Kumar Shah
13. Denied and objected.
14. Denied and objected.
15. Denied and objected.

CC/353/2022 brief. QR Code. https://rat9.medium.com/judicial-investigation-friendly-digital-systems-judibility-b121000a2280

An Important Email was Sent to DCDRC Barasat on 13 July 2024.

from: ratul aich <ratulaich@gmail.com>
to: confo-pn-wb@nic.in
date: Jul 13, 2024, 12:57 PM
subject: Replying to HDFC ERGO Questionnaire notarized copy CC-353–2022 sent by registry post
mailed-by: gmail.com

CC/353/2022.

Replying to questionnaire by OP HDFC ERGO.

The Hon’ble President DCDRC, Barasat asked me to submit a notarised copy of the document on 12 July 2024. However, when I returned at around 5:30 p.m. the court has closed, therefore sending the document by registry post.

DCDRC, Barasat, North 24 Parganas Copy sent by registry post RW780882399IN.

Regards,
Ratul Aich

First in the series is Judicial Investigation Friendly Digital Systems, Judibility. (Link)

Previous in the series is Letter to NCDRC GOI to Use Digital Softcopies, RTI NCDRC-R-E-22–00281. (Link)

Next in the series is, Misrepresentation in DCDRC’s Order, Heckled and Humiliated by Court Official. (Link)