1. Complainant is a company registered under the provisions of Companies Act, 1956. The Opposite Party is Insurance Company, dealing with various type of Insurances, including fire Insurance.

2. The Complainant deals in manufacturing, processing packaging and storage of frozen Indian breads, frozen snacks, ready to cook / bake food, ambient staple ready to eat meals, ready to cook sauces, pastes and condiments. Almost all products manufactured by the Complainant are exported. The Complainant has two units (i) for production of ready to eat products (hereinafter referred to as "Unit - 1") and (ii) for manufacturing and stocking of frozen food products (hereinafter referred to as "Unit - 2").

3. The Complainant took Standard Fire & Special Perils Policy No. 220001115P103526547 for Rs.6 crores, later enhanced to Rs.7 crores. The Policy covered the risk of loss of goods, stock and material in the factory due to fire. The Policy was renewed from time to time.