1.      Heard Mr. B.V.S. Halapathi Rao, Advocate, for the complainant and Mr. Ravi Bakshi, Advocate, for the opposite party.

2.      M/s. Padmaja Laboratories Private Limited (the Insured) has filed above complaint, for directing United India Insurance Company Limited (the Insurer) to pay Rs.9999999/- with interest @18% per annum from 27.07.2011 till the date of payment, towards balance insurance claim, punitive damages and any other relief, which is deemed fit and proper in the facts and circumstances of the case.

3.      The complainant stated that M/s. Padmaja Laboratories Private Limited (the Insured) was a company, registered under the Companies Act, 1956 and engaged in manufacturing and supplying the veterinary and poultry medicines and feed supplements. The Insured had Factory Licence of 10968 and Registration No.66481, Drug Control Licence No.30/AP/KR/96/F/CC and VAT Registration and TIN No.28810865472. The Insured took  factory premises at Plot No. 158/4, D. No.2-134 & 135, Industrial Area, Chinnoutapalli Post, Gannavaram Mandalam, Krishna district, on lease, vide lease deed dated 01.08.2011, for manufacturing and storing raw material and final products. United India Insurance Company Limited (the Insurer) was a public insurance company and used to provide different insurance services to the public. The Insured obtained “Standard Fire And Special Perils Policy” No.151003/11/11/11/00000151 from United India Insurance Company Limited (the Insurer), for the period of 19.05.2011 to 18.05.2012, for a sum insured of Rs.2.5/- crores (i.e. Rs.50/- lakhs on Plant & Machinery, Rs. 1.7/- crores on raw materials, Rs.10/- lakhs on Stock in Process and Rs.20/- lakhs on Finished Goods, including packaging materials), stored at factory premises. The Insured had credit facility from State Bank of Hyderabad, MSME branch, Vijayawada and assets and stocks were hypothecated.

4.      Major fire broke out at the factory premises of the Insured in morning of 27.07.2011. Nagaraju, Supervisor of Security Guard on duty informed the Managing Director, on telephone that smoke was emanating from the ventilators at first floor of the Feed Block building. The Security Guards and other staff tried to douse the fire but its spread soon and became out of control. They immediately informed Fire Service Station, at Gannavaram and Hanuman Junction, from where, fire tenders were deputed on the spot, who could control the fire in 3:20 hours. The Insured informed the fire incident to the local police station on 28.07.2011, where it was registered as FIR No.191 of 2011. The Insured informed the Insurer on telephone on 27.07.2011 about the fire incident at its factory premises as the loss. The Insurer appointed M. Purnachadra Rao, Surveyors & Loss Assessors, Guntur, as the surveyor on 27.07.2011, who visited the spot on 28.07.2011, 01.08.2011 and on subsequent dates, inspected the factory premises and took photographs. He noted that (i) Feed Block building, 1^st & 2^nd floors were affected with the fire. (ii) The machinery installed therein were burnt/charred. (iii) Electrical wiring, installation and fittings were gutted. (iv) Raw materials stored in th