Ola electric - Promises given by sales manager and sales man not full filled

That the Complainant, {SAGAR DNYANESHWAR DHAVLE}, had purchased an electric scooter (OET-***************-JID***) from the Opponent, {OLA Electric Technologies Private Limited, ANDHERI WEST MUMBAI}, on **st March **** with the assurance provided by the sales manager and salesman (MR.KALPESH SATARE) of the delivery being made by *th April ****. Despite multiple follow-ups by the Complainant and reassurances given by the Opponent's staff, the Complainant was informed on *th April ****, a day prior to the promised delivery date by manager Mr. YOGESH, that the delivery would not be made as assured. This action by the Opponent constitutes not only a breach of verbal agreement and trust but also amounts to deficiency in service and an unfair trade practice under the Consumer Protection Act, ****.
 
**LIST OF DATES**
 
****st March ****:** Date of purchase of the electric scooter by the Complainant from the Opponent.
 
**Between **st March **** to *th April ****:** Complainant had made numerous follow-ups to ensure the on-time delivery as promised by the Opponent’s sales manager and salesman.
 
***th April ****:** Complainant was informed by the Opponent that the delivery would not be made as promised.
 
***th April ****:** The promised delivery date on which the Complainant was supposed to receive the electric scooter.
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**GROUNDS**
 
*. Because the Opponent, through their sales manager and salesman, had explicitly assured the Complainant of the delivery of the electric scooter on *th April ****, which constitutes a verbal contract.
*. Because the Opponent's action of not fulfilling the promised delivery date, despite multiple assurances, amounts to deficiency in service as defined under Section *(*)(g) of the Consumer Protection Act, ****.
 
*. Because the Opponent's failure to deliver the scooter as per the committed date, even after acknowledging the official delivery was to be on **th March **** but assuring a different delivery timeline to the Complainant, constitutes an unfair trade practice under Section *(*)(r) of the Consumer Protection Act, ****.
 
*. Because the mental agony and harassment faced by the Complainant due to the uncertainty and the Opponent's last-minute notification of delay in delivery, warrant compensation under the Consumer Protection Act, ****.