How to draft a consumer complaint using AI against healthcare fraud: Part 2 

In Part II of this guide, you will learn how AI can streamline healthcare fraud litigation, cutting consumer complaint drafting time from days to hours. Using a 5-step framework with real examples, it teaches lawyers to use tools like Claude.ai for structuring consumer complaints, ensuring compliance, and calculating damages. It includes ready prompts for fraud scenarios, checklists to balance AI and human input, and practical tips to boost accuracy and efficiency.

Introduction 

“Thank you, sir. Good afternoon, everyone. While Mr. Chatterjee has equipped you with the investigative skills to catch healthcare fraudsters, I am here to show you how to transform that evidence into winning complaints using artificial intelligence.

Three months ago, I was drowning in a complex case involving a Mumbai hospital that had billed Rs. 8 lakhs for fake cancer treatments. I had all the evidence: forged lab reports, phantom chemotherapy sessions, fabricated patient records. But drafting a comprehensive consumer complaint that covered all legal angles seemed impossible given our 48-hour deadline.

That is when I got to AI-assisted legal drafting. What would have taken me three days took three hours. More importantly, the AI helped me identify legal provisions I would have missed and structure arguments that ultimately secured Rs. 12 lakhs compensation for our client.

Today, I will walk you through the exact 5-step process we use in our practice. 

The 5-Step AI framework

I am going to demonstrate this with the help of Claud.ai, as it does an excellent job with litigation drafts. 

Responses of Claude.ai are marked in blue. 

Step 1: Set context and assign role

Give AI the basic context and assign it a specific role as your legal assistant.

Your opening prompt:

“Act as an experienced consumer protection lawyer specialising in healthcare fraud cases. I need to draft a consumer complaint before a consumer district commission under the Consumer Protection Act, 2019. Before I give you facts, help me build a checklist consisting of legal and factual pointers that are essential components of a sound complaint”. 

AI response:

Factual pointers

• Name, address, and details of the complainant
• Name and address of the hospital/doctor/lab (opposite party)
• Date and purpose of treatment or service
• What exactly was promised vs. what was delivered
• Medical reports, bills, and discharge summary (if any)
• How the fraud was discovered (e.g., inflated bill, fake diagnosis)
• Communication made with the hospital (emails, calls, notices)
• Current status (unresolved, denied refund, ongoing billing pressure)

Legal pointers

• Complainant qualifies as a ‘consumer’ under section 2(7)
• Allegation of deficiency in service under section 2(11)
• Allegation of unfair trade practice under section 2(47)
• Jurisdiction: Claim amount under 50 lakh → District Commission
• Relief sought: refund, compensation, litigation cost, interest
• Optional: request for interim relief (e.g., stay on further billing)

Once I have these details, I will draft a complaint following the Consumer Protection Rules, 2020 format.

Step 2: Answer AI’s questions comprehensively

Remember that this Q&A shall form the basis of your complaint, so respond to AI’s questions thoroughly. If you get this step right, trust me, drafting a complaint is a cake walk as it eliminates the risk of missing crucial facts.

Your response:

Factual pointers 

1. What is the name and address of the complainant?

The complainant is Mrs. Meena Joshi, a 58-year-old retired schoolteacher residing at Flat No. 202, Jasmine Towers, Andheri East, Mumbai – 400069.

2. Who is the opposite party, and what are their details?

The opposite party is Lotus Heartcare Hospital Pvt. Ltd., a private multi-speciality hospital located at 17, Station Road, Vile Parle (West), Mumbai – 400056. The hospital is represented by its Medical Director, Dr. Ravi Saxena.

3. When did the treatment take place and what was its purpose?

• On 14th February 2025, Mrs. Joshi visited Lotus Heartcare Hospital for a promotional “Comprehensive Cardiac Evaluation” (₹8,500) after mild chest discomfort during exertion.
• The package included ECG, 2D Echo, Stress Test, and AI-supported analysis, promised as a full-day, clinically validated screening.

4. What was promised vs. what was delivered?

• Promised: Accurate AI-assisted diagnostics with human clinical review, thorough consultation, and only medically justified treatment.
• Delivered: Based solely on an AI report showing 75% LAD blockage, Mrs. Joshi was rushed into angioplasty without proper verification or informed consent.
• Dr. Saxena spent barely 10 minutes before recommending emergency intervention, violating protocol and patient rights.

5. What documentary evidence supports the complaint?

• Diagnostic tests (ECG, Echo, Stress Test) from 14 Feb show normal results.
• AI report from “CardioScan Pro v2.1” flagged severe blockage—without validation.
• Procedure report dated 15 Feb confirms angioplasty and stent insertion.
• Second opinion dated 20 Feb by Dr. Anil Mehta confirms no blockage ever existed.
• Itemised bill of ₹3,45,000 including procedure, stent, hospital stay, and consumables.

6. How was the fraud discovered?

• Mrs. Joshi recovered unusually quickly, triggering doubts.
• Her daughter researched angioplasty outcomes and noticed discrepancies.
• Conflicting staff explanations and AI system secrecy raised red flags.
• Second angiogram on 20 Feb conclusively showed clear arteries, exposing the fraud.

7. What steps did the complainant take?

• 21 Feb: Emailed hospital citing second opinion; sought explanation.
• 23 Feb: Sent follow-up demanding full refund and correction of records.
• 22 Feb: Hospital responded defensively, denying error.
• 26 Feb: Legal notice served through an advocate.

8. What is the current status of the dispute?

• The Dispute remains unresolved.
• 2 March: Hospital’s reply rejected refund, discredited second opinion, and continued post-op billing.
• Threatened to report her for non-compliance with the insurers.
• Refused to disclose AI algorithm specifications, citing proprietary rights.
• Mrs. Joshi is still paying off a loan for the unnecessary procedure and is facing emotional and financial distress.

Legal pointers

9. Does the complainant qualify as a consumer under the Act?
   Yes. Under section 2(7) of the Consumer Protection Act 2019, Mrs. Joshi qualifies as a consumer because she paid for healthcare services.
10. What legal violations are being alleged?
    
    The hospital’s conduct constitutes:

1. Deficiency in service under section 2(11):  

• Negligent diagnosis: Relied solely on an unverified AI-generated report without clinical correlation, human medical interpretation, or confirmatory testing, violating accepted cardiac care standards.
• Unwarranted procedure: Recommended and conducted a major invasive angioplasty based on a single diagnostic input, without confirmatory evidence through alternative methods, contrary to established medical protocols.
• Lack of informed consent: Failed to disclose the limitations of AI diagnosis, risks of angioplasty, and availability of less invasive alternatives, thereby depriving Mrs. Joshi of her right to make an informed decision.
• Post-discovery misconduct: Refused to acknowledge medical error, denied remedial action, and continued billing for the unnecessary procedure, indicating ongoing deficiency and ethical failure.

2. Unfair trade practice under section 2(47) for relying solely on AI diagnostics and misleading the patient into undergoing an unnecessary procedure: 

• Misleading advertising: Promoted their AI diagnostic system with exaggerated claims like “99.7% accuracy” and “revolutionary cardiac care” without scientific backing, validation data, or disclaimers.
• False representation of capabilities: Created unrealistic expectations by misrepresenting AI diagnosis as superior to conventional medical evaluation.
• Deceptive diagnostic practice: Treated AI-generated reports as conclusive diagnoses without human verification or clinical correlation, exploiting patient trust and medical knowledge gaps.
• Inducing false medical urgency: Pressured Mrs. Joshi into consenting to an invasive and expensive procedure by creating a false sense of emergency, denying her the chance to seek second opinions.
• Suppression of patient autonomy: Used complex medical jargon and institutional authority to discourage questions and withhold transparent explanations, thereby preventing informed healthcare decisions.

11. Is the complaint within the correct jurisdiction?
    Yes. The total claim value, including refund, compensation, and litigation costs, is under Rs. 50 lakh plus the cause of action has also arisen in Mumbai; therefore, the District Consumer Disputes Redressal Commission, Mumbai Suburban, possesses both territorial and pecuniary jurisdiction to adjudicate Mrs. Joshi’s complaint. 
12. What relief is being sought?

• Refund of Rs. 3,45,000 billed for the unnecessary procedure
• Compensation of Rs. 1,50,000 for mental trauma and medical harm
• Litigation cost of Rs. 1,00,000

Step 3: Specify format and structure requirements

Provide AI with the exact format required for consumer complaints.

Your Prompt:

“Draft the consumer complaint using this specific format:

HEADER: 

– Case number line (to be filled by forum)

– Proper addressing to the District Consumer Forum

PARTIES:

– Complainant details with complete address

– Versus

– Respondent details (all three respondents with addresses)

MAIN SECTIONS:

1. Facts in chronological order with dates

2. Limitation

3. Jurisdiction justification

4. Prayer for relief (specific amounts)

5. Verification clause

6. List of annexures

Draft a comprehensive complaint explaining each allegation thoroughly. Use formal legal language, but ensure that it is easy to understand. Include relevant case law citations for healthcare fraud. Follow Consumer Protection Rules, 2020 formatting requirements.”

AI response:

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION AT BANDRA, MUMBAI 

COMPLAINT NO. _______ OF 2024

MRS. MEENA JOSHI
Aged 58 years, Retired School Teacher
Flat No. 202, Jasmine Towers,
Andheri East, Mumbai – 400069
Mobile: +91-9876543210
Email: [email protected]
…COMPLAINANT

VERSUS

1. LOTUS HEARTCARE HOSPITAL PVT. LTD.
   Through its Medical Director, Dr. Ravi Saxena
   17, Station Road, Vile Parle (West),
   Mumbai – 400056
   CIN: U85110MH2018PTC123456
   …RESPONDENT NO. 1
   
2. DR. RAVI SAXENA
   Medical Director & Cardiologist
   Maharashtra Medical Council Reg. No. MMC/2008/CARDIO/1247
   C/o Lotus Heartcare Hospital Pvt. Ltd.
   17, Station Road, Vile Parle (West),
   Mumbai – 400056
   …RESPONDENT NO. 2
   
3. CARDIOSCAN PRO TECHNOLOGIES PVT. LTD.
   AI Diagnostic System Provider
   Tech Tower, Bandra Kurla Complex,
   Mumbai – 400051
   (Technology partner for AI diagnostic system)
   …RESPONDENT NO. 3

TO
THE HONOURABLE PRESIDENT AND MEMBERS
DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION
MUMBAI SUBURBAN

The above-named Complainant most respectfully submits this complaint under section 35 of the Consumer Protection Act  2019, against the above-named Respondents for deficiency in service, unfair trade practice, and medical negligence resulting in financial fraud and mental harassment.

1. FACTS OF THE CASE

1. The Complainant, Mrs. Meena Joshi, is a 58-year-old retired school teacher who served the Maharashtra State Education Department with distinction for 35 years before taking voluntary retirement in 2023. She currently resides at Flat No. 202, Jasmine Towers, Andheri East, Mumbai, and receives a monthly pension of ₹45,000. The Complainant has no prior history of major cardiac ailments and maintains an active lifestyle post-retirement.
2. During the last week of January 2025, the Complainant began experiencing mild, intermittent chest discomfort, particularly during physical activities such as climbing stairs or brisk walking. These symptoms, while concerning, were non-specific and not accompanied by other classical cardiac symptoms like severe breathlessness, profuse sweating, or radiating pain.
3. That on 8th February 2025, the Complainant consulted her family physician, Dr. Suresh Patil, who examined her and found her vital signs to be normal. Dr. Patil recommended a cardiac screening as a precautionary measure, given the Complainant’s age and symptoms, and suggested that she undergo a comprehensive cardiac evaluation at a reputable hospital.
4. During the first week of February 2025, Respondent No. 1 launched an aggressive marketing campaign advertising their “Revolutionary AI-Powered Cardiac Screening” through local newspapers, social media platforms, and pamphlets distributed in residential areas of Mumbai. The marketing materials prominently featured claims of “99.7% AI accuracy,” “Instant AI Reports,” and “Preventive Care Excellence,” specifically targeting senior citizens with promotional pricing.
5. That influenced by the marketing campaign and the modern facilities advertised, the Complainant decided to avail herself of the “Comprehensive Cardiac Package” offered by Respondent No. 1 at a promotional price of ₹8,500 (reduced from ₹12,000). The package promised ECG, 2D Echocardiogram, Stress Test, and AI-assisted diagnostic analysis, all to be completed within a single day.
6. That on 14th February 2025, the Complainant visited Respondent No. 1’s hospital at 9:30 AM for her scheduled cardiac screening. At 9:45 AM, an ECG was performed by technician Mr. Rahul Sharma, showing normal cardiac rhythm and electrical activity. At 10:15 AM, a 2D Echocardiogram was conducted by cardiac technologist Ms. Priya Singh, revealing normal heart function with adequate ejection fraction. At 10:45 AM, the Stress Test was completed successfully without any symptoms or abnormal findings. At 11:30 AM, the hospital’s AI system, identified as “CardioScan Pro v2.1” (provided by Respondent No. 3), processed the diagnostic data.
7. That at approximately 12:00 PM on 14th February 2025, the AI system generated a report flagging a supposed “75% blockage in the Left Anterior Descending (LAD) artery” despite all conventional diagnostic tests showing normal results. The AI report was presented with computer-generated images and technical data that appeared convincing but lacked proper medical validation or clinical correlation.
8. That Respondent No. 2, Dr. Ravi Saxena, spent barely ten minutes reviewing the AI report before immediately recommending emergency angioplasty. Dr. Saxena created an atmosphere of medical urgency by stating that delay could result in a “massive heart attack” and that the AI system was “more accurate than traditional diagnostic methods.” The Complainant was pressured into immediate consent without adequate time for consideration, a second opinion, or alternative diagnostic approaches.
9. Under psychological pressure and medical authority, the Complainant consented to the angioplasty procedure, which was performed on 15th February 2025 at 2:30 PM by Respondent No. 2. A drug-eluting stent was inserted during a 45-minute procedure, and the Complainant was kept under observation for 24 hours. The entire treatment was completed without the Complainant being adequately informed about AI system limitations, procedural risks, or alternative diagnostic options.
10. That upon discharge on 16th February 2025, the Complainant was presented with an itemised bill totalling ₹3,45,000, comprising diagnostic package (₹8,500), angioplasty procedure (₹1,85,000), stent (₹85,000), hospital charges (₹37,000), medicines (₹15,000), and other associated costs. The hospital insisted on full payment before releasing medical records, forcing the Complainant to arrange funds through her savings (₹2,00,000) and a personal loan (₹1,45,000).
11. That within 48 hours post-procedure, the Complainant felt completely normal and experienced none of the symptoms that had originally prompted her hospital visit. This rapid recovery, inconsistent with someone who had allegedly suffered from a 75% cardiac blockage, raised serious doubts about the accuracy of the diagnosis.
12. That on 20th February 2025, the Complainant consulted Dr. Anil Mehta, Senior Interventional Cardiologist at Sushrut Cardiology Institute, for an independent second opinion. Dr. Mehta conducted a comprehensive evaluation, including a fresh angiogram with contrast studies, which conclusively revealed no arterial blockage in any coronary vessel. Dr. Mehta’s report dated 20th February 2025 clearly stated that the inserted stent was “medically unnecessary” and that the original AI diagnosis was “fundamentally flawed and potentially fabricated.”
13. That following the discovery of fraud, the Complainant initiated communication with Respondents on 21st February 2025 through first email to hospital administration requesting explanation for diagnostic discrepancy, followed by email on 23rd February 2025 demanding full refund and removal of false diagnosis from medical records, and legal notice served through advocate on 26th February 2025 providing final opportunity for settlement.
14. That Respondent No. 1’s response dated 22nd February 2025 was defensive and evasive, denying wrongdoing while claiming the AI system was “internationally validated.” The formal response to the legal notice dated 2nd March 2025 refused a refund and attempted to discredit the second opinion. Most disturbingly, Respondents continue sending billing reminders for post-operative services and threatening to report “non-compliance” with post-surgical care, causing additional mental harassment.

B. LEGAL VIOLATIONS

Deficiency in Service under section 2(11) of the Consumer Protection Act, 2019

The conduct of Respondents constitutes a clear “deficiency in service” as defined under Section 2(11) of the Act, which includes any fault, imperfection, shortcoming, or inadequacy in the quality, nature, and manner of performance. The deficiency manifests in:

(a) Fundamental diagnostic failure by relying solely on unverified AI report without proper clinical correlation or confirmatory testing (b) Breach of medical protocols by recommending major invasive procedure based on single diagnostic tool without seeking alternative verification (c) Failure in informed consent by not adequately explaining AI system limitations, procedural risks, or alternative diagnostic options (d) Post-discovery misconduct including refusal to acknowledge clear evidence of error and continued billing for unnecessary services

The Respondents’ conduct falls far below the standard expected from qualified medical professionals and accredited healthcare institutions, as established in Indian Medical Association v. V.P. Shantha (1995) 6 SCC 651.

Unfair Trade Practice under Section 2(47) of the Consumer Protection Act, 2019

That Respondents engaged in “unfair trade practice” as defined under Section 2(47) through:

(a) Misleading advertising by promoting AI diagnostic system with claims of “99.7% accuracy” without supporting scientific validation (b) Deceptive service provision by presenting AI-generated reports as definitive medical diagnoses without adequate human verification (c) False urgency creation to pressure immediate consent for expensive procedure without allowing time for second opinions (d) Information exploitation by using technical terminology and institutional authority to suppress patient questioning

Such practices constitute clear violations as established in Poonam Verma v. Ashwin Patel (1996) 4 SCC 332 and Jacob Mathew v. State of Punjab (2005) 6 SCC 1.

Medical negligence

That Respondent No. 2’s conduct constitutes medical negligence under the Bolam Test as applied in Dr. Laxman Balkrishna Joshi v. Dr. Trimbak Bapu Godbole (1969) SCR (1) 206, failing to exercise the degree of skill and care expected from a qualified cardiologist in similar circumstances.

C. EVIDENCE AVAILABLE

The Complainant relies upon the following documentary evidence:

Medical Records

• Hospital admission form dated 14th February 2025 with consent signatures
• Complete diagnostic reports showing normal ECG, Echo, and Stress Test results
• AI system printout claiming 75% LAD blockage
• Angioplasty procedure notes and images from 15th February 2025
• Discharge summary and post-operative instructions

3.2 Second Opinion Documentation

• Dr. Anil Mehta’s comprehensive report dated 20th February 2025
• Fresh angiographic studies proving the absence of any arterial blockage
• Comparative analysis confirming the unnecessary nature of stent insertion

3.3 Financial Documentation

• Itemised bill totalling ₹3,45,000 with detailed breakdown
• Payment receipts and bank statements
• Personal loan documentation arranged for payment

3.4 Communication Records

• Email correspondence with the hospital dated 21st and 23rd February 2025
• Hospital’s denial response dated 22nd February 2025
• Legal notice dated 26th February 2025 and the hospital’s reply dated 2nd March 2025
• Ongoing billing reminders and harassment communications

2. LIMITATION

This complaint is filed well within the limitation period prescribed under Section 69 of the Consumer Protection Act, 2019, which allows two years from the date when the cause of action arose. The complaint is being filed within the stipulated time frame and is therefore maintainable.

3. JURISDICTION

Territorial Jurisdiction

That this Honourable Commission has territorial jurisdiction as: (a) The Complainant resides within the Mumbai Suburban district, (b) Respondent No. 1 and 2 operate within the Mumbai Suburban district, (c) The cause of action arose within the territorial limits of this Commission

Pecuniary Jurisdiction

That this Honourable Commission has pecuniary jurisdiction as the total claim value of ₹5,20,000 (comprising refund of ₹3,45,000, compensation of ₹1,50,000, and costs of ₹25,000) falls within the District Commission’s limit of ₹1 crore as specified under Section 34(1) of the Consumer Protection Act, 2019.

Subject Matter Jurisdiction

The complaint relates to a deficiency in service and unfair trade practice in healthcare services, falling squarely within this Commission’s jurisdiction under Section 34 of the Act.

4. PRAYER

In the light of the facts and circumstances stated above, the Complainant most respectfully prays that this Honourable Commission may be pleased to:

Primary Relief

(a) Direct Respondent No. 1 to refund Rs. 3,45,000 being the total amount paid for the medically unnecessary angioplasty procedure, stent insertion, and associated charges under Section 34(1)(a) of the Act;

(b) Award compensation of Rs. 1,50,000 to the Complainant for mental agony, physical trauma, and financial hardship caused by the unnecessary medical intervention under Section 34(1)(b) of the Act;

(c) Award litigation costs of Rs. 1,00,000 including legal fees, expert consultation charges, and incidental expenses under Section 34(1)(f) of the Act;

Additional Relief

(d) Direct payment of interest on the refund amount from 15th February 2025 until actual payment at the rate prescribed under the Act;

(e) Order removal of the fraudulent AI diagnosis from the Complainant’s permanent medical records maintained by Respondent No. 1;

(f) Direct Respondent No. 1 to cease all billing and recovery actions related to the unnecessary procedure;

Interim Relief

(g) Grant interim relief staying all further billing and recovery actions by Respondents pending final adjudication;

(h) Direct preservation of all medical records, AI system data, and diagnostic reports to prevent evidence tampering;

General Relief

(i) Award such other relief as this Honourable Commission may deem fit and proper in the circumstances of the case;

(j) Award costs of the proceedings to the Complainant.

VERIFICATION

I, Mrs. Meena Joshi, the Complainant above-named, do hereby solemnly affirm and declare that the contents of the above complaint are true and correct to the best of my knowledge and belief, and nothing material has been concealed therefrom. The allegations made in paragraphs 1.1 to 1.14 are based on my personal knowledge and are true. The allegations made regarding legal violations are based on legal advice received and are true to the best of my knowledge and belief.

Place: Mumbai
Date: ___________

DEPONENT
(MRS. MEENA JOSHI)

Identified by:
Advocate Name
Bar Council Registration No.
Address

LIST OF ANNEXURES

Annexure	Description
A-1	Hospital admission form dated 14th February 2025
A-2	ECG report dated 14th February 2025
A-3	2D Echocardiogram report dated 14th February 2025
A-4	Stress Test report dated 14th February 2025
A-5	AI diagnostic report showing an alleged 75% blockage
A-6	Angioplasty procedure notes dated 15th February 2025
A-7	Discharge summary dated 16th February 2025
A-8	Itemised bill totalling Rs. 3,45,000
A-9	Payment receipts and bank statements
A-10	Personal loan documentation
A-11	Dr. Anil Mehta’s second opinion report dated 20th February 2025
A-12	Fresh angiographic studies from Sushrut Cardiology Institute
A-13	Email to hospital dated 21st February 2025
A-14	Follow-up email dated 23rd February 2025
A-15	Hospital’s response dated 22nd February 2025
A-16	Legal notice dated 26th February 2025
A-17	Hospital’s reply to legal notice dated 2nd March 2025
A-18	Ongoing billing reminders and notices
A-19	Copy of Complainant’s Aadhaar Card
A-20	Copy of the hospital’s incorporation certificate

FILED BY:

[ADVOCATE NAME]
Advocate for Complainant
Bar Council Registration No. [NUMBER]
Chamber Address: [ADDRESS]
Mobile: [NUMBER]
Email: [EMAIL]

Step 4: Refine through specific enhancement prompts

Yes, I know you did not call for that draft, but here is where you tailor the draft as per your requirements. Use multiple specific prompts. Whatever you would expect from your junior colleague, blurt it out in your prompts one by one. 

Enhancement prompt 1 

“Retain the existing structure. Remove the separate section titled ‘Legal Violations’, but ensure that facts within the remaining sections are modified or strengthened to clearly imply or reflect the applicable legal violations (such as deficiency in service, unfair trade practice, lack of informed consent, etc.) through the narrative itself. The legal breaches should be embedded in the factual narration, not stated separately. Avoid duplicating content, and maintain a professional, fact-driven tone.”

Enhancement prompt 2 – Evidence

“Retaining the structure of the complaint, remove the section on ‘Evidence’. 

Enhancement prompt 3 – Damage calculation:

“Retain all substantive elements of the prayer clause, but compress similar or related reliefs into a single consolidated point wherever possible. Remove separate headings for each prayer and present the entire prayer clause as a concise, numbered list of reliefs sought. Ensure clarity, avoid repetition, and maintain a formal and persuasive tone suitable for a consumer complaint.”

Enhancement prompt 4 – Annexures 

“Integrate references to each Exhibit directly within the relevant sections of the FAQ so that whenever a factual point is made (e.g., the incorrect medical report, second opinion, or itemised bill), it is immediately followed by a reference such as ‘refer to Exhibit [X]’. Use the term Exhibit instead of Annexure throughout. Additionally, remove the exhibits relating to (i) Personal Loan Documentation, (ii) the Complainant’s Aadhar Card, and (iii) the Hospital’s Registration Certificate from the list entirely, and ensure they are not mentioned in the text or index.”

In literally 4 steps, you have a great base draft to work on. Needless to say, you will have to proofread, apply your mind and make changes manually. The changes are marked in red. 

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION

MUMBAI SUBURBAN DISTRICT

MRS. MEENA JOSHI
Aged 58 years, Retired School Teacher
Flat No. 202, Jasmine Towers,
Andheri East, Mumbai – 400069
Mobile: +91-9876543210

VERSUS

COMPLAINT UNDER SECTION 35 OF 

THE CONSUMER PROTECTION ACT, 2019

TO
THE HONOURABLE PRESIDENT AND MEMBERS
DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION
MUMBAI SUBURBAN

The above-named Complainant most respectfully submits this complaint under Section 35 of the Consumer Protection Act, 2019, against the above-named Respondents for deficiency in service, unfair trade practice, and medical negligence resulting in financial fraud and mental harassment.

MAY IT PLEASE YOUR HONOUR

The Complaint craves leave of this Hon’ble Commission to file a complaint against the 

1. PRELIMINARY

1. The Complainant, Mrs. Meena Joshi, has referred the instant complaint u/s. 35(1) of the Consumer Protection Act, 2019 (“the Act”) against the Opposite Parties above named. 
2. The Complaint submits that she is a Consumer within the meaning, definition and scope of section 2(7) of the Act. 
3. By way of present Complaint, the Complainant inter alia alleges that the Opposite Parties are guilty of “Deficiency in Services” and “Unfair Trade Practice” within the meaning definition and scope of section 2(11) and 2(47), respectively. The Complainant, through her present complaint is seeking refedressal of her consumer dispute, amongst other reliefs against the Opposite Parties from this Hon’ble Court. 

2.  FACTS OF THE CASE

1. The Complainant, Mrs. Meena Joshi, is a 58-year-old retired school teacher, currently residing at Flat No. 202, Jasmine Towers, Andheri East, Mumbai. It is pertinent to mention here that the Complainant has no prior history of major cardiac ailments and maintains an active lifestyle post-retirement.
2. During the last week of January 2025, the Complainant began experiencing mild, intermittent chest discomfort, particularly during physical activities such as climbing stairs or brisk walking. These symptoms, while concerning, were non-specific and not accompanied by other classical cardiac symptoms like severe breathlessness, profuse sweating, or radiating pain.
3. That on 8th February 2025, the Complainant consulted her family physician, Dr. Suresh Patil, who examined her and found her vital signs to be normal. Dr. Patil recommended a cardiac screening as a precautionary measure, given the Complainant’s age and symptoms, and suggested that she undergo a comprehensive cardiac evaluation at a reputable hospital.
4. During the first week of February 2025, Respondent No. 1 launched an aggressive and misleading marketing campaign advertising their “Revolutionary AI-Powered Cardiac Screening” through local newspapers, social media platforms, and pamphlets distributed in residential areas of Mumbai. The marketing materials prominently featured unsubstantiated claims of “99.7% AI accuracy,” “Instant AI Reports,” and “Preventive Care Excellence,” specifically targeting vulnerable senior citizens with promotional pricing, without providing any scientific validation or disclaimers about AI system limitations. A copy of the hospital marketing materials claiming “99.7% AI accuracy” is annexed hereto and marked as Exhibit A-1.
5. That influenced by these deceptive marketing representations and the modern facilities advertised, the Complainant decided to avail herself of the “Comprehensive Cardiac Package” offered by Respondent No. 1 at a promotional price of Rs. 8,500 (reduced from Rs. 12,000). The package promised ECG, 2D Echocardiogram, Stress Test, and AI-assisted diagnostic analysis, all to be completed within a single day, with assurances of comprehensive medical evaluation and proper clinical correlation.
6. That on 14th February 2025, the Complainant visited Respondent No. 1’s hospital at 9:30 AM for her scheduled cardiac screening. A copy of the hospital admission form dated 14th February 2025 is hereto annexed and marked as Exhibit A-2. At 9:45 AM, an ECG was performed by technician Mr. Rahul Sharma, showing a completely normal cardiac rhythm and electrical activity (refer to Exhibit A-3). A copy of the ECG report dated 14th February 2025 is annexed hereto and marked as Exhibit-A-3. At 10:15 AM, a 2D Echocardiogram was conducted by cardiac technologist Ms. Priya Singh, revealing entirely normal heart function with adequate ejection fraction (refer to Exhibit A-4). At 10:45 AM, the Stress Test was completed successfully without any symptoms or abnormal findings (refer to Exhibit A-5). At 11:30 AM, the hospital’s AI system, identified as “CardioScan Pro v2.1” (provided by Respondent No. 3), processed the diagnostic data without proper human oversight or verification protocols. A copy of the 2D Echocardiogram report dated 14th February 2025 and Stress Test report dated 14th February 2025 are hereto annexed and marked as Exhibits A-4 and A-5, respectively. 
7. That at approximately 12:00 PM on 14th February 2025, the AI system generated a completely erroneous report flagging a supposed “75% blockage in the Left Anterior Descending (LAD) artery” despite all conventional diagnostic tests showing perfectly normal results. The AI report was presented with computer-generated images and technical data that appeared convincing but lacked any proper medical validation, clinical correlation, or verification by qualified medical professionals, representing a fundamental breach of medical diagnostic standards.  A copy of the AI diagnostic report showing an alleged 75% blockage is hereto attached and marked as Exhibit A-6.
8. That Respondent No. 2, Dr. Ravi Saxena, failed to exercise the degree of skill and care expected from a qualified cardiologist by spending barely ten minutes reviewing the AI report before immediately recommending emergency angioplasty without seeking confirmatory tests or second opinions. Dr. Saxena created an artificial atmosphere of medical urgency by stating that delay could result in a “massive heart attack” and that the AI system was “more accurate than traditional diagnostic methods,” thereby pressuring the Complainant into immediate consent without providing adequate time for consideration, consultation with family, or alternative diagnostic approaches, constituting a clear violation of informed consent principles.
9. That under psychological pressure and medical authority, and without being provided complete information about AI system limitations, procedural risks, alternative diagnostic options, or the experimental nature of AI-based diagnosis, the Complainant consented to the angioplasty procedure, which was performed on 15th February 2025 at 2:30 PM by Respondent No. 2. A drug-eluting stent was inserted during a 45-minute procedure, and the Complainant was kept under observation for 24 hours, representing a completely unnecessary medical intervention that violated accepted standards of cardiac care. A copy of the Angioplasty procedure notes dated 15th February 2025 is hereto annexed and marked as Exhibit A-7.
10. That upon discharge on 16th February 2025, the Complainant was presented with an itemized bill totaling Rs. 3,45,000, comprising diagnostic package (Rs. 8,500), angioplasty procedure (Rs. 1,85,000), stent (Rs. 85,000), hospital charges (Rs. 37,000), medicines (Rs. 15,000), and other associated costs for services that were medically unnecessary and fraudulently induced (refer to Exhibit A-8). The hospital insisted on full payment before releasing medical records, forcing the Complainant to arrange funds through her life savings (Rs. 2,00,000) and borrowing (Rs. 1,45,000), causing severe financial hardship (refer to Exhibit A-9). A copy of the itemised bill totalling Rs. 3,45,000 and payment receipts and bank statements are hereto annexed and marked as Exhibit A-8 and A-9. 
11. That within 48 hours post-procedure, the Complainant felt completely normal and experienced none of the symptoms that had originally prompted her hospital visit. This rapid recovery, entirely inconsistent with someone who had allegedly suffered from a 75% cardiac blockage requiring emergency intervention, raised serious doubts about the accuracy and authenticity of the diagnosis, clearly indicating the fraudulent nature of the entire treatment.
12. That on 20th February 2025, the Complainant consulted Dr. Anil Mehta, Senior Interventional Cardiologist at Sushrut Cardiology Institute, for an independent second opinion. Dr. Mehta conducted a comprehensive evaluation, including a fresh angiogram with contrast studies, which conclusively revealed no arterial blockage whatsoever in any coronary vessel. Dr. Mehta’s detailed report dated 20th February 2025 categorically stated that the inserted stent was “medically unnecessary” and that the original AI diagnosis was “fundamentally flawed and potentially fabricated,” thereby establishing the fraudulent and negligent nature of Respondents’ conduct (refer to Exhibit A-10). The comparative angiographic studies clearly demonstrate the absence of any blockage, proving the false nature of the original AI diagnosis (refer to Exhibit A-11). A copy of Dr. Anil Mehta’s second opinion report dated 20th February 2025 and fresh angiographic studies from Sushrut Cardiology Institute are hereto annexed and marked as Exhibit A-10 and Exhibit A-11, respectively. 
13. That following the discovery of this medical fraud, the Complainant initiated good faith communication with Respondents seeking amicable resolution, including email on 21st February 2025 to hospital administration requesting explanation for the diagnostic discrepancy (a copy of the email is hereto annexed and marked as refer to Exhibit A-12), followed by email on 23rd February 2025 demanding full refund and removal of false diagnosis from medical records (a copy of the email is hereto annexed and marked as refer to Exhibit A-13), and legal notice served through advocate on 26th February 2025 providing final opportunity for settlement (a copy of the legal notice dated 26th February 2025 is hereto annexed and marked as Exhibit A-15), all of which were either ignored or inadequately addressed.
14. That Respondent No. 1’s response via email dated 22nd February 2025 was defensive and evasive, denying any wrongdoing while claiming their AI system was “internationally validated” without providing supporting documentation (a copy of the hospital’s response via email is hereto annexed and marked as Exhibit A-14). The formal response to the legal notice dated 2nd March 2025 refused a refund and attempted to discredit the independent second opinion by claiming it was “commercially motivated” (a copy of the hospital’s response to the legal notice is hereto annexed and marked as Exhibit A-16). Most disturbingly, Respondents continue their harassment by sending billing reminders for post-operative services related to the unnecessary procedure and threatening to report “non-compliance” with post-surgical care protocol, causing ongoing mental trauma and financial pressure (copies of bills as on the date of filing of this complaint is hereto annexed and marked as Exhibit A-17), demonstrating their complete lack of acknowledgment of the medical fraud perpetrated and their continued attempts to extract money for services stemming from fraudulent diagnosis.

3. TERRITORIAL JURISDICTION

That this Honourable Commission has territorial jurisdiction as the Complainant resides within the Mumbai Suburban district, Respondent Nos. 1 and 2 operate within the Mumbai Suburban district, and the cause of action arose within the territorial limits of this Commission. 

4. PECUNIARY JURISDICTION

This Honourable Commission has pecuniary jurisdiction as the total claim value of Rs. 5,95,000 (comprising refund of Rs. 3,45,000, compensation of Rs. 1,50,000, and costs of Rs. 1,00,000) falls within the District Commission’s. 

5. LIMITATION

The cause of action arose on 15th February 2025 when the unnecessary angioplasty was performed based on a fraudulent AI diagnosis, and continued to accrue through 20th February 2025 when the fraud was definitively established through a second opinion. The Complaint is therefore well within the limitation period as prescribed under the Act. and remains ongoing due to the Respondents’ continued denial and harassment. This complaint is filed well within the limitation period prescribed under Section 69 of the Consumer Protection Act, 2019, which allows two years from the date when the cause of action arose.

6. The Complainant has not filed any complaint before any other Court/Commission or authority in respect of the above cause of action against the Opposite Parties. 
7. The Complainant has paid the requisite court fees on this Complaint. 
8. The Complainant craves leave to refer to and rely upon the documents annexed hereto and further craves leave to file additional documents/s in support of their contentions, if required, with the permission of this Hon’ble Commission. 
9. The Complainant crave leave to add, alter, amend any or all of the foregoing paragraphs; if and when found necessary, with the permission of this Hon’ble Commission. 
10. PRAYERS

The Complainant therefore prays that given the foregoing paragraphs, it would be just and proper and further in the interest of justice that this Hon’ble Commission be pleased to grant the following reliefs: In the light of the facts and circumstances stated above, the Complainant most respectfully prays that this Honourable Commission may be pleased to:

1. To allow the Complaint and to hold and declare that the Opposite Parties are guilty of “Deficiency in service” and “unfair trade practices” within the scope, meaning and definition of the Act. 

1. Direct the Opposite Parties to jointly and severally pay to the Complainant to refund Rs. 3,45,000 being the total amount paid for the angioplasty procedure, stent insertion, and associated charges, along with interest from 15th February 2025 until actual payment at the rate prescribed under the Act.
2. Award compensation. Direct the opposite parties to jointly and severally pay of  Rs. 1,50,000 to the Complainant for mental agony, physical trauma, and financial hardship caused due medical intervention and ongoing harassment.
3. To grant Award litigation costs of Rs. 1,00,000, including legal fees, expert consultation charges, and incidental expenses necessarily incurred in pursuing this complaint.
4. Direct removal of the fraudulent AI diagnosis from the Complainant’s permanent medical records maintained by Respondent No. 1 and cessation of all billing and recovery actions related to the unnecessary procedure.
5. Grant interim relief, staying all further billing and recovery actions by Respondents pending final adjudication and direct preservation of all medical records, AI system data, and diagnostic reports to prevent evidence tampering.
6. Award Grant such other relief as this Honourable Commission may deem fit and proper in the circumstances of the case. , along with costs of the proceedings to the Complainant.

VERIFICATION

I, Mrs. Meena Joshi, the Complainant above-named, do hereby solemnly affirm and declare that the contents of the above complaint are true and correct to the best of my knowledge and belief, and nothing material has been concealed therefrom. The allegations made in paragraphs 1 to 14 are based on my personal knowledge and are true. The allegations made regarding legal violations are based on legal advice received and are true to the best of my knowledge and belief.

Place: Mumbai
Date: ___________

DEPONENT
(MRS. MEENA JOSHI)

Identified by:
Advocate Name
Bar Council Registration No.
Address

LIST OF EXHIBITS

A-1: Hospital marketing materials claiming “99.7% AI accuracy”

A-2: Hospital admission form dated 14th February 2025

A-3: ECG report dated 14th February 2025

A-4: 2D Echocardiogram report dated 14th February 2025

A-5: Stress Test report dated 14th February 2025

A-6: AI diagnostic report showing an alleged 75% blockage

A-7: Angioplasty procedure notes dated 15th February 2025

A-8: Itemised bill totalling Rs. 3,45,000

A-9: Payment receipts and bank statements

A-10: Dr. Anil Mehta’s second opinion report dated 20th February 2025

A-11: Fresh angiographic studies from Sushrut Cardiology Institute

A-12: Email to hospital dated 21st February 2025

A-13: Follow-up email dated 23rd February 2025

A-14: Hospital’s response dated 22nd February 2025

A-15: Legal notice dated 26th February 2025

A-16: Hospital’s reply to legal notice dated 2nd March 2025

A-17: Ongoing billing reminders and notices

Did you guys see something? The factual core of this draft remained almost entirely intact, and there were no major corrections required. Only a few refinements and standard legal clauses were added to enhance the structure and completeness of the document. 

Importantly, the draft also generated a comprehensive checklist of all the necessary exhibits to be annexed, ensuring that the complaint is both factually sound and procedurally ready for filing.

Step 5: Final review and compliance check

Perform a comprehensive final review for accuracy and compliance.

Final review prompt:

“Conduct a final compliance review of this consumer complaint and check: procedural compliance, legal accuracy, drafting quality, missing elements, if any”.

Pro tips for drafting with the help of AI 

Ready-to-use prompts for different healthcare fraud scenarios

For unnecessary surgery:

“Act as a consumer protection lawyer. Draft a complaint for unnecessary surgery fraud: Client underwent appendectomy later confirmed as medically unnecessary by an independent expert, charged Rs. 3 lakhs, suffered complications. Ask me questions to gather complete details for the Consumer Protection Act complaint.”

For insurance billing fraud:

“Act as an expert in insurance fraud litigation. Help me draft a consumer complaint where the hospital billed insurance Rs. 6 lakhs for treatments the patient never received while abroad. Insurance was wrongfully paid. I need a comprehensive complaint under CPA 2019 with criminal law violations.”

For medical equipment fraud:

“Act as a healthcare fraud specialist lawyer. Draft consumer complaint for medical device fraud: Patient sold unnecessary cardiac pacemaker for Rs. 8 lakhs, second opinion revealed no cardiac issues requiring the device. Need a complaint covering medical negligence and commercial fraud.”

Conclusion 

“So there you have it,” Shanaya said, closing her laptop with a satisfied smile. “What used to take me three days now takes three focused hours, thanks to this 5-step AI framework. But remember, and I cannot stress this enough, AI is your research assistant, not your replacement. It is brilliant at organising facts, ensuring we don’t miss procedural requirements, and structuring arguments, but you still need to verify every case citation, double-check medical facts, and ensure your damage calculations are realistic.”

“The future belongs to lawyers who can dance with AI, not those who fear it or blindly trust it,” she concluded, gathering her notes. “Master this hybrid approach, and you will deliver comprehensive, compelling advocacy for healthcare fraud victims faster than ever before. But never forget, behind every winning complaint is our judgment, not just smart technology. Questions?”

FAQs

1. Can AI really draft a complete consumer complaint in 3 hours?

Yes, but with caveats. AI can generate a structured, legally compliant draft in 2-3 hours that would traditionally take 2-3 days. However, you will still need 3-4 hours for fact verification, case citation checks, and medical accuracy review. The real time-saver is in organisation, formatting, and ensuring no procedural requirements are missed.

2. What if the AI cites fake case laws in my complaint?

This is a real risk. AI can generate convincing but fictitious case citations. Always verify every case law mentioned, check the citation format, confirm the case exists in legal databases, and ensure the legal principle is accurately stated. 

3. Can I use AI-generated complaints directly in court without editing?

Absolutely not. AI drafts require mandatory human review for: factual accuracy, medical terminology verification, local forum compliance, realistic damage assessment, and case law validation. Think of AI as your first draft writer, not your final editor.

4. What evidence is most crucial in healthcare fraud cases?

The “holy trinity” is: (1) Original medical reports showing normal results, (2) a Second opinion from a reputable doctor contradicting the first diagnosis, and (3) Financial documentation showing the money trail. These three pieces typically make or break your case; everything else is supporting evidence.

5. How do I handle hospitals that refuse to provide medical records?

Under the Consumer Protection Act, you can seek interim relief directing record preservation and production. Include this in your prayer for relief. Hospitals legally cannot withhold records once treatment is complete and bills are paid. Document all refusal communications as evidence of non-cooperation.

6. Should I include the AI diagnostic company as a separate respondent?

Yes, especially in AI diagnostic fraud cases. The technology provider can be held liable for faulty algorithms, inadequate validation, or misleading accuracy claims. This creates multiple liability sources and strengthens your case. Include them as a separate respondent with specific allegations about their AI system’s deficiencies.