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Role Of NCDCR In Consumer Welfare: Landmark Judgements

National Consumer Disputes Redressal Commission abbreviated as NCDRC was a commission set up under C0nsumer Pr0tection Act 1986 in the year 1988. The head office of NCDRC is situated in New Delhi. The Consumer Protection Act 1986 targets at providing fast and cheap protection for any complaints of the consumers related to acquisitions from markets and conduct meted out to them by the shop keepers.

The act visibly identifies the rights a consumer has in market against duplicitous trade practices of traders and thus forms the maxim "Caveat Emptor" (let the buyer beware). COPRA makes it obligatory to establish a dispute resolution mechanism at the center and state level.

At the Central Level, it is supervised by the Minister in-charge for consumer affairs and at the State Level; it is regulated by the Minister in-charge for consumer affairs. It has established a three-tier dispute resolution mechanism, the District Forum, the State Commission and the National Commission. [1] NCDRC is a quasi-judicial commission in India.

The District Forum comprises of a Prėsident and tw0 other members, 0ne 0f which ought be a female. A grievance can be filed in the District Forum if the worth of the good does not surpass Rs. 20 Lakh. After the complaint is filed, the article is sent for testing to the laboratory and on the footing of the report from the laboratory a verdict is made. If the complainant is not contended with the decision made by the District Forum, then he can pertain to the State C0mmissi0n within a peri0d of 30 Days. Likewise, State Commission involves a President and not fewer than two other members one of which shall be a female.

A complaint can be filed to the State Commission when the value of the goods in interrogation exceeds Rs. 20 Lakh but is less than 1 crore. After receiving the complaint, the Commission passes an order based on the result of the laboratory and if the complainant is not satiated with the order then he can apply t0 the National C0mmission within 30 Days of the 0rder. St�te C0mmission also, has to look after complaints approved on from the District Forum.[2]

The National Commission was recognized in 1988 and involves a President who should be a judge of the Supreme Court and more than two other affiliates, one of which shall be a woman. A grievance is filed in the National Commission when the price of goods and services in question surpasses Rs.1 crore.

The decision is made based on the results of the laboratory test and if the litigant is not placated with the decision, then an appeal in the Supreme Court of India can be filed within 30 days of the order. National Commission also, has to look after the complaints carried onward from the State Commission. Currently, the National Commission is headed by Justice R.K. Agrawal and is known as National Consumer Disputes Redressal Commission (NCDRC).

The main aim of NCDRC is to provide quick and economical redressal to the grievances of the consumers from partial trade practices carried out in the market place and for this NCDRC has a set of standards required to be followed by every dealer and if one does not follow them, then the dealer might have to face severe penalties.

In order to demonstrate this, the NCDRC has essentially taken certain steps toward the assistance of consumer. Certain judgements were passed involving the major issues and they proved to be landmark cases in consumer redressal for the future. Some of the landmark cases in the field of consumer welfare are deliberated below[3].

Research Objectives:
  1. To understand the Dispute Redressal Mechanism as given under COPRA.
  2. To study the effects of the redressal mechanism in the daily lives of both the consumer as well as the seller.
  3. To study the various landmark cases under NCDRC and know whether they had any change in the consumer-seller relationship.
  4. To study whether the changes brought out after the landmark cases proved to be negative or positive.
  5. To understand whether the seller actually follows the rules given under COPRA and doesn't fool the consumers.
Research Methodology:
For the purpose of research, the researcher went to the website of National Consumer Dispute Redressal Commission to know what the commission is all about and also took assistance from the Consumer Protection Act of 1986 to understand the provisions under which the commission was formed. The researcher also referred to the verdicts passed out in the various landmark cases which were found by using various database like Manupatra and SCC Online. COPRA 1986 was used to get a clear view of the Dispute Redressal Mechanisms.

Research Questions:
  1. Whether the primary purpose of the National Consumer Dispute Redressal Commission has been attained or not?
  2. Whether the National Consumer Dispute Redressal Commission has helped the consumers in any way?

Chapterisation:
The research paper begins with the declaration and the acknowledgement. The research paper is divided into two chapters. The first chapter is the synopsis and it gives the introduction regarding the National Consumer Dispute Redressal Commission and also the various sections of COPRA. The second chapter discussed the landmark cases in some detail. Lastly, there is conclusion. In the end, there is bibliography and also a list of the cases that are being discussed and referred to in it
Literature Review:

For this research paper, the researcher had to refer to a lot of cases and to find out the latest and most crucial cases in this field, the researcher took assistance from e-databases like Manupatra and SCC Online. Both the e-databases gave a never-ending list of cases but the researcher filtered out the most important ones and the ones that truly showed an impact in the society.

The researcher also went to the website of NCDRC to know more about the commission and get a clear view of the role of the commission and also refereed to COPRA 1986 to comprehend the act and the commission better.

The Landmark Cases
Nestle India v The F00d Safety and Standards Authority
The dispute vented from Barabanki district of Uttar Pradesh where testers of Maggie Instant Noodles were gathered by Uttar Pradesh Food Safety and Drug Administration and the same was found to comprise of lead, MSG. Relevantly, the order dated 5th June released by FSSAI has categorized the issue with respect to Maggie.

The first is the existence of lead in surplus of maximum accepted levels of 2.5 ppm, deceptive classification information on the package reading "n0 added MSG" i.e. M0n0 S0dium Glutamine and lead.

The Acts that were relating to the case are The C0nsumer Protection act of 1986, The Preventi0n of Food Adulterati0n Act of 1954, the Food Safety and Standard Act of 2006 and the Competition Act of 2002.

The entire controversy revolving around Maggi had caught everyone's attention.

The government had filed a complaint against the Nestle issue before NCDRC under the Section 12(1D) of the Consumer Protection Act. Rs.640 Crore was sought as compensation. The issue was such that each packet of Maggie was labelled by FSSAI but not even once during this whole issue did it give any explanation as to how were the violations permitted to take place at such a large scale.

Nestle also never identified the list of items which were in violation. It was a surprise when media was flooded with the news that FSSAI had not executed any food recall technique to date. Also, there were labelling violations. The defense taken by Maggie was that they don't add MSG but the raw materials may contain naturally added MSG which cannot be confused with commercially produced MSG and therefore it was not harmful as it is found in everyday material such as tomatoes, peas, onions, cottage cheese, milk.

A twist for the case was when FSSAI claimed that it had never banned the instant noodles by Nestle and instead had only sent a show-cause notice. It also said that the company straightaway moved to the Bombay HC and claimed that it was unjustified to ban the noodles without even giving them an audi alterem partem.

Almost after a year it got into controversy, Maggie passed all the safety test prescribed by the Supreme Court and the National Consumer Dispute Redressal Commission. All the tests that were conducted on the instant noodles failed to find any excess of lead and MSG in it. Due to the ban on Maggie Instant Noodles, the company had suffered a huge financial loss for the first time on seventeen years. [4]

Air India Ltd. v Tej Shoes Exporters Pvt. Ltd. and Another[5]
In the given case, Tej shoes gave a shipment to Air India for a delivery in Germany worth 1,50,152 deutsche mark. Air India further gave it to Lufthansa Airlines as Air India confided in the carriers and was into business with them for quite a while. This was finished by printing the terms and c0nditions on the back 0f the aviation route b�ll.

Be that as it may, Lufthansa Airlines erroneously conveyed the whole dispatch to Militzer Und Munch without getting the aviation route bill. Lufthansa Airlines likewise approved Air India to settle the case of Tej Shoes as US$ 39,780 according to the Maximum Liability Rule. Not happy with the sum Tej Shoes filed a complaint before NCDRC under Section 21 read with Section 12 of the Consumer Protection Act, 1986.

The Commission asked Air India to pay the imperative sum itself of US$ 39,780 and nothing else. Yet, Air India stayed unsatisfied and recorded a Special Leave Petition which was rejected. Tej Shoes after a gap of over three years filed a suit in the Supreme Court of India challenging the order of the National Consumer Dispute Redressal Commission and requested a remuneration of Rs.48,86,784. Air India argued that the suit was time barred and that they shouldn't pay a sum more than that predefined in the carriage via Air Act.

To argue this Air India referred to Sailesh Textile Industries V. English Airways and Another,[6] wherein it was determined that any case for any misfortune must be set aside a few minutes of two years according to the Limitation Act. On account of improper conveyance of products, activity lies under proviso 29 and 30 of the restriction demonstration and subsequently according to this activity will be started if a grumbling is recorded inside two years of the protest.

In any case, these provisos separate period from the time of confinement and hence make the suit time banished. In this way, the intrigue was permitted. This case determines profound dispute as to there will be no cure if a suit is time barred and no exclusion will be allowed. Additionally, it determines that just reasonable sums ought to be redressed and unnecessary cases ought to be set off. NCDRC permitted just the total upto which Air India may have endured the misfortune with some pay, yet in addition it didn't permit any further case via Air India to give them additional pay.

Likewise, it was referenced that each suit should be documented inside the time indicated under the Limitation Act for example two years and any case crossing that period will be viewed as void and not taken up in the court[7]. Thus, this judgment made it extremely clear onto the determinations of the court and that no one can go about according to their wish without following the requests of the court.

Kolkata and Others v Shri Apurba Konar[8]
In this case, the opposite party had to board a train from Katwa Junction on 4th October 2002.
But when he reached the station he found that his train was to boarded from platform 2 rather 1. Subsequently so as to get to platform 1, he chose to cross the tracks since the overhead bridge was under maintenance. While endeavoring to cross by means of the tracks, the individual fell getting a crack in his right leg since his right leg stalled out between the rock and the railroad track.

The individual filled a complaint before the Calcutta Disputes Redressal Commission asking for Rs.3 lakhs as compensation and also Rs.29.585 for the medical costs he had to pay and Rs.5000 as expense of procedures.

The District Forum permitted the guarantee giving Rs.18,900 as costs brought about on medical treatment, Rs.2000 as costs on suit and Rs.1 Lakh as remuneration. The Railway Authority was not contended with the decision and therefore it filed a revision Petition before the State Commission but the verdict given by the District Forum was carried on since the State Commission rejected the claim.

Thus, the case went to the National Commission where the Railway Authority pleaded that the claim didn't fall within the jurisdiction of Consumer Protection Act and it should be appealed before Railway Tribunal since the mishap which took place had no association with the services or the quality that is provided by the Railway Authority.

It was also claimed by the authority that it was a fault on the part of the person since he did not bother checking any notice boards that demonstrated a way to get to platform 2. Railway Authority claimed that the "untoward act" falls within the ambit of Section 13 and 15 read along with Section 123 and 124A claiming that the case could only be filed before the Railway Tribunal.

They also said that they took instantaneous actions to relief the person and also presented Rs.5000 for treatment expenses as per Railways Act. Therefore, the court nullified the orders passed by the District Forum as well as the State Commission and disposed-off the claims.

This case had a very far-reaching impact in the people since they got a clear view regarding the jurisdiction of the courts and also gave them the knowledge that filling a case before the wrong authority would provide them with no compensation or remedy. Also, if a person gets injured due to his own negligence then a particular authority cannot be held liable for that very injury.

National Insurance Company Ltd. v Hindustan Safety Glass Works Ltd. [9]
In this case, the question that arising was that whether the claim of the respondent for goods insured was rightly accepted by the National Commission. And the court said that it found no reason to interfere with the decision of the National Commission. The respondent Hindustan Safety Glass Works Ltd had taken out two policies with the appellant National Insurance Company for a period of one year dated 29th August 1990. The first policy was for Rs. 4.9 Lakh and second one was for Rs. 5.7 crore.

There was no conflict on 6th August 1992 after there was heavy rainfall in Calcutta resulting in accumulation of rain water both inside and outside of the factory which cause a huge loss and therefore claims were filed by the insured on 7th and 8th August 1992 for around Rs.52 Lakh. NT Kothari was appointed as the surveyor by the National Insurance and submitted a report indicating a loss of Rs.24 Lakh.

But National Insurance didn't accept that report and instead appointed Seascan Services Pvt Ltd as a surveyor and the loss accessed was Rs.26 Lakh. The damage incurred was reduced to about Rs.24 Lakh by the insured but nothing was paid to the National Insurance.

The Supreme Court in this landmark case held that in a conflict regarding a consumer, it is a necessity for the court to take a convincing view of the rights of the consumer predominantly since it is the consumer who is placed at the inconveniency in comparison to the supplier of services of g00ds. Also, it is to overcome this drawback that a law which is considerate towards people in the form of the Consumer Protection Act 1986 was passed by the Parliament.

Therefore, in the Judgement the Apex Court has ratified the spirit of the Consumer Protection Act of 1986 under which the protection of consumers was the primary goal and not to let the practical provisions of limitation in the Act to be interpreted in the manner which puts consumer on the disadvantageous position thereby divesting them of their rights. The above Judgement of the Apex court comes as a major reassurance to the consumers whereby the large corporations and companies will not be able to utilize the period of limitation to their advantage and the "Little man" will be able to claim his right without any trouble whatsoever.

A Consumer can file a complaint even after two years (which is the limit according to the law) from the date on which his right was infringed if the consumer can prove that it was the service provider or the company that was responsible for the emerging delay. Where supplier is accountable for causing a delay in the arrangement of the consumer's claim the consumer shall be authorized under law to file a complaint in the Consumer's Court even after expiry of two years.

Chief Administrator H.U.D.A & Anr v Shakuntala Devi[10]
In the present case, the respondent Shakuntala Devi was allotted a plot in Sector 8, Urban District of Karnal on 3rd April 1987, but was not given the physical possession of the property. Due to the lack of authorities in granting the physical possession of the property to Shakuntala Devi, she filed a complaint before the State Consumer Disputes Redressal Commission.

The State Commission on 21st December 1998 held H.U.D.A accountable for the deficiency in service of allotting the plot to the respondent and thereby allowed the complaint of Shakuntala Devi ordering H.U.D.A to pay interest at the rate of 12% of the deposited amount and also pay Rs.2 lakhs as compensation on account of an increase in the cost of production.

Also, H.U.D.A was asked to pay Rs.20,000 on account of monetary loss and mental harassment suffered by the respondent. H.U.D.A was not satisfied with the order of the State Commission and hence filed an appeal before the National Consumer Disputes Redressal Commission. Before the aforesaid authority, the appellant submitted a building plan on 14th February 2006 which clearly proved that the respondent had no intention in constructing a house over the allotted plot in contradiction to the claim by the respondent of an increase in construction charges between April 1989 and January 2000 to Rs.18,67,000.

Therefore, after considering the fact that the respondent was not interested in constructing a house on the property until 2006, the compensation to be granted was reduced from Rs.18,67,000 to Rs.15lakhs. Therefore, on 25th September 2007, the National Consumer Disputes Redressal Commission dismissed the claim by H.U.D.A and went ahead with its order.

The case was further taken to the Supreme Court who said that for entitlement of compensation, one should prove the loss or injury that might have been incurred. Thus, as a result of the proof, the appropriate authority shall decide the amount of compensation as per the Consumers Protection Act of 1986.

The Supreme Court referred to Ghaziabad Development Authority V. Balbir Singh[11], wherein it was contended that compensation for harassment shall be less since the opposite party will be receiving extra amount as compensation due to an increase in the value of property that the party shall be getting.

Further, the court said that an order to provide possession is already an advantage to the opposite party and the compensation also rose since the value of the land/property shall go up with time. In the present case, the court feels that whether the order passed by the State Commission and confirmed by the National Commission to give Rs.15 lakhs as compensation was correct or not.

The court agrees that the respondent got affected due to a rise in prices of construction between April, 1989 to January, 2000. But the court felt that the State Commission ignored an important fact that the respondent intentionally delayed construction for 6 years and because of which it felt that the amount granted in the form of interests were sufficient to compensate the respondent and there was no need to provide further 15 lakhs. Therefore, the Supreme Court dismissed the orders by the State Commission and the National Commission to grant Rs.15 lakhs as compensation.

Such a case plays an important role in warning consumers that they cannot misuse the law and take undue advantage of the law. The act carried out by Shakuntala Devi to get possession of the property and also receive compensation in order to get double benefits was inspected by the Supreme Court and condemned by striking off the compensation order.

This brought out the point that no one can take undue advantage of the law and fool the law on account of personal benefits, such acts are condemned by the court and not supported at any instance. Thus, the case becomes important since it warns the consumers that they should not indulge into practices involving misuse of the law since such an act can have repercussions that may lead to disadvantages instead of a certain advantage.

Charan Singh v Healing Touch Hospitals and Others [12]
In this case, the appellant Charan Singh went to Healing Touch Hospital for treatment of stomach ache and burning sensation while passing urine, at the hospital he was diagnosed by Dr. Juneja who admitted him and asked him to undergo a surgery for removal of stone from his body on 12th January 1993. At the time of the operation, Charan Singh was given spinal anesthesia by Dr. Seth.

After the operation, Charan Singh felt that there were some major changes in his body, his right side of the body was paralyzed and blood came from his urine. Therefore, he was asked by the doctors to take some medicines after being told that the disorder was for a limited time. But even after a few days the problem continued and Charan Singh again went to the hospital where was again asked by Dr. Juneja to be admitted in order to carry out a surgery to stop the flow of blood while passing urine.

At the time of the operation, after being given anesthesia, Charan Singh contends that in his drowsy state he had forcefully been made to sign on certain documents. After the operation, the right side of his body still remained paralytic but he was made to believe that he should continue taking medicines that would help him get over the problem.

But, the state of his body continued because of which he went to another hospital where he was told that his left kidney was removed. In a fit of shock, Charan Singh went back to the Healing Touch hospital to ask about the situation, but found that nobody was interested in talking to him and he was made to get out of the hospital.

Therefore, Charan Singh filed a complaint before the National Consumer Disputes Redressal Commission with a claim of Rs.34lakhs which included the cost of operations and medicines, compensation for illegally removing his kidney without consent, he lost his job because of his paralytic state and a certain compensation for the state of body he was made to enter.

The National Commission after looking into the salary of Charan Singh found that the claim was made before the wrong court and dismissed it suggesting the counsel to file a case before the District Forum or State Commission. But the learned counsel argued that Charan Singh had lost his job, he had become paralyzed from one side of his body, his left kidney was removed without his consent because of which he was incapable of doing anything and he suffered a lot of pain and suffering because of which he should have been given a chance to present his claim but his claim was dismissed after being termed as unrealistic and exaggerated.

The Supreme Court said that it was unhappy with the decision given by the National Commission since the Commission did not give a chance to the appellant to present his claim even after suffering so much, which makes the National Commission wrong in dismissing the claim by calling it to be an exaggerated one.

The court said that the National Commission has no pecuniary jurisdictional limits in granting compensations beyond its jurisdictions, whereas the District Forum or the State Commission have a certain jurisdictional limit. Thus, in the present case, the court feels that the National Commission after carrying out the proceedings for 6 years should have had brought the case to a proper conclusion that might have involved an proper mathematical calculation of the compensation amount keeping in mind the salary of the appellant instead of dismissing the claim by calling it to be unreasonable.

Therefore the Supreme Court asked the National Commission to work as per the motive of the Consumer Protection Act which is to provide speedy redressal to the consumer instead of carrying out the cases for long years, 6 years in the present case. Therefore, the court allowed the appeal of the appellant and directed the National Commission to set aside its order.

Lucknow Development Authority v M. K. Gupta [13]
M.K. Gupta had booked a flat with the Lucknow Development Authority but due to some reasons did not get the delivery of the flat on time, because of this he brought up a suit before the appropriate consumer forum. In response to it the Lucknow Development Authority contended that M.K. Gupta was not a consumer under Section 2(1)(o) of the Consumer Protection Act since construction activities did not come under the category of services.

The court said that the expression 'consumer' is a wide definition, it includes a variety of activities like corporation, shops etc. Its definition has two parts, one deals with goods whereas the other deals with services, both the parts show the meaning of the goods and services. Another side taken is that the definition of service has three parts, the main clause, the inclusive clause and the exclusive clause.

The main clause is very wide and applies to a host of services made available to consumers. Therefore, it fulfils the purpose of including activities which involve professional skills. Thus, the act of constructing houses comes under the clause of providing services since it includes varies activities like allotting houses, building sites, constructing houses etc. and in return the builder gets appropriate monetary benefit, therefore this act of builders is termed as 'Benefit made available to potential users'.

Hence, any person who applies for allotment of a building or a flat and enters into an agreement with any authority or builder or contractor becomes a potential user and gets his transaction covered under the category of 'Service of any Description'.

Therefore, as per the National Consumers Disputes Redressal Commission, M.K. Gupta was entitled to the delivery of flat since he entered into an agreement with the Lucknow Development Authority for receiving a flat and this agreement made him a consumer under the Consumer Protection Act. Therefore, the Lucknow Development Authority was asked to give M.K. Gupta the possession of the flat and some compensation in order to make for his loss.

National Seeds Corporation V. M. Madhusudan Reddy [14]
National Seeds Corporation was setup by the Government of India in order to arrange for good quality seeds that help in better agriculture. Its main task is to arrange for sees of different varieties and supply them to farmers in order to get better and efficient production. The respondent owns lands in various parts of Andhra Pradesh, they filed a complaint against the petitioners on the ground that they were delivered bad quality of seeds that had damaged their land and the crop was also not grown on time.

The respondent arranged for horticulturist who inspected the land and made a report stating that the crop failed because the seeds were defective. The respondent therefore filed a complaint before the consumer forum asking for a compensation of Rs 1,38,322 and another rs 1lakh for the losses suffered. The District Forum asked to pay Rs 1lakh as compensation and Rs 10,000 in lieu of the losses suffered.

Aggrieved by the order the petitioner filed a revision petition before the State Commission and the National Commission but it was dismissed and therefore, the complaint was brought before the Supreme Court. The Court read that the Section 3 of the Consumer Protection Act shall be read along with other provisions and not in derogation to any other provision for the time being in force.

The court mentioned that the appellant should have applied for arbitration remedy under the Section 8 of the Arbitration and Conciliation Act and that District Forum had no authority to entertain the complaint. And if the respondent files a complaint under the Consumer Forum, he cannot deny remedy under the Arbitration clause. Seeing the reports of the horticulturist, it could be concluded that the seeds were defective and the crop failed because of them, and therefore because of the report there was no need to invoke Section 13 of the Consumer Protection Act.

Also, the appellant had promised the respondent to buy the crop and on that ground the respondent purchased the seeds. Therefore, since the respondent was under the promise of the appellant, he did not purchase the seeds for resale or any other commercial purpose and was therefore termed as a consumer under the Consumer Protection Act and was eligible for remedy. Thus, the court dismissed the appeal of the appellant and directed them to pay a cost Rs 25,000 to the respondents.

Conclusion
When Consumer Protection Act was established in 1986, its primary purpose was to protect the consumers from the biased and fraudulent activities that were carried out by the traders, shopkeepers etcetera. It not only provided protection and rights to the consumers but the shopkeepers as well and coined out the maxims 'Caveat Emptor' and 'Caveat Venditor'. Former means 'Let the Buyer Beware' and the latter means 'Let the Seller Beware'.

The Consumer Protection Act also specifies the role of the various courts and has laid down the duties of the three courts which are the District forum, the State Forum and The Central Forum. [15]When the complainant is still not satisfied from the three, then the case can be filed in the Supreme Court of India.

The Act has assisted the consumers in getting respect and safety from the sellers. They are provided with good material products and are not deceived by the sellers. There are various landmark judgements that have been passed at different level forums which distinctly postulate the roles and obligations that are to be followed by both the seller as well as the buyer. it has become a platform where the consumers can file their grievances in regard to any fault in products or if they get any defective services from the service provider.

The act has fulfilled its motto of providing quick redressal to the complaints of the consumer and also providing the basic protection rights to the consumers. It has unchained the consumers for raising their voices in case they feel that they are being betrayed by the seller or the service provider which was not present before the act was established. By taking all the cases given above together, it can be said that both the seller as well as the buyer have the rights against each other and they cannot be violated.

This act has brought a major positive change in the market and due to this, the buyer feels safe while purchasing any product. The decision of creating a independent body for such consumer related problems was an appropriate one. It gives the consumers a sense of reassurance. They are now being offered superior quality products and it has also created a struggle among the sellers to provide enhanced services to the consumers at an affordable price.

The mistreatment of the consumers has been almost eliminated due to this act and the suspicion of the consumers have been overcome due to this speedy redressal mechanism under the Consumer Protection Act of 1986.

Bibliography:
  1. The Consumer Protection Act, 1986
  2. National Consumer Dispute Redressal Commission Portal
List of Cases:
  1. Nestle India v The Food Safety and Standards Authority WPL/1688/2015
  2. Air India Ltd. v Tej Shoes Exporters Pvt. Ltd and Another
  3. Kolkata and Others v Shri Apurba Konar
  4. National Insurance Co. Ltd. v Hindustan Safety Glass Works Ltd. and Another
  5. Chief Administrator Huda and Another v Shakuntla Devi
  6. Charan Singh v Healing Touch Hospitals and Others
  7. Sailesh Textile Industries v British Airways and Anr
  8. Vij Sales Corporation v Lufthansa Airlines
  9. Ghaziabad Development Authority v Balbir Singh
  10. Lucknow Development Authority v MK Gupta
  11. National Seeds Corporation v M. Madhusudan Reddy
End-Notes:
  1. The Consumer Protection Act, 1986
  2. Section 21 COPRA 1986
  3. The Consumer Protection Act 1986
  4. M/S Nestle India Limited v The F00d Safety and Standards Auth0rity of India WPL/1688/2015
  5. Air India Ltd. v Tej Shoes Exporters Pvt. Ltd. and Another MANU/DE/3321/2013
  6. Sailesh Textile Industries v British Airways and Anr 2003 (69) DRJ 683
  7. Vij Sales Corporation v Lufthansa Airlines ILR 1981 Del 749
  8. Kolkata and Others v Shri Apurba Konar MANU/WB/1370/2009
  9. National Insurance Company Ltd. v. Hindustan Safety Glass Works Ltd (2009) 5 SCC 121
  10. Chief Administrator HUDA & Anr v Shakuntala Devi Civil Appeal No. 7335 of 2008
  11. Ghaziabad Development Authority v Balbir Singh, (2004) 4 SCC 65
  12. Charan Singh v Healing Touch Hospital and Ors (2000) 7 SCC 668
  13. Lucknow Development Authority v M. K. Gupta, AIR 1994 SC 787
  14. National Seeds Corporation V. M. Madhusudan Reddy, MANU/SC/0038/2012
  15. Consumer Protection Act of 1986

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