1. Civil appeals challenging orders of the National Consumer Disputes Redressal Commission in consumer disputes. (Para 2 )
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2025 Supreme(SC) 1487
SUPREME COURT OF INDIA
PAMIDIGHANTAM SRI NARASIMHA AND MANOJ MISRA, JJ.
Iris Pioneer Infraproject Private Limited - Appellant
Versus
Praveen Sachdeva And Others – Respondent
Civil Appeal No(s). 65, 66 of 2025 (@ Diary No. 54592/2024)
Decided on : 03-01-2025
The Supreme Court upheld the NCDRC's judgment but modified the scope of relief, restricting the entitlement to payments specifically to the complainants rather than all project allottees. The Court also extended the deadline for making these payments to February 28, 2025.
Headnote:(A) Consumer Protection Act, 2019 - Order of the National Consumer Disputes Redressal Commission - Appeals against order dated 12.04.2024 regarding entitlement of allottees to payments as stated in paragraph 10 - Modification made to refer specifically to complainants. (Paras 3 - 5)
(B) Errors in Law - The court found no error in fact or in law in the original judgment of the Commission, therefore, no intervention was deemed necessary beyond the specified modification. (Paragraph 3)
Facts of the case:
The appeals concern an order from the National Consumer Disputes Redressal Commission stating entitlements related to a project, and both appeals were against orders dated April 12, 2024, and October 23, 2024, affecting the rights of allottees.
Findings of Court:
The Supreme Court recognized no factual or legal errors within the Commission's original judgment while altering the terminology in the judgment regarding entitlements.
Issues: The primary issues involved the recognition of complainants' rights in the project as articulated by the National Consumer Disputes Redressal Commission.
Ratio Decidendi: The Supreme Court maintained that there were no grounds for interference in the Commission's order and redefined the designation of complainants' rights in payments without finding errors in the original judgment.
Result: Civil Appeals disposed of with specified modifications.
Legal Category Hierarchy
Table of Contents
2. Challenge to the findings of fact and law in the orders passed by the National Consumer Disputes Redressal Commission. (Para 3 )
3. The court found no error in fact or law in the lower commission's order but modified the scope of entitlement. (Para 3 )
4. Interference with a consumer commission's order is warranted only upon the existence of an error in fact or law. (Para 3 )
5. Appeals disposed of; NCDRC order modified to limit entitlement to complainants; payment timeline extended. (Para 3 , 4 , 5 , 6 )
6. Under what circumstances will the court interfere with an order of the National Consumer Disputes Redressal Commission?
The court will not interfere with the judgment and order of the National Consumer Disputes Redressal Commission if there is neither an error in fact nor an error in law. (Para 3 )
7. Can the court modify the beneficiaries of a relief granted by a consumer commission?
Yes, the court may modify the order to restrict the entitlement of relief from all allottees of a project to only the specific complainants in the case. (Para 3 )
ORDER :
1. Delay condoned.
2. These civil appeals are against the order passed by the National Consumer Disputes Redressal Commission in Consumer Case No. 316 of 2020 dated 12.04.2024 and also in Review Application No. 313 of 2024 dated 23.10.2024.
3. Heard Mr. S. Pattajoshi, learned senior counsel appearing on behalf of the appellant(s). While we are not inclined to interfere with the judgment and order passed by the National Consumer Disputes Redressal Commission on the ground that there is neither an error in fact or in law, we modify the direction in paragraph 10 that 'the Allottees of the project are similarly entitled to' to read as 'the complainants are entitled to'.
4. Apart from the above, there shall be no other modification in the order passed by the National Consumer Disputes Redressal Commission.
5. In the facts and circumstances of the case, we direct that the payments to be made as per the judgment of the National Consumer Disputes Redressal Commission and the time for making the same is extended till 28.02.2025.
6. With these observations, the Civil Appeals are disposed of.
7. Pending application(s), if any, shall stand disposed of.
