1. Purchase of groundnut seeds — Allegation of substandard quality leading to crop failure — Complaints filed under Section 12, Consumer Protection Act, 1986. (Para 3 )
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2026 Supreme(SC) 170
SUPREME COURT OF INDIA
B.V. Nagarathna, Ujjal Bhuyan, JJ.
M/S Shyam Beej Bhandar & Anr. Etc. – Appellants
Versus
Suresh Etc. – Respondent
Civil Appeal Nos. 13749-13755 of 2024
Decided On : 05-02-2026
Advocates appeared:
For the Appellant(s) : Mr. Vikas Upadhyay, Adv. Mr. Abhindra Maheshwari, Adv. Ms. Tulika Mukherjee, AOR Mr. Beenu Sharma, Adv. Mr. Venkat Narayan, Adv.
For the Respondent(s):Mr. Varun Mishra, AOR Mr. Ankur Jain, Adv. Mr. Anirudha Singh Rajavat, Adv. Mr. Sanchit Jain, Adv. Mr. Prablin Singh Abrol, Adv. Mr. Prashant Kumar Saxena, Adv. Mr. Ajit Kumar Singh, Adv.
For the Appellant(s) : Mr. Vikas Upadhyay, Adv. Mr. Abhindra Maheshwari, Adv. Ms. Tulika Mukherjee, AOR Mr. Beenu Sharma, Adv. Mr. Venkat Narayan, Adv.
For the Respondent(s):Mr. Varun Mishra, AOR Mr. Ankur Jain, Adv. Mr. Anirudha Singh Rajavat, Adv. Mr. Sanchit Jain, Adv. Mr. Prablin Singh Abrol, Adv. Mr. Prashant Kumar Saxena, Adv. Mr. Ajit Kumar Singh, Adv.
Partial deficiency in service can coexist with natural causes affecting crop yield, underscoring the need for a balanced assessment in consumer disputes.
Headnote:(A) Consumer Protection Act, 1986 - Sections 12 and 19 - Dispute regarding substandard quality of groundnut seeds leading to crop failure - The NCDRC restored the order of the District Forum after setting aside the State Commission's order. Findings indicated a partial deficiency in service by the appellants, suggesting shortfalls from both seeds and natural causes (Paras 6, 12, 16).
(B) Orders of lower consumer forums and appraisement - The court emphasized the need to balance consumer rights against production shortcomings due to natural phenomena (Paras 6, 16).
Facts of the case:
Respondents-farmers purchased groundnut seeds from the appellants, which led to failed crops due to alleged substandard quality. The District Forum awarded compensation, which was overturned by the State Commission but restored by the NCDRC (Paras 2-4).
Findings of Court:
The court partially allowed compensation, directing the release of 50% of the deposited amount to the respondents-farmers while refunding the remainder to the appellants (Paras 16, 17).
Issues: The core issues involved assessing the quality of seeds and determining liability for the crop failure.
Ratio Decidendi: The court concluded that while the findings of deficiency in service were partially valid, natural causes also contributed to the crop failure, warranting a balanced response (Paras 12, 16).
Result: Appeals allowed in part, directing compensation adjustments.
Legal Category Hierarchy
Table of Contents
2. Appellants contend no deficiency of service and vis-major due to rain; respondents argue deficiency based on crop failure and expert findings. (Para 6 , 7 , 8 , 13 , 14 )
3. Expert report confirms partial seed maturity and mixed species, but also notes excess rainfall contributing to yield shortfall, indicating partial deficiency. (Para 9 , 10 , 11 , 12 , 15 )
4. Liability for deficiency in service is apportioned when crop failure results from both substandard seed quality and intervening natural causes. (Para 15 , 16 )
5. Appeals allowed in part — Findings of deficiency modified — 50% of deposited compensation released to respondents and 50% refunded to appellants. (Para 16 , 17 )
6. How is deficiency of service determined when an expert report shows partial crop failure?
If an expert report indicates that only a portion of the crop developed fully while the rest remained semi-developed beyond the ripening timeline, it suggests a deficiency in service, though not necessarily a complete one. (Para 9 , 10 , 11 , 15 )
7. What is the impact of natural causes (vis-major) on a claim for deficiency of service regarding seed quality?
When evidence shows that natural causes, such as excess rainfall, contributed to a shortfall in yield alongside substandard seed quality, the liability for deficiency of service may be mitigated or apportioned. (Para 12 , 15 )
8. Can compensation be apportioned if both seed quality and environmental factors cause crop loss?
Yes, the court may direct the release of a portion of the compensation to the consumers and the refund of the remainder to the provider to serve the interests of justice. (Para 15 , 16 )
JUDGMENT :
NAGARATHNA, J.
The producer and distributor of groundnut seeds, namely, M/s. Shyam Beej Bhandar and Shree Ram Agro Bio-Tech (“appellants”, for short) respectively have filed these appeals assailing the order dated 19.03.2021 passed by the National Consumer Disputes Redressal Commission, New Delhi (“NCDRC”, for short) in Revision Petition Nos.1275 to 1281 of 2019.
2. By the impugned order, the NCDRC has set aside the order dated 04.04.2019 passed by the State Consumer Disputes Redressal Commission, Rajasthan (“State Commission”, for short) which was in favour of the appellants and thereby sustained the order dated 28.08.2018 passed by the District Consumer Disputes Redressal Forum, Alwar, Rajasthan (“District Forum”, for short) in all the complaints filed by the respondents-farmers.
3. Briefly stated the facts of the case are that the respondents- farmers approached the appellant for the purchase of ground nut seeds on 15.06.2013. Around four months later, in October, a complaint was filed by the respondents-farmers before the Deputy Director (Agriculture), District Council, Alwar alleging sub- standard quality of the seeds leading to the failure of the crop. Accordingly, a committee was constituted to investigate the failure of the crop. The committee submitted its inspection report on 09.10.2013. Thereafter, the respondents-farmers filed complaints under Section 12 of the Consumer Protection Act, 1986 before the District Forum. The District Forum, vide order dated 28.08.2018, allowed the complaints and directed the appellant(s) to make payment of different amounts to the respondents-farmers along with compensation of Rs.20,000/- and cost of the suit at Rs.5,000/- each. Aggrieved, the appellant preferred Appeal No.754/2018 before the State Commission. The State Commission, vide order dated 04.04.2019, set aside the order of the District Commission dated 28.08.2018. In turn, the respondents-farmers moved the NCDRC by filing Revision Petition Nos.1275-1282 of 2019. Vide the impugned order dated 19.03.2021, the NCDRC set aside the order of the State Commission and restored the order of the District Forum.
4. We have heard learned counsel for the appellants and learned counsel for the respondents-farmers at length and perused the material on record including the complaints filed by the respondents-farmers; the order passed by the District Forum dated 28.08.2018; the order passed by the State Commission which has set aside the aforesaid order of the District Forum; and the impugned order passed by the NCDRC on dated 19.03.2021 which has sustained the order of the District Forum.
5. During the course of submissions, learned counsel for the respective parties drew our attention to the Investigation/Inspection Report (Annexure P-1) dated 09.10.2013. For ease of reference, the said report is extracted as under:
“INVESTIGATION/INSPECTION REPORT
Investigation inspection report in the complaint of the farmers from Village Katopur, Tehsil Kotkasim in relation to demeritorious groundnut crops.
The complaints of the demeritorious groundnut crops of the farmers from Village Katopur, Tehsil Kotkasim have been received by this office from the office of the respected District Collector, Alwar. The farmers from Katopur i.e. Shri Dilip Singh, Chait Ram, Suresh, Abhay Singh, Puran, Ramphal, Subey Singh, Jai Prakash, Vishambhar etc. have submitted in the complaint of the demeritorious crops that "groundnut seeds were sown over a land of 250 Bigha and that all the bags i.e. 300 bags were purchased from Shyam Beej Bhandar, 125 Nemi Chand Market, Alwar. The crops of groundnut ripen within 3 to 3.5 months time but till now the crops being demeritorious as: the quality of seeds being substandard and due to the said sub-standard seeds the crops over 250 Bigha of land in the village have become demeritorious." The details of the invoices of Shyam Beej Bhandar annexed along with the complaint is as following:-
| Sl. No. | Name of Farmer | ||||
