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NATIONAL CONSUMER DISPUTES REDRESSAL COMMISSION, NEW DELHI
Dr. Inder Jit Singh, Presiding Member, Dr. Sudhir Kumar Jain, Member
Jarpula Veeru and Ors. – Petitioners
versus
Maharashtra Hybrid Seeds Company Ltd. and Ors. – Respondents
Revision Petition Nos. 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 76, 77, 78, 79, 80 and 81 of 2025 With IA No. 275-277 of 2025
(Condonation of delay, Exemption of file typed copies of documents, Exemption for filing official Translation), IA No. 1744 of 2025 (Amendment of cause title)
Decided on 4.12.2025

Counsel for the Parties:
For the Petitioners:Mr. Rana Sandeep Busa, Ms. Divya Tomarand and Mr Abadh Kishore Singh, Advocates
For the Maharashtra Hybrid Seeds:Mr. Ankit Swarup and Ms. Vidisha Swarup, Advocates
For the Vasavi Fertilizers: Ex parte (vide order dated 14.10.2025)
For the Sri Thirumala Fertilizers: Ex parte (vide order dated 14.10.2025)
For the Biotech Laboratory: Ex parte (vide order dated 14.10.2025)
For the Durga Fertilizers: Ex parte (vide order dated 14.10.2025)

IMPORTANT POINTS
(1) Burden of Proof for Defective Goods – The primary onus lies on the complainant to prove that the seeds supplied were defective or spurious. In cases involving seeds, the absence of a recognized laboratory test report (under Section 13(1)(c)) or specific scientific evidence makes it difficult to hold a manufacturer liable for poor crop yield.
(2) Finality of Orders – If one of the Opposite Parties fails to prefer an appeal against a District Forum’s order, that order becomes final and binding against that specific party. Even if a co-defendant successfully appeals and proves no liability on their part, the court cannot suo motu set aside the decree against the non-appealing party.

Headnote:

Consumer Protection Act, 1986 – Section 24 – Finality of Orders – Defective Seeds – Burden of Proof – NCDRC addressed revision petitions filed by farmers (Complainants) against the manufacturer of “Tejaswini” hybrid chilli seeds – District Forum had originally allowed the complaints, holding both the Dealer, OP-1, and the Manufacturer, OP-2, jointly and severally liable for crop loss due to allegedly substandard seeds – However, only the Manufacturer, OP-2, appealed to the State Commission, which subsequently set aside the entire order against both parties – NCDRC held that under Section 24, since the Dealer, OP-1, did not appeal, the District Forum’s order attained finality regarding their liability – Regarding the Manufacturer, OP-2, the Commission upheld the State Commission’s reversal, ruling that a field inspection report based on visual observations of “admixture” without scientific laboratory testing of seed samples is insufficient to prove a manufacturing defect – The initial burden of proof rests on the complainant to establish that the seeds were spurious.

ORDER :

Dr. Inder Jit Singh, Presiding Member.—The present Revision Petitions (RPs) have been filed by the Petitioners against Respondents as detailed above, against the order(s) dated 05.01.2023 of the State Consumer Disputes Redressal Commission Telangana (hereinafter referred to as the ‘State Commission’), inter alia praying for setting aside the order(s) of the State Commission. Notice was issued to the Respondent(s) on 09.04.2025. Parties also filed their Written Arguments/Synopsis.

2. As issues/law points and opposite parties involved are the same in these RP(s), these are taken up together, with RP No. 63 of 2025 as lead case . For sake of convenience, parties will also be referred to as they were arrayed before District Forum. Similar orders have been passed by the State Commission in other cases. Details of RP(s) covered under this order, their corresponding FA, CC No. before the District Commission, name of the complainant, names of OPs before the District Commission are given in Table at Annexure-A. Delay in filing the RPs was condoned vide this Commission’s order dated 14.10.2025.

3. Brief facts of the case, as presented by the Complainant and as emerged from the RP, Order of the State Commission, Order of the District Forum and other case records are that complainant is an agriculturist and purchased Hybrid Chilli Tejaswini (MHP) Mahyco seeds, 4 pouches of 10 grams each for Rs.1120/- vide bill no.26 from the OP No.1 He sowed all the said seeds in his land and observed all the required formalities as per directions of the Mahyco Company.(OP No.2) Unfortunately, there was no proper flowering and fruit didn’t ripen normally. The fruit should turn into red colour and the size was also not normal. There was variation in the fruit colour and most of the fruits have fallen, as such the yield was almost nil. The complainant alongwith other farmers approached the Horticulture Officer, Mahubudabad and requested to inspect the crops in their village. Higher Agriculture Officers visited and inspected the fields and gave report stating that there is 30% admixture in the crop and opined that there will be reduction of yields. The complainant sustained loss due to impurity and substandard seeds supplied by the OP(s). Complainant alongwith farmers issued legal notice to the OP(s) but OP(s) gave evasive reply. Being aggrieved, the Complainant filed CC before the District Forum and District Forum vide order dated 07.02.2019 allowed the Complaint. Being aggrieved, OP No.2 only filed an Appeal(s) before the State Commission, which was/were allowed vide State Commission’s order dated 05.01.2023. Therefore, the Petitioner(s) are before us now in the present RP(s).

4. Here it is important to note that in RP No. 63 of 2025 the Consumer Complaint (CC) filed before the District Forum by the complainant (Petitioner herein) there were 2 OPs, OP No.1 was M/s Vasavi Fertilizers, Pesticides and Seeds (respondent no.2 herein) and OP No.2 was Maharashtra Hybrid Seeds Company Ltd (respondent no.1 herein). As per the orders of the District Forum, complaint was allowed qua both the OPs and liability was fixed jointly and severally against both the OPs. The said order of the District Forum is reproduced below:—

27. In the result this complaint is allowed directing the opposite parties jointly and severally liable to deposit before this Forum a sum of Rs.40,000/- towards crop loss and to pay Rs.20,000/- per acre towards expenditure incurred by the complainant and to pay Rs.5000/- towards costs within one month from the date of receipt of the order.

5. However, it is only OP No.2 which challenged the order of the District Forum before the State Commission in FA No. 277 of 2019 and the appeal was allowed by setting aside the impugned order. No appeal was filed by OP No.1 to challenge the said order of District Forum. In this regard, we refer to Section 24 of the Consumer Protection Act, 1986, which is reproduced below:—

24. Finality of orders.—Every

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