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2025 Supreme(Telangana) 2068

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
K. Lakshman, J.
VNR Seeds Private Limited and other - Petitioners
Versus
Lingampalli Ravinder and others - Respondents
CIVIL REVISION PETITION Nos. 1175, 1196, 1197, 1198, 1201, 1202, 1203, 1205, 1206, 1210, 1211, 1222, 1249, 1260, 1264 ,1266, 1279, 1280, 1281, 1282, 1283 ,1284, 1293, 1314, 1320 ,1321, 1324 ,1325 ,1326, 1327, 1340, 1346, 1372, 1373, 1377, 1392, 1393, 1407 ,1408, 1409, 1484, 1485, 1486, 1487, 1488, 1489, 1490, 1491, 1492, 1493, 1494, 1495, 1496, 1497, 1498 , 1499, 1711, 1712 ,1713 ,1714 , 1715 ,1717, 1720, 1721, 1722, 1723, 1724, 1725, 1726, 1727, 1743, 1744, 1745, 1746 , 2017, 1747, 1748, 1749, 1750, 1753, 1821, 1822, 1824, 1823 , 1825 , 1826, 1827, 1828, 1829, 1830, 1831, 1845, 1846, 1847, 1848, 1849, 1858, 1859, 1860, 1861, 1862, 1863, 1864, 1865, 1867, 1868, 1869, 1870, 1871, 1872, 1873, 1874, 1876, 1877, 1878, 1880, 1892, 1893, 1894, 1895, 1896, 1897, 1898, 1899, 1921, 1923, 1926, 1929, 1940, 1957, 1958, 1959, 1972, 1993, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2018, 2019, 2021, 2022, 2023, 2024, 2026, 2027, 2028, 2029, 2031, 2033, 2039, 2040, 2041, 2042, 2043, 2044, 2045, 2046, 2047, 2048, 2049, 2050, 2051, 2054, 2055, 2056, 2057, 2058, 2059, 2060, 2061, 2062, 2063, 2064, 2065, 2079, 2080, 2081, 2082, 2098, 2105, 2140, 2141, 2149, 2150, 2151, 2154, 2155, 2156, 2157, 2163, 2164, 2165, 2177, 2184, 2324, 2325, 2696, 2326, 2344, 2346, 2345, 2347, 2348, 2374, 2380, 2384, 2353, 2354, 2365, 2375, 2376, 2377, 2378, 2379, 2381, 2382, 2383, 2385, 2387, 2389, 2391, 2409, 2429, 2462, 2482, 2483, 2484, 2485, 2523, 2540, 2542, 2559, 2567, 2569, 2586, 2587, 2609, 2610, 2611, 2612, 2613, 2623, 2624, 2625, 2626, 2646, 2654, 2659, 2660, 2666, 2667, 2671, 2673, 2675, 2679, 2680, 2681, 2683, 2684, 2686, 2687, 2688, 2690, 2692, 2694, 2698, 2699, 2700, 2701, 2702, 2703, 2704, 2714, 2715, 2716, 2717, 2718, 2719, 2720, 2730, 2731, 2732, 2744, 2745, 2756, 2759, 2766, 2767, 2768, 2769, 2770, 2771, 2772, 2773, 2780, 2781, 2782, 2783, 2786, 2787, 2795, 2796, 2797, 2801, 2802, 2803, 2804, 2805, 2806, 2807, 2808, 2809, 2810, 2811, 2812, 2813, 2845, 2846, 2847, 2870, 2876, 2877, 2878, 2879, 2881, 2882, 2883, 2884, 2885, 2886, 2887, 2888, 2889, 2890, 2891, 2914, 2915, 2916, 2917, 2918, 2919, 2920, 2921, 2922, 2923, 2924, 2934, 2935, 2936, 2937, 2938, 2939, 2941, 2942, 2943, 2944, 2945, 2946, 2947, 2958, 2959, 2960, 2966, 2971, 2972, 2973, 2985, 3007, 3009, 3011, 3013, 3014, 3027, 3028, 3029, 3031, 3036, 3042, 3045, 3046, 3047, 3049, 3050, 3052, 3053, 3054, 3055, 3070, 3071, 3072, 3078, 3082, 3073, 3087, 3074, 3081, 3083, 3086, 3097, 3100, 3088, 3109, 3179, 3114, 3161, 3166, 3167, 3168, 3169, 3171, 3172, 3173, 3174, 3175, 3176, 3177, 3178, 3180, 3181, 3182, 3183, 3184, 3185, 3186, 3187, 3207, 3208, 3209, 3225, 3227, 3239, 3240, 3249, 3252, 3254, 3255, 3256, 3287, 3288, 3289, 3290, 3291, 3292, 3293, 3294, 3295, 3296, 3350, 3370, 3371, 3372, 3373, 3374, 3375, 3393, 3423, 3501, 3502, 3503, 3504 OF 2025 
Decided On : 19-12-2025

Advocates Appeared:
For the Petitioner: Mr. Ankit Swaroop, Mr. Drupad Sangwan, Mr. N. Pavan Krishna Reddy, Mr. Rishi Bhargava, Mr. Ruchil Raj, Ms. Harika Tejavath, Ms. Duvvuru Ruthika Reddy, M. M. Naga Vekata Neeraj and Mr. K. Anirudh Reddy, learned counsel.
For the Respondent: Mr. P. Ravi Shankar, Mr. Kunamalla Karunakar and P. Aravind Reddy, learned counsel.

Farmers purchasing seeds for cultivation are recognized as consumers under the Consumer Protection Act, 1986, and can claim compensation for crop loss due to defective seeds.

Headnote:(A) Consumer Protection Act, 1986 - Section 2(1)(d) - Revision petitions against NCDRC's order - Farmers purchased defective and mis-branded seeds from manufacturers, leading to crop loss - Legal recognition of farmers as consumers confirmed - Evidence of deficiency in service established through expert reports, DNA testing. (Paras 19, 80, 84)

(B) Definition of 'Consumer' - Farmers buying seeds for personal cultivation considered consumers under the Act, despite crop yield sales. (Paras 19, 80)

(C) Deficiency in Service - Manufacturers' liability arises from defective goods resulting in crop failure, necessitating accountability under consumer protection laws. (Paras 18, 80)

(D) Burden of Proof - Initially lies with complainants, but shifts to manufacturers to disprove allegations of defect based on substantive evidence. (Paras 68, 78)

Facts of the case:
Petitioners provided chilli seeds to farmers, who experienced crop failure due to alleged genetic defects. Farmers filed complaints before District Forum which awards compensation; appeals by petitioners led to partial relief by State Commission, restored by NCDRC. (Paras 12-16, 33)

Findings of Court:
NCDRC upheld District Forum's findings of defective seeds, emphasizing consumer rights. (Paras 84, 86)

Issues: Main considerations included the definition of consumers in agricultural contexts, procedural compliance in evidence and liability in seed supply cases. (Paras 19, 80)

Ratio Decidendi: The Court emphasized the need for manufacturers to maintain quality standards; liability assigned due to evidence indicating misbranding and deficiency in service. (Paras 80, 84)

Result: Civil Revision Petitions dismissed; NCDRC's order confirming consumer liability upheld.

Judgement Key Points

Key Points: - Farmers purchasing seeds for cultivation are recognized as consumers under the Consumer Protection Act, 1986, irrespective of subsequent sale of produce (!) (!) (!) . - Supply of defective or misbranded seeds resulting in crop loss amounts to deficiency in service, with liability arising from failure to meet statutory quality and testing standards (!) (!) (!) . - The burden of proof initially lies with the complainant, but shifts to the manufacturer once prima facie evidence of defect is presented; manufacturers must produce contemporaneous quality‑control data to rebut allegations (!) (!) (!) .

What is the scope of "consumer" under the Consumer Protection Act for farmers purchasing seeds?

What constitutes "deficiency in service" in transactions involving seeds and agricultural inputs?

What is the burden of proof in seed‑related consumer disputes, including the shift of onus and evidentiary standards?


Table of Content
1. defective seeds and crop failure claims. (Para 4 , 5 , 6 , 7 , 8)
2. consumer complaints regarding compensation. (Para 12 , 13 , 15)
3. understanding consumer definitions in agriculture. (Para 18 , 19 , 22)
4. deficiency in service related to seeds. (Para 20 , 21 , 24)
5. judicial recognition of consumer rights. (Para 70 , 80 , 83)

ORDER :

K. Lakshman, J.

Heard Mr. Ankit Swaroop, Mr. Drupad Sangwan, Mr. N. Pavan Krishna Reddy, Mr. Rishi Bhargava, Mr. Ruchil Raj, Ms. Harika Tejavath, Ms. Duvvuru Ruthika Reddy, M. M. Naga Vekata Neeraj and Mr. K. Anirudh Reddy, learned counsel for respective petitioners and Mr. Kunamalla Karunakar, Mr. P.Ravi Shankar and Mr. P. Aravind Reddy, learned counsel for respective respondents.

2. All these revisions arise out of common order dated 06.01.2025 passed by learned National Consumer Disputes Redressal Commission, New Delhi (for short, ‘learned NCDRC’) in Revision Petition No.1376 of 2024 and batch, whereby learned NCDRC had upheld the orders passed by learned District Forum by setting aside the orders passed by learned State Commission wherein State Commission allowed some appeals filed by the petitioners, in part, reduced the quantum of compensation granted by learned District Forum and allowed some appeals in toto, set aside some of the orders passed by the District Forum in respect of some farmers –complainants.

3. Since there are multiple revisions, it would be difficult to discuss facts of all the cases. Further, the facts of all the cases are similar, except the names of parties and the quantum of compensation granted. There is no dispute with regard to the facts. Therefore, to avoid confusion and to have more clarity, it would be better to refer to the facts of the case in CRP No. 1203 of 2025.

FACTUAL MATRIX:-

4. The revision petitioner is a company registered under the Companies Act, 1956. It engaged in the business of seed production and sales having its registered office at Raipur, Chhattisgarh.

5. Respondent No.1 is a farmer and resident of Agrahampahad village, Atmakur Mandal, Warangal District, Telangana State and is claiming to have been cultivating chilli crops for the last few years.

6. It is also apt to note that even other farmers/complainants residents of the said village and other nearby villages of Warangal district, claiming to have been cultivating chilli crop for the last few years.

7. Respondent No.2 is a dealer, who sold the seeds to the farmer. Respondent No.1 - farmer purchased ten (10) packets of VNR 145 chilli seeds on 07.03.2017 from respondent No.2 dealer vide Lot No.1870 after paying an amount of Rs.3,300/- manufactured by Respondent No.1. Thereafter, respondent No.1 sowed the seeds in an area measuring Ac.1.00 guntas in the month of April, said to have incurred an amount of Rs.40,000/- for cultivating the land.

8. According to respondent No.1 – Farmer, there was crop loss due to supply of defective, mis-branded, genetically poor chilli seeds supplied by the petitioners – Manufacturers.

9. Upon a letter written by various farmers on 06.07.2017 with regard to alleged bad condition of crop, the District Collector, Warangal, informed the same to the Agriculture Officer, Joint Director of Agriculture and District Horticulture and Sericulture Officers. Later, the District Agriculture Officer, vide letter dated 07.07.2017 directed the Mandal Agriculture Officer to conduct joint inspection with the Horticulture officer and report compliance at the earliest.

10. The Mandal Agriculture Officer, vide letter dated 10.07.2017, informed the Asst. Director of Agriculture, Telangana DNA Finger Printing Crops monitoring Lab that he is sending green chillies leaves of 50 plants (randomly selected) for analysis. The Joint District-Level committee conducted a visual inspection on 11.07.2017 and subsequently submitted its report, stating that the crop had been severely affected by ‘Thrips incidence’, during the initial crop growing stage, attributed to the prevalence of high t

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