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2025 Supreme(Online)(NCDRC) 3240

IN THE NATIONAL CONSUMER DISPUTES REDRESSAL COMMISSION, NEW DELHI
Jonnalagadda Rajendra, Presiding Member, Anoop Kumar Mendiratta, Member
VEERAMUSTI SATHISH S/o. VEERAMUSTI poshalu – Appellant
Versus
FASTINFO LEGAL SERVICE PVT LTD Through its rep.by authorised signatory – Respondent
SECOND APPEAL NO.788 OF 2025



Advocates:
For the Appellants/Petitioners: Appearance not marked
For the Respondents:

The revisional jurisdiction of the National Commission under Section 21(b) of the Consumer Protection Act is extremely limited and cannot be exercised to interfere with concurrent findings of fact recorded by the District and State Commissions unless there is a jurisdictional error or material irregularity.

Headnote:The matter involves the interpretation of Section 2(42) of the Consumer Protection Act, 2019. A complainant engaged a legal services provider to file consumer complaints against multiple parties, alleging subsequent deficiency in service and unfair trade practices due to delays and failure to properly file the complaints. The District Commission and State Commission both determined that the services rendered were contracts of personal service, which are excluded from the definition of "service" under the Act. The primary issue is whether the National Commission should exercise its revisional jurisdiction to interfere with the concurrent findings of the lower commissions. The court reasoned that under Section 21(b) of the Consumer Protection Act, revisional jurisdiction is extremely limited and should only be exercised if the lower commission acted illegally, with material irregularity, or exercised jurisdiction not vested in it by law, and cannot be used to disturb concurrent findings on evidence. Based on the discussion above, we do not find any merit in the present Second Appeal and the same is dismissed at this stage.

Table of Content
1. background of the dispute regarding legal services and the lower courts' finding that personal service contracts are excluded from the consumer protection act. (Para 1 , 2 , 3 , 4 , 5)
2. the limited scope of revisional jurisdiction under section 21(b) and the inability to disturb concurrent findings of fact. (Para 6 , 7 , 8)
3. dismissal of the appeal due to lack of merit and absence of jurisdictional error. (Para 9 , 10)

ORDER

1. This Second Appeal No.788 of 2025 challenges the impugned order of the Telangana State Consumer Disputes Redressal Commission, (‘State Commission’) dated 16.09.2025. Vide this order, the State Commission dismissed First Appeal No. 137 of 2025 filed by the Appellant/Complainant. In turn, this Appeal had been filed against the order of the District Consumer Disputes Redressal Commission, Warnagal (‘District Commission’) dated 03.03.2025. Vide this order, the District Commission, disposed of the Complaint filed by the Complainant/Appellant.

2. Brief facts of the case, as per the Complainant, are that attracted by a graphic designs web, app design, logo etc., of the Respondent/OP which is doing business with its Head Quarters at Calcutta and Noida in the State of Uttar Pradesh, he entrusted his case to the opposite party that against the services promised to cause filing and progressing of the case. However, OP adopted to making false and inaccurate statements, thereby, exploited for its commercial gain. The Complainant submitted a Consumer Complaint online against (i) CNH Industrial (India) Private Ltd., Gurugram, Haryana State; (iii) K.S. Tractors, Warangal, (ii) Sri Lakshmi Motors, Siddipet, (iv) Srilatha Tractors, Choppadandi, for their deficiency in service and unfair trade practice. Basing on the category of services of the Consumer Complaint, he paid the OP Rs.2,999/- as consideration along with GST of Rs.539 on 13.01.2023. He was allotted a number and, at first, the OP provided the service of Mr.Vishaka Chaurasia, an Advocate who issued legal notice dated 13.01.2023 to those parties. Having received reply from four, the OP provided service to the Complainant through their Panel Advocate, Smt. Susmita Biswas, who issued rejoinder notice. The panel advocate vide mail dated 19.05.2023 asked him to visit the District Consumer Forum, Hyderabad. She represented to the Complainant that a sum of Rs.4,999 + GST of 18% is to be paid. Ultimately, by offering discount of Rs.5,000, he was made to pay Rs.5,604 to the OP on 19.05.2013 under invoice. Due to delay on the part of OP, in extending the services as against their promise on 23.05.2023, the Complainant addressed an e-mail to refund the amount, that the OP assigned one Mari a, Advocate in Hyderabad in the month of June 2023 who extended the services and she sent draft copy of the Complaint and he suggested some amendments. On 12.07.2023 he was informed that she was going to USA and handed over the complaint to one Mr.K. Bhaskar, Advocate to process the same. On 14.07.2023, he sent all documents to the Advocate. Mr. K Bhaskar on 28.07.2023 sent a draft complaint, without incorporating the points suggested by the complainant, on 09.08.2023, he was asked to come to Ranga Reddy Court, to subscribe signatures. Again he was asked to come to same court on 17.03.2023, after corrections and signatures and he was made to pay Rs. 1,500 to Mr.Bhaskar on 09.10.2023, which is an unfair trade practice. Thereafter, while a new Sr No. was given, on 22.11.2023 the complaint was returned by the Advocate for filing on online e-daakhil. Despite all documents were sent, no response was received from Mr. K. Bhaskar, Advocate and no complaint was filed, which amounts to deficiency in service. In total the Complainant paid Rs.7,104 to the OP and spent Rs.3,000 for legal notice. The acts of OP amount to deficiency of service and unfair trade practice. He filed the complaint for refund of Rs.2,621 with interest @ 18% per annum, compensation of Rs. 1,00,000

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