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2024 Supreme(Online)(SC) 2705

SUPREME COURT OF INDIA
SHRIRAM CHITS (INDIA) PRIVATE LIMITED EARLIER KNOWN AS SHRIRAM CHITS (K) PVT. LTD. – Appellant
Versus
RAGHACHAND ASSOCIATES – Respondent


JUDGEMENT

Aravind Kumar, J.

1. Leave granted.

2. The appellant (‘OP’/‘service provider’, used interchangeably) has challenged the order dated 10.03.2021 of the National Consumer Disputes Redressal Commission, New Delhi (NCDRC) in these appeals. The respondent (complainant) had successfully redressed its consumer grievance, originally, before the Principal Consumer Disputes Redressal for Bangalore Urban District, at Bangalore (‘District Forum’). The service provider was unsuccessful in upsetting the order of the District Forum before the State Consumer Disputes Redressal Commission, Bangalore (‘State Forum’) as well as the NCDRC. That is how this matter has come before us.

3. The service provider is a registered Chit Fund company engaged in Chit business. Admittedly, the complainant had subscribed to certain chits in the said business. The subscription was made in the chit group 53005/Ticket No.9 for a chit value of Rs.1,00,000/- payable at the rate of Rs.2500/- per month for a period of 40 months.

4. It is the case of the complainant that the OP had illegally stopped the chit business in the year 1996. The complainant requested the OP to repay the chit amount deposited until stoppage of

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                                              Judicial Analysis

                                              Joy Varkey alias Sebastian V.V. S/o George vs Regional Manager, Piaggio Vehicles - 2025 Supreme(Online)(SCDRC) 2301: Cited positively by the Supreme Court ("The Hon’ble Supreme Court held in paragraph 22"), indicating it was followed or relied upon as good law. This is Shriram Chits (India) Pvt. Ltd. vs Raghachand Associates (2024 KHC 6279).

                                              Federal Bank Ltd. vs National Consumer Disputes Redressal Commission and others - 2025 Supreme(Online)(P&H) 3684: Explicitly relies on and confirms the same Shriram Chits case ("Reliance in this regard can be placed on the judgment of the Supreme Court in the case of Shriram Chits (India) Private Associates, 2024 INSC 403"), treating it as confirmed good law. The phrasing "The Supreme Court confirmed the onus..." further supports positive treatment.

                                              Paramount Digital Color Lab VS Agfa India Pvt. Ltd. & Ors. Etc. - 2018 5 Supreme 754: Describes a holding on "consumer" definition for self-employment without any keywords or phrases indicating subsequent judicial treatment (e.g., no "held," "followed," "overruled"). No evidence of how later cases treated it.

                                              Lilavati Kirtilal Mehta Medical Trust VS Unique Shanti Developers - 2020 5 Supreme 497: States principles on "commercial purpose" for purchasing flats without treatment indicators. No references to subsequent decisions or treatment language.

                                              Cheema Engineering Services VS Rajan Singh - 1997 1 Supreme 51: Discusses "commercial purpose" and "self-employment" as a matter of evidence without any treatment keywords or citations to how it was handled later.

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