2025 Supreme(Online)(SCDRC) 39877

STATE CONSUMER DISPUTES REDRESSAL COMMISSION
R. Subbiah, President
M.G.G. Trading Pvt. Ltd. – Appellant
Versus
Mercedes Benz Ind. Pvt. Ltd. – Respondent
C.C. No.242 of 2017

A manufacturer is not liable for an alleged defect in safety features like airbags without cogent, independent expert evidence. Where a technical report provides a reasoned basis for non-activation of safety systems based on collision parameters, the burden of proof rests on the claimant to scientifically disprove such findings.

Headnote:(A) Consumer Protection Act, 1986 - Sections 2(r), 13(1)(c) and 14 - Sale of allegedly defective vehicle - Manufacturer's liability for non-deployment of airbags - Failure to establish manufacturing defect - Held, in the absence of independent expert evidence, the burden of proving a manufacturing defect remains on the consumer - Mere non-deployment of airbags during a collision, without more, does not constitute sufficient proof of inherent defect when contemporaneous technical evidence suggests the impact did not reach the threshold for activation. (Paras 6, 7, 9, 10, 11)

(B) Evidence - Burden of proof - Res ipsa loquitur - Doctrine of res ipsa loquitur applies only where the factual matrix permits a reasonable inference of defect, such as presence of actual injuries or uncontroverted evidence of impact - In the present case, where official record indicates no injury and unchallenged technical report provides a coherent rationale for non-deployment, the doctrine cannot override credible engineering assessment. (Paras 6, 10, 13)

(C) Contract Law - Volenti non fit injuria - Insurance policy - Selection of services - A consumer's voluntary and informed election of an insurance policy precludes subsequent claims of deficiency against the dealer - Mere post hoc dissatisfaction with a choice does not constitute a legally actionable breach. (Paras 8, 12)

Facts of the case:
The complainant alleged that a new vehicle, marketed with sophisticated safety features, suffered from a manufacturing defect because the airbags failed to deploy in a collision, resulting in property loss and personal risk, despite the manufacturer claiming the vehicle was equipped with multiple airbags. The complainant also challenged the dealer's issuance of an insurance policy, claiming it was inferior to the one promised. The manufacturer and dealer contended that the collision was an under-ride impact that did not trigger the specific longitudinal sensor thresholds required for deployment and that the vehicle functioned as designed.

Findings of Court:
The Court held that the manufacturer’s technical report, detailing why the sensor parameters for airbag deployment were not met, remained un-rebutted by the complainant. The complainant failed to exercise the statutory right to have the vehicle independently examined by a notified laboratory and admitted in testimony that the allegation of defect was based on personal perception rather than technical evidence.

Issues: Whether the non-deployment of airbags in an accident proves a manufacturing defect and whether the dealer is liable for providing an insurance policy that the consumer allegedly found inadequate after having voluntarily opted for it.

Ratio Decidendi: A manufacturer cannot be held liable for a systemic defect in safety features solely based on a, consumer's subjective observation. The burden lies on the consumer to prove such a defect, preferably through expert evidence or the statutory mechanism provided for independent testing, especially when there exists an unchallenged technical assessment that explains the system's performance in light of collision dynamics.

Result: Complaint dismissed.