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2026 Supreme(Online)(SCDRC) 12163

STATE CONSUMER DISPUTES REDRESSAL COMMISSION
Pawan Kumar Singla – Appellant
Versus
Liberty General Insurance Ltd. – Respondent
RA-25/2026|FA-213/2024



Important Points

Review jurisdiction under Section 50 of the Consumer Protection Act, 2019 is restricted to errors apparent on the face of the record; personal hardships of a counsel do not justify prolonged inaction or provide grounds for review if no such error exists.

Subject

Civil - Consumer Protection

Act Referred

Headnote

(A) Review Jurisdiction - Error Apparent on Record - The power of the State Commission to review its own order under Section 50 of the Consumer Protection Act, 2019, is limited to cases where there is an error apparent on the face of the record. (Para 11)

(B) Non-Prosecution - Professional Negligence/Personal Hardship - Continued inaction and failure to comply with repeated court directions for filing necessary applications (such as condonation of delay) cannot be excused solely by attributing the failure to the personal difficulties or emotional distress of the counsel; the party must demonstrate due diligence. (Para 13, 14)

Issues: Whether the order dismissing the appeal for non-prosecution could be reviewed on the grounds of the counsel's personal grievances and subsequent inaction.

Legal Category Hierarchy

  • practice and procedure
    • review
      • error apparent on record
    • dismissal for non-prosecution
    • condonation of delay
  • consumer law
    • consumer protection act 2019
      • section 50

Advocates:
For the Appellants/Petitioners: D.K. Sinha

07.09.2026

RA-25/2026 IN FA-213/2024

ORDER

The Applicant has preferred theReview Application against the order dated 25.03.2026 passed in FA-213/2024, whereby this Commission has dismissed the Appeal of the Applicant/Appellant for non-prosecution. The relevant portion of the order dated 25.03.2026 has been reproduced below for the ready reference herein:

“25.03.2026

Order dated 30.01.2026 passed by the Deputy Registrar is perused.

A perusal of order dated 02.04.2024 shows that the appeal was filed by the appellant without proper index and therefore the counsel for the appellant was directed to do the needful and the matter was adjourned for 09.04.2024.

But the appellant did not comply with order dated 02.04.2024 and therefore on 09.04.2024, the appellant was again directed to comply with order dated 02.04.2024 and the matter was adjourned for 16.04.2024.

But the appellant did not comply with order dated 02.04.2024 as well as 09.04.2026, hence, vide order dated 16.04.2024, the appellant was again directed to comply with the said order and the matter was adjourned for 04.07.2024.

However, the proper index was not filed by the appellant and vide order dated 04.07.2024, the appellant was again directed to comply with order dated 02.04.2024 and the matter was adjourned for 29.08.2024.

But again the appellant did not comply with the said order and was again directed on 18.09.2024 to comply with the said order dated 02.04.2024.

A perusal of record further shows that on 24.10.2024, learned counsel for the appellant submitted that the proper indexing of the file was done by him in compliance of order dated 02.04.2024.

A perusal of order dated 24.10.2024 further shows that an IA No.894/2024 moved by the appellant seeking condonation of delay in filing the revision was filed instead of an application seeking condonation of delay in filing the appeal.

Since there was a typographical error in IA No. 894/2024, learned counsel for the appellant wished to file another application in this regard within a week.

But the appellant did not comply with the said order and did not fileapplication for condonation of delay in filing the appeal.

Vide order dated 11.11.2024, 09.01.2025, 17.02.2025, 01.04.2025, 01.05.2025 and 19.09.2025 the appellant was again directed to comply with the order dated 24.10.2024.

A perusal of record further shows that till date the appellant has not moved application for condonation of delay in filing the appeal despite various opportunities granted by this Commission.

Learned counsel for the appellant submits that two weeks' time be given to him to file application for condonation of delay in filing the appeal.

Since various opportunities have granted to the appellant to file application for condonation of delay and the appellant is not serious to comply with the orders passed by this Commission and did not move any application in this regard till today, therefore, we find no ground to grant further time to the appellant to move the application.

We are of the considered view that the appellant is not interested inpursuing this appeal.

Hence, FA No. 213/2024 is dismissed for non-prosecution.

File be consigned to record room.”

The Applicant has filed the present Review Application seeking review and recall of the order dated 25.03.2026, primarily on the ground that the non-appearance of the counsel was occasioned by the prolonged illness of his mother, which commenced in September 2022 and ultimately resulted in her demise in Canada on 19.08.2023. It is further submitted that, following the demise of his mother, the counsel suffered from depression and owing to his mental and emotional condition, he was unable to properly attend to and represent the case of the Applicant before the District Commission as well as before this Commission. Pressing the aforesaid, the counsel for the Applicant prayed for the review and recall of the order dated 25.03.2026.

We have perused the material available on record.

To deal with the pre

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