VidhiSangh

Supreme Court of India · 19/03/2026

SANT ROHIDAS LEATHER INDUSTRIES AND CHARMAKAR DEVELOPMENT CORPORATION LTD. versus VIJAYA BANK

[2026] 4 S.C.R. 221 · 2026 INSC 264

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Summary

A State corporation's consumer complaint against a bank, which had adjusted its Rs. 9 crore fixed deposit against an overdraft the corporation said was fraudulently created on a pledge of that deposit, was held not maintainable before the NCDRC. Although merely earning interest on a deposit does not make banking service commercial, the complaint turned on allegations of fraud and forgery fit for a civil or criminal court.

Issues

  1. Whether a body corporate depositing surplus funds in an interest-bearing fixed deposit is a consumer under Section 2(1)(d) of the Consumer Protection Act, 1986.
  2. Whether the allegations of fraud and forged pledge took the complaint outside summary proceedings under the 1986 Act.

Provisions considered

Held

Result

Appeal dismissed; NCDRC's dismissal of the complaint upheld on the ground of non-maintainability, though not entirely for its reasons; dismissal not to bar the appellant from appropriate proceedings before the proper court or forum; no costs.

Judgment PDF: Supreme Court of India, [2026] 4 S.C.R. 221.