VidhiSangh

Supreme Court of India · 23/07/2020

UNION OF INDIA & ANR. versus N. R. SRIVASTA & ORS.

[2020] 6 S.C.R. 1 · 2020 INSC 462

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Summary

The Court declined to disturb a Rs.2 lakh consumer award against Safdarjung Hospital given the small amount and the inadequate factual foundation for resolving its jurisdictional objection. It expressly left open whether the hospital fell within the Consumer Protection Act and whether the National Commission could reverse an unchallenged finding in revision using powers analogous to appellate relief. The National Commission’s judgment was confined to the case and barred from citation as precedent; payment was directed within two months.

Issues

  1. Whether the appeal warranted intervention over the Rs.2 lakh award.
  2. Whether consumer jurisdiction over Safdarjung Hospital and the Commission’s revisional powers should be conclusively decided.

Provisions considered

Held

Result

Appeal dismissed subject to express clarifications reserving jurisdictional and revisional-power issues. National Commission judgment confined to the facts and not citable as precedent; Rs.2 lakh payable within two months of receipt of certified copy.

Judgment PDF: Supreme Court of India, [2020] 6 S.C.R. 1.