Supreme Court Upholds Validity Of Pecuniary Jurisdiction Based On Consideration Value

In an unexpected ruling on April 29, 2025, the Supreme Court of India upheld the constitutionality of provisions of the Consumer Protection Act 2019 that relate to the consumer forum's pecuniary jurisdiction, which is determined by the values of goods or services paid but does not necessarily include the full amount of compensation claimed. This really sounds like a directive from above that the legislators have purposively created a structured rather than an ad-hoc system for an efficient redressal mechanism for disputes concerning consumers.

Background of the Case

• The case arose under Article 32 of the Constitution by way of writ petition Rutu Mihir Panchal and others vs Union of India and others (WP(C) 282/2021). The petitioners, who are legal heirs of a man now deceased brought about a controversy regarding the grounds of his death that were apparently caused by a fire in a car after allegedly being brought on by a manufacturing flaw in a ₹44 lakh Ford Endeavour. They demanded damages exceeding ₹50 crores before the National Consumer Disputes Redressal Commission (NCDRC). The NCDRC, however, rejected the case, concluding that the amount of the consideration paid (₹44 lakhs) did not meet the ₹2 crore threshold.
• The plaintiffs challenged the constitutional validity of Sections 34, 47, and 58 of the Consumer Protection Act, 2019, arguing that these provisions created an absurd classification which was violative of Article 14 (Right to Equality).

Supreme Court's Observations and Ruling

A two-judge panel consisting of Justices Manoj Misra and P.S. Narasimha rejected the constitutional claim. Disposing of the judgment, Justice Narasimha proclaimed that provisions challenged were not arbitrary and violative of Article 14.

Key Observations:

1.Classification Based on Consideration Is Valid: The Court confirmed that jurisdiction depending on the value of consideration paid rather than the compensation claimed is both very reasonable and logical. It stated:

" Consideration value is and may be a legitimate criterion for categorizing claims in order to establish pecuniary jurisdiction."

2. Rationale of Classification: The Court found rational nexus between the classification and the object of the statute creating the hierarchy of consumer dispute redressal infrastructures: 

"Compared to a self-assessed claim for damages, the value of consideration given for goods or services is closer and easier to relate to compensation."

3. No Discrimination or Arbitrariness: The Court specified that these provisions do not induce a discriminatory treatment but, rather, further provide that cases are referred correctly to the forums according to objective criteria.

4. Functional Concerns Acknowledged: The Court preserving the provision also recognized certain operational problems and directed the Central Consumer Protection Council and the Central Consumer Protection Authority to take proactive steps under Sections 3, 5, 10, and 18-22 of t.

Statutory Framework of Pecuniary Jurisdiction

The following is the financial jurisdiction of the Consumer Protection (Jurisdiction of the District Commission, the State Commission, and the National Commission) Rules, 2021:

• District Commission: Claims where less than ₹50 lakh was paid in consideration 
• State Commission: Claims under ₹2 crore and for a deliberation period of ₹50 lakh 
• National Commission: Claims above ₹2 crore.

This shift from evaluating jurisdiction based on amount of claim (as per earlier Act of 1986) to actual amount paid is intended to prevent forum shopping and facilitate important case backlogs.

Arguments Raised by the Petitioners

• The petitioners argued that moving to a consideration basis where lower price would lead to lower-level commission cases for high dollar value damages has resulted in anomalies and arbitrary classifications violating Article 14. 
• But the Court did not accept this argument, stating the worth of the goods or services is much more objective and consistent measure than self-assessed damages which can be inflated arbitrarily.

The Supreme Court's decision has made it clear and unequivocal how pecuniary jurisdiction will be assessed under the 2019 Consumer Protection Act. The constitutional validity of classification based upon consideration paid has been reaffirmed to further fortify the capital intent of establishing a tiered and efficient consumer grievance redresser system. The judgment acknowledges the imperative of better access to implementation, coupled with reasonable and practicable legal classifications that have significance in ensuring access to justice. 

This ruling serves as a reminder that public interest judicial efficiency must be dovetailed by objective standards and statutory intent when appraising constitutional challenges within emerging legal frameworks.

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