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Legal Notice under Sections 2(10), 2(21), 2(47) & 39

of the Consumer Protection Act, 2019**

1. Section 2(10) – “Consumer”

Meaning:
A consumer is a person who:

  • Buys goods or hires/avails services for consideration
  • Includes online, e-commerce, teleshopping purchases
  • Does not include goods/services taken for resale or commercial purpose (except self-employment)

Purpose in Legal Notice:
To establish that the complainant legally qualifies as a consumer under the Act.


2. Section 2(21) – “Deficiency”

Meaning:
Any fault, imperfection, shortcoming or inadequacy in:

  • Quality
  • Nature
  • Manner of performance
  • Service promised by law or contract

Examples:

  • Delay in delivery
  • Poor service
  • Non-refund
  • Incomplete work

Purpose in Legal Notice:
To prove deficiency in service by the opposite party.


3. Section 2(47) – “Unfair Trade Practice”

Meaning:
Any unfair or deceptive practice, including:

  • False representation
  • Misleading advertisements
  • Charging excess price
  • Concealment of material facts

Purpose in Legal Notice:
To show that the service provider indulged in fraudulent or misleading conduct.


Section 39 – Reliefs Available to Consumer

Consumer Commission may order:
✔ Removal of defects
✔ Replacement of goods
✔ Refund of amount paid
✔ Compensation for loss/mental agony
✔ Discontinuation of unfair trade practice
✔ Withdrawal of misleading advertisement
✔ Punitive damages (where applicable)

Purpose in Legal Notice:
To formally demand reliefs and warn of legal action before filing a consumer complaint.


Why This Legal Notice Is Issued

  • To give the service provider one final opportunity to resolve the dispute
  • To comply with principles of natural justice
  • To avoid litigation if settlement is possible

Common Situations Where This Notice Is Used

  • Builder–buyer disputes
  • Online shopping fraud
  • Defective products
  • Insurance claim rejection
  • Medical negligence
  • Travel & hospitality disputes
  • Coaching institute fraud

Standard Closing Line (Sample)

If you fail to comply within 15 days, my client shall be constrained to initiate appropriate proceedings before the Consumer Commission at your sole risk, cost, and consequences.

CASE LAWS SUPPORTING CONSUMER LEGAL NOTICE

(CPA, 2019 – Definitions, Deficiency & Reliefs)


1. Who is a “Consumer” – Section 2(10)

Laxmi Engineering Works v. P.S.G. Industrial Institute

(1995) 3 SCC 583 – Supreme Court

✔ Held that:

  • A person purchasing goods/services for self-use or livelihood is a consumer
  • Commercial purpose must be interpreted narrowly

Use in Notice:

Establishes complainant’s status as a “consumer”.


Kavita Ahuja v. Shipra Estates Ltd.

I (2016) CPJ 31 (NC)

✔ Buyer of flat is a consumer
✔ Delay/defects amount to deficiency

Useful for: Builder-buyer disputes


2. Deficiency in Service – Section 2(21)

Lucknow Development Authority v. M.K. Gupta

(1994) 1 SCC 243 – Supreme Court

✔ Deficiency includes:

  • Delay
  • Negligence
  • Harassment
  • Mental agony

Landmark case – most cited in consumer notices


Haryana Urban Development Authority v. Raje Ram

(2008) 17 SCC 407

✔ Failure to deliver promised service = deficiency
✔ Compensation is justified


Ghaziabad Development Authority v. Balbir Singh

(2004) 5 SCC 65

✔ Consumer Commissions can grant:

  • Compensation
  • Interest
  • Mental agony damages

3. Unfair Trade Practice – Section 2(47)

Skypak Couriers Ltd. v. Tata Chemicals Ltd.

(2000) 5 SCC 294

✔ Misrepresentation & false assurances = unfair trade practice
✔ Disclaimers cannot override consumer rights


DLF Ltd. v. Mridul Estate Pvt. Ltd.

(2013) 14 SCC 22

✔ One-sided terms & misleading promises are unfair trade practices

Use when:

  • Hidden charges
  • False advertising
  • One-sided contracts

4. Reliefs by Consumer Commission – Section 39

Charan Singh v. Healing Touch Hospital

(2000) 7 SCC 668 – Supreme Court

✔ Compensation must:

  • Redress injury
  • Deter wrongdoing
  • Be realistic & just

Spring Meadows Hospital v. Harjol Ahluwalia

(1998) 4 SCC 39

✔ Compensation can be awarded for:

  • Mental agony
  • Harassment
  • Negligent service

5. Online / E-commerce Consumers Covered

Amazon Seller Services Pvt. Ltd. v. Amrita Nanda

2022 (NC)

✔ Online buyers are consumers
✔ Platform liability recognised

Very relevant for e-commerce disputes


HOW TO CITE IN LEGAL NOTICE (Sample Line)

“The acts of your client squarely fall within the definition of ‘deficiency in service’ under Section 2(21) of the Consumer Protection Act, 2019 as laid down by the Hon’ble Supreme Court in Lucknow Development Authority v. M.K. Gupta (1994) 1 SCC 243…”

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