RUTU MIHIR PANCHAL & ORS. versus UNION OF INDIA & ORS.

Citation: [2025] 4 S.C.R. 1983 · Decided: 29-04-2025 · Supreme Court of India · Bench: PAMIDIGHANTAM SRI NARASIMHA · Disposal: Disposed off

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Judgment (excerpt)

[2025] 4 S.C.R. 1983 : 2025 INSC 593
Rutu Mihir Panchal & Ors. 
v. 
Union of India & Ors.
(Writ Petition (Civil) No. 282 of 2021)
29 April 2025
[Pamidighantam Sri Narasimha* and Manoj Misra, JJ.]
Issue for Consideration
Constitutionality of ss.34(1), 47(1)(a)(i) and 58(1)(a)(i) of the 
Consumer Protection Act, 2019 prescribing pecuniary jurisdictions 
of the district, state and national commissions on the basis of 
value of goods and services paid as consideration, instead of 
compensation claimed are challenged.
Headnotes†
Consumer Protection Act, 2019 – ss.34(1), 47(1)(a)(i) and 58(1)
(a)(i) – Constitution of India – Art.246 and Entry 95 of List I 
read with Entries 11-A and 46 of List III – Power to determine 
pecuniary jurisdiction:
Held: There is no doubt about the fact that the Parliament has 
the legislative competence to enact the Consumer Protection 
Act, 2019 – Under Entry 95 of List I r/w. Entries 11-A and 46 of 
List III and in exercise of power under Article 246, the Parliament 
has enacted the Consumer Protection Act, 2019 – The legislative 
competence to prescribe jurisdiction and powers of a court, coupled 
with the power to constitute and organize courts for administration 
of justice, takes within its sweep the power to prescribe pecuniary 
limits of jurisdiction of the courts or tribunals – Parliament has 
the legislative competence to prescribe jurisdiction and powers 
of courts – This power extends to prescribing different monetary 
values as the basis for exercising jurisdiction. [Paras 9, 9.1] 
Consumer Protection Act, 2019 – ss.34(1), 47(1)(a)(i) and 58(1)
(a)(i) – Contract Act, 1872 – Constitution of India – Art.14 – 
Whether ss.34, 47 and s.58 are violative of Article 14 of the 
Constitution.
* Author
1984
[2025] 4 S.C.R.
Supreme Court Reports
Held: No – Classification based on value of goods or services 
on the basis of the amount paid as consideration is valid – 
“Consideration” is an integral part of forming any contract – It 
is also an integral part of the definition of a ‘consumer’ – It is in 
recognition of the first principles of formation of a contract that 
s.2(7) of the 2019 Act defines a consumer as any person who buys 
any goods or hires or avails any service for a consideration – The 
consideration could be in the present or future, in whole, part, or 
by deferred payment – Whichever be the mode, there must be a 
consideration – That is essential to be a consumer – Therefore, 
vesting jurisdiction in the district, state or national commission on 
the basis of value of goods or services paid as ‘consideration’, is 
neither illegal nor discriminatory – The determination of jurisdiction 
of the district, state or national commissions on the basis of value 
of consideration paid for purchase of goods and services has 
rational nexus to the object of provisioning hierarchy of judicial 
remedies – The relief or compensation that a consumer could 
claim remained unrestricted and at the same time, access to the 
state or the national commission is also not taken away – It is well 
settled that there is no right or a privilege of a consumer to raise 
an unlimited claim of compensation and thereby chose a forum of 
his choice for instituting a complaint – Thus, the classification of 
claims based on value of goods and services paid as consideration 
has a direct nexus to the object of creating a hierarchical structure 
of judicial remedies through tribunals. [Paras 10.2, 10.4, 11, 11.1]
Contract Act, 1872 – Essentials of a Contract – Discussed. 
[Para 10.3] 
Statute – Performance Audit of the Statute:
Held: Legal reform through legislative correction improves the 
legal system and it would require assessment of the working of 
the law, its accessibility, utility and abuse as well – The Executive 
branch has a constitutional duty to ensure that the purpose and 
object of a statute is accomplished while implementing it – It has 
the additional duty to closely monitor the working of a statute 
and must have a continuous and a real time assessment of the 
impact that the statute is having – Reviewing and assessing the 
implementation of a statute is an integral part of Rule of Law – The 
purpose of such review is to ensure that a law is working out in 
practice as it was intended – If not, to understand the reason and 
[2025] 4 S.C.R. 
1985
Rutu Mihir Panchal & Ors. v. Union of India & Ors.
address it quickly – It is in this perspective that this Court has, in 
a number of cases, directed 

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