Consumer Protection Act, 1986 — Section 12 — Agricultural seed failure — Inspection report showing 50% pod development and semi-development in remaining pods — Excess rainfall — No complete deficiency in service — Compensation modified.
Seed quality — Mixed species 8–10% — Semi-development of pods — Impact on market price — Vis major (excess rainfall) considered — Liability apportioned.
National Commission — Restoration of District Forum’s order — Supreme Court partly allowing appeals — Setting aside finding of deficiency of service — Equitable adjustment of compensation.
FACTUAL MATRIX
-
Respondent-farmers purchased groundnut seeds (TAG 37A) on 15.06.2013.
-
Alleged crop failure after 100–120 days.
-
Complaint lodged before Deputy Director (Agriculture).
-
Inspection Committee constituted.
-
District Forum allowed complaints and awarded compensation.
-
State Commission set aside District Forum’s order.
-
National Consumer Disputes Redressal Commission restored District Forum’s order.
-
Appeals filed before the Supreme Court.
KEY FINDINGS FROM INSPECTION REPORT (09.10.2013)
The Committee found:
-
8–10% plants of different species (seed mixture).
-
50% pods fully developed, remaining 50% semi-developed.
-
Crop ripening timeline: 100–110 days.
-
Excess rainfall during July–August.
-
Possibility of:
-
20–25% general shortfall due to rains,
-
40–50% shortfall in TAG37A variety.
-
-
Infection by Tika disease.
-
Good germination overall.
-
Adequate irrigation and soil fertility.
CORE ISSUE
Whether there was deficiency in service attributable to the seed producer/distributor, justifying full compensation as awarded by the District Forum and restored by the NCDRC.
SUPREME COURT’S ANALYSIS
I. Semi-Development ≠ Complete Failure
The Court emphasized:
-
50% pods were completely developed.
-
Remaining 50% semi-developed.
-
Therefore, not total crop failure.
This contradicted the District Forum’s assumption of complete deficiency.
II. Role of Excess Rainfall (Vis Major)
The inspection report acknowledged:
-
Heavy rainfall during relevant period.
-
Significant arboreal growth.
-
Yield shortfall attributable partly to climatic conditions.
Thus, liability could not be wholly fastened on appellants.
III. Deficiency of Service — Not Absolute
The Court inferred:
-
Some irregularity (semi-development, species mixture).
-
But also natural causes.
-
Therefore, finding of complete deficiency of service was unsustainable.
FINAL DIRECTIONS
-
50% of compensation deposited pursuant to interim order (02.08.2021) to be released to farmers with accrued interest.
-
Remaining 50% refunded to appellants with accrued interest.
-
Findings regarding deficiency of service set aside.
-
Appeals allowed in part.
-
Parties to bear own costs.
RATIO DECIDENDI
Where an expert inspection report establishes partial yield (50% full development) and attributes shortfall partly to natural causes such as excess rainfall, a finding of complete deficiency in service under the Consumer Protection Act is unsustainable. Compensation may be equitably apportioned.
SIGNIFICANCE
This judgment underscores:
-
Courts must carefully analyze scientific inspection reports.
-
Agricultural disputes require consideration of climatic factors.
-
Vis major cannot be ignored in seed quality cases.
-
Compensation must be proportionate to proven deficiency.
-
Consumer fora cannot assume total failure when evidence shows partial productivity.
