Torts - Consumer Protection Act, 1986

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Law OF

TORTS- II

SANA
WASIM
B.A. L.L.B. (HONS.)
IIND SEMESTER

Acknowledgement
I would like to express my heartfelt gratitude towards our Contracts professor
Dr. Eqbal Hussain for being a constant pillar of support and strength and
rendering us with invaluable information that assisted us in making of this
project.

CONSUMER
PROTECTION
ACT, 1986

Index
1. Introduction
2. Need for Consumer Protection
3. Objectives of the Consumer Protection Act

4. Relevant Provisions of the Act


5. Important Definitions
6. Consumer Law Protection in Torts
7. Consumerism
8. The Prevention of Food Adulteration, 1954
9. Drugs & Cosmetics Act, 1940
10. Consumer Protection Council
11. Remedies Under the Act
12. Appeal
13. Limitation Period
14. Penalties
15. References

INTRODUCTION
The Consumer Protection Act, 1986 is a milestone in the history of socioeconomic legislation in India. It is one of the most progressive and
comprehensive regulations formulated to safeguard the interest of a small
consumer in the country. It was enacted after an in-depth study of consumer
protection laws in several countries, and in consultation with representatives of

consumer-bodies, trade and industry, and extensive discussions within the


government. The Act attempts to give consumers complete protection from
malpractices of manufacturers, producers, suppliers, wholesalers and retailers.
The Act is designed to make quick cheap and speedy justice to the complaints of
a common consumer. All the provisions of the Act came into force from 1 July
1987. The Act extends to the whole of India except the State of Jammu and
Kashmir. The Act was amended in 1991 and 1993 for addressing certain
loopholes. Furthermore, to make the Consumer Protection Act more functional
and purposeful, a comprehensive amendment was introduced in December
2002, and brought into force from 15 March 2003. As a sequel, The Consumer
Protection Rules, 1987 were also amended and notified on 5 March 2004.
Remedy for consumers under this Act is through an effective three-tier quasijudicial mechanism comprising the district forums at the grass roots, state
commissions at the state level and the National commission located at Delhi at
its apex. At present there are 35 State Commissions, one in each State or Union
territory and 571 district Forums. The State Governments are accountable for
setting up the district forums and the State commissions. The Government of
India has declared 24th November as National Consumer Day as it was on that
day then president of India had given his assent to the enactment of this historic
Act. Besides this, 15 March is observed as World Consumer Rights Day.

SALIENT FEAURES OF THE ACT


The act applies to all goods and services unless specifically exempted by
the central Government.
It covers all the sectors- private, public and cooperative
The provisions of this act are chiefly compensatory in nature.
It seeks to confer upon the consumer the following six rights
i. Right to safety
ii. Right to be informed
iii. Right to choose
iv. Right to be heard
v. Right to seek redressal, and
vi. Right to consumer Education

The Act also envisages establishment of consumer protection councils at


the central, state and district levels, whose main objectives will be to
promote and protect the rights of consumers
To provide a simple, speedy, and inexpensive redressal of consumer
grievances, the Act envisages three-tier quasi-judicial machinery at the
national, state, and district levels. These are- National Consumer Disputes
Redressal Commissions known as State Commissions and District
Consumer Disputes Redressal Forums known as District Forums
Engagement of an advocate is not mandatory to file a complaint under the
Consumer Protection Act.

Need for
consumer
protection
In order to maximise profits, many businessmen exploit consumers by
supplying poor quality goods at higher prices. They adopt unfair trade practices
such as adulteration, boarding, black-marketing, etc.
As a result consumers do not get value for their money. Big business houses use
their power for private gain and to the detriment of consumers. Consumers are
exposed to physical, environmental and other hazards.

They need to be protected from spurious, duplicate and adulterated products,


pollution of air, water and noise, and misleading advertising.
Consumers need protection due to the following reasons:
1. Illiteracy and ignorance:
Consumers in India are mostly illiterate and ignorant. They do not understand
their rights. A system is required to protect them from unscrupulous
businessmen.
2. Unorganised consumers:
In India consumers are widely dispersed and are not united. They are at the
mercy of businessmen. On the other hand, producers and traders are organised
and powerful.
3. Spurious goods:
There is increasing supply of duplicate products. It is very difficult for an
ordinary consumer to distinguish between a genuine product and its imitation.
He pays the price for the original but gets a substandard product. It is necessary
to protect consumers from such exploitation.
4. Deceptive advertising:
Some businessmen give misleading information about quality, safety and utility
of products. Consumers are misled by false advertisement and do not know the
real quality of advertised goods. A mechanism is needed to prevent misleading
advertisements.
5. Malpractices of businessmen:
Fraudulent, unethical and monopolistic trade practices on the part of
businessmen lead to exploitation of consumers. Consumers often get defective,
inferior and substandard goods and poor service.
Certain measures are required to protect the consumers against such
malpractices. Greedy businessmen indulge in adulteration, boarding, blackmarketing and other illegal practices.
6. Freedom of enterprise:
Businessmen must ensure satisfaction of consumers. In the long run survival
and growth of business is not possible without the support and goodwill of

consumers. If business does not protect consumer's interests. Government


intervention and regulatory measures will grow to curb unfair trade practices.
Thus, consumers need protection against the following:
(a) Unsafe and harmful products,
(b) Unfair trade practices,
(c) False advertising,
(d) Abuse of monopoly power,
(e) Environmental pollution.

OBJECTIVES OF
THE CONSUMER
PROTECTION
ACT

To provide for the better protection of the interest of the consumer


To establish the consumer protection council at centre, state and district
level
To provide for the establish quasi-judicial authorities for the settlement of
consumer disputes
District forum, State commission and National commission are the main
platforms for filing the case

The act was amended in 1991, 1992 and 2002

To provide certain important scheduled commodities to the ration card


holders at reasonable rates at prescribed quantum.
To indirectly control open market prices of certain commodities.
To protect the interests of consumers through enforcement of Weights &
Measures Act and rules there under
To implement Minimum Support Price Scheme of the Central
Government to safeguard farmer's interests
Matters incidental and supplementary to the above objectives

To promote & protect the rights of consumers by theway of


implementation of Consumer Protection Act.

Relevant
provisions of
the act
Section 1(4)

Save as otherwise expressly provided by the central


government by notifications, this act shall apply to all goods
and services.

SECTION 3
ACT Not in DEROGATION OF ANY OTHER LAW
The provision of this act shall be in addition to and not in
derogation of the provisions of any other law for the time
being in force.
COMMENTS
The provision of the act are in addition and not in derogation
of the provisions of any other law for the time being in force.
Manifestly, provisions of the Act grant additional remedy to
the consumers but where the remedy itself is barred by some
provisions of some other act then the remedy which the
consumer prays cannot be granted by the various forums
constituted under the act

Presidency Post Master v. Dr. V. Shanker Rao 1993 (2)


CPJ 141
Where the additional rights and remedies are granted to the
consumers by the act itself, courts are not to interpret the
same in such a manner as to cut and abridge the scope
thereof. Rights and remedies under the Act cannot be curbed
either by Statutory arbitration provision contained in an
earlier law or by some arbitration agreement entered into by
the parties themselves. If that is not so, not only the scope of
the Act would be entailed but by introducing arbitration

clause whole of the act would be rendered inapplicable


Jagdamba Rice Mills v. Union of India 1991( 1) CPJ 273

Important
definitions
Consumer of goods
1. Any person who buys any good for a consideration and
2. Includes any user of such goods with approval of the buyer

Consumer of Services
1. Any person which hires any services for a consideration
2. Includes any beneficiary of such services availed of with the approval of
the hirer.

Goods
The expression goods has been defined with reference to its definition under
the Sales Of Goods Act 1913
(1) The goods which form the subject of a contract of sale may be either
existing goods, owned or
possessed by the seller, or future goods.
(2) There may be a contract for the sale of goods the acquisition of which by the
seller depends upon
a contingency which may or may not happen.
(3) Where by a contract of sale the seller purports to effect a present sale of
future goods, the contract operates as an agreement to sell the goods.

SERVICES
Services means any description which is made available to potential user
There are two parts in sevices1. INCLUSIONARY PART
Services includes but not limited to the provision of facilities in connection with
banking, financing, insurance, transport, processing, supply of electrical, or
other energy, boarding or lodging or both, housing construction, entertainment,
amusement or purveying of news or other information.

2. EXCLUSIONARY PART
Service does not include

The rendering if any service free of charge, or


Under a contract of personal services
CONTRACT OF SERVICE
It implies relationship of master and servant.
Contract for service
It implies a contract where there is no master servant relationship.

Indian medical association v. V.P. Shantha AIR 1996 SC 550.


Samira Kholi v. Prabha Manchanda AIR 2008 SC 1385 (patient
consent as defence)

Consumer dispute
Where a person against who and whom a complaint made denies
allegation.

Complaint
Its means an allegation in writing as
Unfair/ restricted trade practices adopted by trader service
provider.
Goods bought suffer defect
Services hired suffered deficiency
Trader charges excessive price than fixed

Goods hazardous to life ordered for sale


Hazardous services

CONSUMER LAW
PROTECTION IN
TORTS
In addition to the remedies under contract and criminal law, consumers have
rights under tort law. Based on its numerous legal intricacies, however, tort law
is not the ideal remedy for injured consumers in India. For example, the
traditional doctrine of negligence imposes heavy responsibility on the plaintiff
to prove each of its required elements. These traditional legal requirements
naturally encourage injured consumers to pursue legal remedies under different
laws.53 Not surprisingly, it is estimated that for about half a century from 1914
to 1965, only 613 tort cases came before the appellate courts.The orthodox legal
requirements under the law of torts and contracts forced the policy makers to

craft specific legislation to protect consumers. As a result, the Consumer


Protection Act of 1986 was enacted with the objective of providing cheap,
simple and quick justice to Indian consumers.

Consumerism
Consumerism is a movement or policies aimed at regulating the products or
services, methods or standards of manufacturers, sellers and advertisers in the
interest of buyers, such regulation maybe institutional, statutory or embodied in
a voluntary code occupied by a particular or it may result more indirectly from
the influence of consumer organisation. The principle of Caveat emptor
relieved the seller of the obligation to make disclosure about the quality of the
product. In addition, the personal relation between the buyer and the seller was
one of the major factors in their relations. But with the growth of trade and its
globalization the rule no more holds true. It is now impossible for the buyer to
examine the goods beforehand and most of the transactions are conclude by
correspondence. Further on account of complex structure of the modern goods,
it is only the producer/seller who can assure the quality of goods. With
manufacturing activity becoming more organized, the producers/sellers are
becoming stronger and organized whereas the buyers are still weak and
unorganized. In the age of revolutionized information technology, Internet and
with the emergence of e-commerce and m-commerce related innovations the
consumers are further deprived to a great extent. As a result buyer is being
misled, duped and deceived day in and day out.
Consumerism is in its infancy in our country, thanks to the sellers market and
the Government monopoly in most services. Consumer awareness is low due to

the apathy and lack of education among the masses. No one has told them about
their rights- to be informed about product quality, price, protection against
unsafe products, access to variety of goods at competitive prices, consumer
education etc. What consumers lack here are education and information
resources, testing facilities, competent leadership, price control mechanism, and
adequate quasi-judicial machinery. The providers of goods and services have
been reluctant to give due consideration to consumer interest protection.
Some business in India have come together to adopt a code of conduct for
regulating their own activities. Regulation of business through legislation is one
of the important means of protecting the consumers. Consumerism has over the
time developed into a sound force designed to aid and protect the consumer by
exerting legal, moral and economic pressure on producers and providers in
some of the developed countries. The success of consumerism lies in the
realization of the business that there is no substitute for voluntary selfregulations. Little attention from the business will not only serve consumers
interest but will also benefit them. The best possible solution is that the
Consumers must be aware of their rights, join voluntary Consumer
organizations, raise voice against exploitation and seek redress of their
grievances in time.

THE
PREVENTION
OF FOOD
ADULTERATION
ACT, 1954
INTRODUCTION
Food is one of the basic necessities for sustenance of life. Pure, fresh and
healthy diet is most essential for the health of the people. It is no wonder to say
that community health is national wealth.
Adulteration of food-stuffs was so rampant, widespread and persistent that
nothing short of a somewhat drastic remedy in the form of a comprehensive
legislation became the need of the hour. To check this kind of anti-social evil a
concerted and determined onslaught was launched by the Government by
introduction of the Prevention of Food Adulteration Bill in the Parliament to
herald an era of much needed hope and relief for the consumers at large.

STATEMENT OF OBJECTS AND


REASONs
Laws existed in a number of States in India for the prevention of
adulteration of food- stuffs, but they lacked uniformity having been passed at
different times without mutual consultation between States. The need for

Central legislation for the whole country in this matter has been felt since 1937
when a Committee appointed by the Central Advisory Board of Health
recommended this step. Adulteration of food-stuffs and other goods is now
included in the Concurrent List (III) in the Constitution of India. It has,
therefore, become possible for the Central Government to enact an all India
legislation on this subject. The Bill replaces all local food adulteration laws
where they exist and also applies to those States where there are no local laws
on the subject. Among others, it provides for
(i) a Central Food Laboratory to which food samples can be referred to for final
opinion in disputed cases (clause 4),
(ii) a Central Committee for Food Standards consisting of representatives of
Central and State Governments to advise on matters arising from the
administration of the Act (clause 3), and
(iii) the vesting in the Central Government of the rule-making power regarding
standards of quality for the articles of food and certain other matters (clause 22).

ACT 37 OF 1954
The Prevention of Food Adulteration Bill was passed by both the house of
Parliament and received the assent of the President on 29th September, 1954. It
came into force on Ist June, 1955 as THE PREVENTION OF FOOD
ADULTERATION ACT, 1954 (37 of 1954).

Drugs and
cosmetics Act,
1940
INTRODUCTION
In 1937 a Bill was introduced in the Central Legislative Assembly to give effect
to the recommendations of the Drugs Enquiry Committee to regulate the import
of drugs into British India. This Bill was referred to the Select Committee and
the Committee expressed the opinion that a more comprehensive measure for
the uniform control of manufacture and distribution of drugs as well as of
imports was desirable. The Central Government suggested to the Provincial
Governments to ask the Provincial Legislatures to pass resolutions empowering
the Central Legislature to pass on Act for regulating such matters relating to
control of drugs as fall within the Provincial sp here. Provincial Governments
got the resolution passed from the Provincial Legislatures and sent them to the
Central Government for getting through the Bill to regulate the import,
manufacture, distribution and sale of Drugs and Cosmetics. Thereupon the
Drugs and Cosmetics Bill was introduced in the Central Legislative Assembly.

STATEMENT OF OBJECTS AND


REASONS

1. In order to give effect to the recommendations of the Drugs Enquiry


Committee,, in so far as they relate to matters with which the Central
Government is primarily concerned, a Bill to regulate the import of drugs into
British India was introduced in the Legislative Assembly in 1937. The Select
Committee appointed by the Legislative Assembly was of the opinion that a
more comprehensive measure providing for the uniform control of the
manufacture and distribution of drugs as well as of import was desirable. The
Government of India accordingly asked Provincial Governments to invite the
Provincial Legislatures to pass resolutions under section 103 of the Government
of India Act, 1935, empowering the Central Legislature to pass an Act for
regulating such matters relating to the control of drugs as fall within the
Provincial Legislative List. Such resolutions have now been passed by all
Provincial Legislatures.
2. Chapter II of the Bill establishes a Board of Technical Experts to advise the
Central and Provincial Governments on technical matters.
3. Chapter III provides for the control of the import of drugs into British India.
The executive power under this chapter will accordingly be exercised by the
Central Government.
4. Chapter IV relates to control of the manufacture, sale and distribution of
drugs and contains the provisions which it is proposed should be enacted in
exercise of the powers conferred by the resolutions under section 103 of the
Government of India Act passed by the Provincial Legislatures. The executive
power under Chapter IV will be exercised by the Provincial Government.
5. The First Schedule prescribes the standards to be complied with by imported
drugs and the Second Schedule prescribes the standards to be complied with the
drugs manufactured, sold or distributed in India. The standards prescribed in the
two Schedules are identical. The Central Government will have power to amend
the First Schedule, but power to amend the Second Schedule will rest with
Provincial Government.
6. The Government of India have considered to what extent provision can be
made to secure the maintenance of unformity in standards and in other
important matters in which uniformity is desirable. They understand that it
would be ultra vires of Central Legislature to assign to any authority other than
the Provincial Government's authority conferred by the Bill in respect of matters

falling within the Provincial Legislative field. For this reason it is not possible
to assign the power to fix standards and to make rules to any single authority. In
order to assure that before any action is taken due consideration is given to the
desirability of maintaining uniformity, provision has been made in Chapter VI
for a single Technical Advisory Board which both Central and Provincial
Government will be required to consult before modifying the standards set up
by the Bill or before making rules under the Bill.

ACT 23 OF 1940
The Drugs and Cosmetics Bill was passed by the Central Legislative Assembly
and it received the assent of the Governor General on 10th April, 1940 and thus
became the Drugs and Cosmetics Act, 1940 (23 of 1940).
LIST OF AMENDING ACTS AND ADAPTATION ORDERS
1. The Repealing and Amending Act, 1949 (40 of 1949).
2. The Adoption of Laws Order, 1950
3. The part B States (Laws) Act, 1951 (3 of 1951).
4. The Drugs (Amendment) Act, 1955 (11 of 1955).
5. The Drugs (Amendment) Act, 1960 (35 of 1960).
6. The Drugs (Amendment) Act, 1962 (21 of 1962).
7. The Drugs and Cosmetics (Amendment) Act, 1964 (13 of 1964).
8. The Drugs and Cosmetics (Amendment) Act, 1972 (19 of 1972).
9. The Drugs and Cosmetics (Amendment) Act, 1982 (68 of 1982).
10. The Drugs and Cosmetics (Amendment) Act, 1986 (71 of 1986).

CONSUMER
PROTECTION
COUNCIL
Central Consumer Protection Council
It is established by the Central Government which consists of the following
members:

The Minister of Consumer Affairs, Chairman, and


Such number of other official or non-official members representing such
interests as may be prescribed.

State Consumer Protection Council


It is established by the State Government which consists of the following
members:

The Minister in charge of consumer affairs in the State Government


Chairman.

Such number of other official or non-official members representing such


interests as may be prescribed by the State Government.

such number of other official or non-official members, not exceeding ten,


as may be nominated by the Central Government.

The State Council is required to meet as and when necessary but not less than
two meetings every year.

CONSUMER DISPUTE REDRESSAL


AGENCIES

District Consumer Disputes Redressal Forum (DCDRF): Also known as


the "District Forum" established by the State Government in each district of
the State. The State Government may establish more than one District
Forum in a district. It is a district level court that deals with cases valuing up
to 2 million (US$37,000).

State Consumer Disputes Redressal Commission (SCDRC): Also known


as the "State Commission" established by the State Government in the State.
It is a state level court that takes up cases valuing less than 10 million
(US$180,000)

National Consumer Disputes Redressal Commission (NCDRC):


Established by the Central Government. It is a national level court that
works for the whole country and deals with amount more than 10 million
(US$180,000).

OBJECTIVES
Objectives of Central Council
The objective of the Central Council is to promote and protect the rights of the
consumers such as:a) the right to be protected against the marketing of goods and services which
are hazardous to life and property.
b) the right to be informed about the quality, quantity, potency, purity,
standard and price of goods or services, as the case may be so as to protect the
consumer against unfair trade practices.
c) the right to be assured, wherever possible, access to a variety of goods and
services at competitive prices.
d) the right to be heard and to be assured that consumer's interests will receive
due consideration at appropriate forums.
e) the right to seek redressal against unfair trade practices or restrictive trade
practices or unscrupulous exploitation of consumers; and
f) the right to consumer education.

Objectives of State Council


The objects of every State Council shall be to promote and protect within the
State the rights of the consumers laid down in clauses (a) to (f) in central
council objectives.
[

JURISDICTION

1.Jurisdiction of District Forum


a)

PECUNIARY JURISDICTION
Subject to the other provisions of this Act, the District Forum shall have
jurisdiction to
entertain complaints where the value of the goods or services and the
compensation, if any, claimed does not exceed rupees twenty lakhs.
b) TERRITORIAL JURISDICTION
A complaint shall be instituted in a District Forum within the local limits of
whose jurisdiction:a) the opposite party or each of the opposite parties, where there are more than
one, at the time of the institution of the complaint, actually and voluntarily
resides or carries on business or has a branch office or personally works for
gain, or
b) any of the opposite parties, where there are more than one, at the time of
the institution of the complaint, actually and voluntarily resides, or carries on
business or has a branch office, or personally works for gain, provided that in
such case either the permission of the District Forum is given, or the acquiesce
in such institution of the suit, of such of the opposite parties who do not reside,
or carry on business or have a branch office, or personally work for gain, as the
case may be, or
c) the cause of action, wholly or in part, arises.

2.Jurisdiction of state council

1) Subject to the other provisions of this Act, the State Commission shall have
jurisdiction:a) to entertain
i) complaints where the value of the goods or services and compensation, if
any, claimed exceeds rupees twenty lakhs but does not exceed rupees onecrore;
and
ii) appeals against the orders of any District Forum within the State; and
b) to call for the records and pass appropriate orders in any consumer dispute
which is pending before or has been decided by any District Forum within the
State, where it appears to the State Commission that such District Forum has
exercised a jurisdiction not vested in it by law, or has failed to exercise a
jurisdiction so vested or has acted in exercise of its jurisdiction illegally or with
material irregularity.

3.Jurisdiction of National Council


Subject to the other provisions of this Act, the National
Commission shall have jurisdiction
i) complaints where the value of the goods or services and compensation, if any,
claimed exceeds rupees one crore; and
ii) appeals against the orders of any State Commission

a) to call for the records and pass appropriate orders in any consumer dispute
which is pending before or has been decided by any State Commission where it
appears to the National Commission that such State Commission has exercised
a jurisdiction not vested in it by law, or has failed to exercise a jurisdiction so
vested, or has acted in the exercise of its jurisdiction illegally or with material
irregularity.

Remedies under
the Act
Remedies Granted Under Consumer Protection Act, 1986
The District Forum / State Commission / National Commission may pass one or
more of the following orders to grant relief to the aggrieved consumer :1. to remove the defects pointed out by the appropriate laboratory from goods in
question;
2. to replace the goods with new goods of similar description which shall be
free from any defect;
3. to return to the complainant the price, or, as the case may be, the charges paid
by the complainant;
4. to pay such amount as may be awarded by it as compensation to the
consumer for any loss or injury suffered by the consumer due to negligence of
the opposite party;
5. to remove the defects or deficiencies in the services in question;
6. to discontinue the unfair trade practice or the restrictive trade practice or not
to repeat them;

7. not to offer the hazardous goods for sale:


8. to withdraw the hazardous goods from being offered for sale:
9. to provide for adequate costs to parties.

Appeal
Any person aggrieved by an order made by the District Forum may prefer an
appeal against such order to the State Commission within a period of thirty days
from the date of the order, in such form and manner as may be prescribed:
PROVIDED that the State Commission may entertain an appeal after the expiry
of the said period of thirty days if it is satisfied that there was sufficient cause
for not finding it within that period

Limitation period
1) The District Forum, the State Commission or the National Commission
shall not admit a complaint unless it is filed within two years from the date on
which the cause of action has arisen.
2) Notwithstanding anything contained in sub-section (1), a complaint may be
entertained after the period specified in sub-section (1), if the complainant
satisfies the District Forum, the State Commission or the National Commission,
as the case may be, that he had sufficient cause for not filing the complaint
within such period: Provided that no such complaint shall be entertained unless
the National Commission, the State Commission or the District Forum, as the
case may be, records its reasons for condoning such delay.

Penalties
Where a trader or a person against whom a complaint is made 2[or the
complainant] fails or omits to comply with any order made by the District
Forum, the State Commission or the National Commission, as the case may be,
such trader or person 2[or complainant] shall be punishable with imprisonment
for a term which shall not be less than one month but which may extend to three
years, or with fine which shall not be less than two thousand rupees but which
may extend to ten thousand rupees, or with both:
PROVIDED that the District Forum, the State Commission or the National
Commission, as the case may be, may, if it is satisfied that the circumstances of
any case so require, impose a sentence of imprisonment or fine, or both, for a
term lesser than minimum term and the amount lesser than the minimum
amount, specified in this section.

Lucknow Development Authority v. M.K. Gupta AIR 1994 SC 787


In this case the Supreme Court emphasised upon the basic principle
of consumer justice embodied in the Consumer Protection Act,
when it spoke about the need for consumer courts to award
compensation commensurate with the injustice suffered by the
consumer. It called for a liberal interpretation of the provision in
the law for compensation. Besides the actual loss or the expected
loss, the compensation may extend to physical, mental or even
emotional suffering, insult or injury or loss.

References
1. Law of Torts- by R.K Bangia
2. www.indiankanoon.com
3. www.slideshare.net
4. www.consumersinternational.com

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