Palm Groves Cooperative Housing Society Ltd. v. Magar Girme and Gaikwad Associates, 2025 INSC 1023 - Consumer Protection Act - Interpretation Of Statutes

Consumer Protection Act 1986 - Section 25(1) - Section 25(1) of the 1986 Act shall be read as enumerated below for the period from 15.03.2003 to 20.07.2020 with reference to all pending proceedings at any stage for execution of any order passed under the 1986 Act. “Section 25. Enforcement of orders of the District Forum, the State Commission or the National Commission. (1) Where any order made under this Act is not complied with, the District Forum or the State Commission or the National Commission, as the case may be, enforce the same in the manner as if it were a decree or order made by the Court in a suit and the provisions of Order XXI of the First Schedule to the Code of Civil Procedure, 1908 shall, as far as may be, applicable and may order the property of the person, not complying with such order to be attached.” (Para 38)

Consumer Protection Act 1986 - Section 39,15- Against an order passed by the District Forum in execution petition, an appeal shall lie to the State Commission under Section 15 with no further remedy of appeal or revision. (Para 39)

Interpretation Of Statutes - Normal principle of statutory interpretation is that when the words used in the statute are clear and unambiguous, the same should be given their normal meaning without adding or rejecting any word. However, there is an exception to this general rule. In case, the Court finds that the provision is vague and ambiguous or the normal meaning may lead to confusion, absurdity or repugnancy with other provisions, the court may by using the interpretative tools, set right the situation by adding or omitting or substituting words in the statute. (Para 18)

Court Orders - An order passed by any court, or any forum is merely a kind of paper decree unless effective relief is granted to the party entitled thereto. The consumers of justice should feel that they have received justice in reality and not merely on papers. (Para 30)

Consumer Protection Act 2019 - Sections 71 to 73 - More teeth have been provided to the District, State and the National Commission for enforcement of the orders passed by them. The words used in Section 71 provides for enforcement of ‘every order’. Similarly, Section 72 uses the words ‘any order’. Beside civil proceedings for enforcement of orders, for non-compliance thereof, criminal liability has also been provided. The words, as used in the aforesaid sections, clearly include ‘interim orders’ and the ‘final orders’. (Para 14.5)