Rajesh Kumar National Insurance Co. Ltd. 2024 INSC 993- S 21 Consumer Protection Act - Revisional Jurisdiction

Consumer Protection Act, 1986 - Section 21(b) - National Commission could not have interfered with pure finding of fact arrived at by the District and State Commissions while exercising revisional jurisdiction. (Para 13)- the conditions laid down in Section 21(b) are the only parameters under which a revision may be invoked. If a document has already been considered and rejected by the State Commission, a revision does not lie merely because the National Commission has a different view on the same- Even if no patent error, the revisional jurisdiction may be invoked in a case of gross miscarriage of justice- In cases where the courts below have reached findings on facts, the jurisdiction of revision is very limited and must be invoked only when there is a patent illegality in the findings. (Para 15)

Insurance Law - Delay in intimation may be condoned if it is properly explained. (Para 19) - Principles of interpreting and applying exclusionary clauses in insurance policy - Condition merely prescribed that in the event of any accident, the vehicle shall not be left unattended without proper precaution being taken- While interpreting such a clause the Court/Commission or Tribunal will see whether the said obligation has been complied with reasonably or not. The context in which accident occurs and the circumstances that prevailed at the time of accident are extremely important to conclude whether the insured has taken reasonable care or not. (Para 18)