ORDER : K. Lakshman, J. Heard Mr. Ankit Swaroop, Mr. Drupad Sangwan, Mr. N. Pavan Krishna Reddy, Mr. Rishi Bhargava, Mr. Ruchil Raj, Ms. Harika Tejavath, Ms. Duvvuru Ruthika Reddy, M. M. Naga Vekata Neeraj and Mr. K. Anirudh Reddy, learned counsel for respective petitioners and Mr. Kunamalla Karunakar, Mr. P.Ravi Shankar and Mr. P. Aravind Reddy, learned counsel for respective respondents. 2. All these revisions arise out of common order dated 06.01.2025 passed by learned National Consumer Disputes Redressal Commission, New Delhi (for short, ‘learned NCDRC’) in Revision Petition No.1376 of 2024 and batch, whereby learned NCDRC had upheld the orders passed by learned District Forum by setting aside the orders passed by learned State Commission wherein State Commission allowed some appeals filed by the petitioners, in part, reduced the quantum of compensation granted by learned District Forum and allowed some appeals in toto, set aside some of the orders passed by the District Forum in respect of some farmers –complainants. 3. Since there are multiple revisions, it would be difficult to discuss facts of all the cases. Further, the facts of all the cases are similar, except the names of parties and the quantum of compensation granted. There is no dispute with regard to the facts. Therefore, to avoid confusion and to have more clarity, it would be better to refer to the facts of the case in CRP No. 1203 of 2025. FACTUAL MATRIX :- 4. The revision petitioner is a company registered under the Companies Act, 1956. It engaged in the business of seed production and sales having its registered office at Raipur, Chhattisgarh. 5. Respondent No.1 is a farmer and resident of Agrahampahad village, Atmakur Mandal, Warangal District, Telangana State and is claiming to have been cultivating chilli crops for the last few years. 6. It is also apt to note that even other farmers/complainants residents of the said village and other nearby villages of Warangal district, claiming to have been cultivating chilli crop for the last few years. 7. Respondent No.2 is a dealer, who sold the seeds to the farmer. Respondent No.1 - farmer purchased ten (10) packets of VNR 145 chilli seeds on 07.03.2017 from respondent No.2 dealer vide Lot No.1870 after paying an amount of Rs.3,300/- manufactured by Respondent No.1. 7. Respondent No.2 is a dealer, who sold the seeds to the farmer. Respondent No.1 - farmer purchased ten (10) packets of VNR 145 chilli seeds on 07.03.2017 from respondent No.2 dealer vide Lot No.1870 after paying an amount of Rs.3,300/- manufactured by Respondent No.1. Thereafter, respondent No.1 sowed the seeds in an area measuring Ac.1.00 guntas in the month of April, said to have incurred an amount of Rs.40,000/- for cultivating the land. 8. According to respondent No.1 – Farmer, there was crop loss due to supply of defective, mis-branded, genetically poor chilli seeds supplied by the petitioners – Manufacturers. 9. Upon a letter written by various farmers on 06.07.2017 with regard to alleged bad condition of crop, the District Collector, Warangal, informed the same to the Agriculture Officer, Joint Director of Agriculture and District Horticulture and Sericulture Officers. Later, the District Agriculture Officer, vide letter dated 07.07.2017 directed the Mandal Agriculture Officer to conduct joint inspection with the Horticulture officer and report compliance at the earliest. 10. The Mandal Agriculture Officer, vide letter dated 10.07.2017, informed the Asst. Director of Agriculture, Telangana DNA Finger Printing Crops monitoring Lab that he is sending green chillies leaves of 50 plants (randomly selected) for analysis. The Joint District-Level committee conducted a visual inspection on 11.07.2017 and subsequently submitted its report, stating that the crop had been severely affected by ‘Thrips incidence’, during the initial crop growing stage, attributed to the prevalence of high temperatures. Further it was stated that the crop was affected by viral diseases such as PBNV (Peanut Bud Necrosis Virus) and CMV (Cucumber Mosaic Virus) which led to poor growth. 11. Thereafter, on 01.08.2017, the Genetic Purity test report was submitted to the District Agriculture officer, Warangal, and the Commissioner of Agriculture, Telangana have concluded that, sample taken from the field and the sample given by the Manufacturer-petitioner differed and termed them ‘Misbranded’ 12. The respondent No.1 approached the learned District Consumer Forum, Warangal, by filing a consumer complaint bearing No.199/2018 Under section 12 of the Consumer Protection Act, 1986 (herein after” Act, 1986”) to direct the Petitioners herein to pay compensation for the alleged crop loss and other expenses incurred with regard to the crop failure. Likewise, other similarly situated farmers also filed complaints with similar contentions. Likewise, other similarly situated farmers also filed complaints with similar contentions. The Learned District Consumer Forum has allowed the Complaints in part holding that the petitioners herein - opposite parties are jointly and severally liable and directed them to deposit a sum of Rs.1,35,000/- (One Lakh Thirty Five Thousand only) towards crop loss for Ac.1.00 guntas of land with interest @7.5% p.a. and to pay Rs.10,000/- (Ten Thousand Rupees only) towards mental agony, legal expenditure including costs with one month from the date of receipt of a copy of that order. 13. Aggrieved by the orders passed by the learned District Forum, the Petitioners herein have preferred appeals in State Commission under Section 15 of the Act, 1986 vide Appeal No.703/2020 and batch. Vide orders all dated 07.11.2023, the learned State Commission has allowed some appeals in part and some appeals in toto, reduced the quantum of Compensation awarded by the District Consumer Forum in some appeals, directing to pay a sum of Rs.67,500/- to the Respondent No.1/Complaint along with Rs.10,000/- towards costs of the litigation within eight weeks. 14. Against the orders passed by the State Commission, Hyderabad, the Petitioners and farmers – complainants have filed Revision Petitions under Section 21(b) of the Act of 1986 before the learned NCDRC. The learned NCDRC has disposed of the Revision Petitions vide common order dated 06.01.2025. The learned NCDRC has upheld the orders passed by the learned District Forum, and has set aside the orders passed by the State Commission. 15. The Petitioners have filed these Civil Revision Petitions against the said common order dated 06.01.2025 passed by the learned NCDRC, New Delhi. 16 . We have heard leaned counsel for the petitioners and respondents –Consumers extensively. MAINTAINABILITY OF THE CRPs 17. At the initial stage of hearing, learned counsel for the respondents did raise an objection as to the maintainability of the present Civil Revision Petitions filed under Article 227 of the Constitution of India. However, upon further hearing and after adverting to the settled legal position, both learned counsel ultimately agreed that the petitions are maintainable. The issue of maintainability is, in any event, no longer res integra. However, upon further hearing and after adverting to the settled legal position, both learned counsel ultimately agreed that the petitions are maintainable. The issue of maintainability is, in any event, no longer res integra. In M/s. Indus Hospitals v. Rajeev Lochan Singh , (2025) 3 ALD 801 (C.R.P. No. 2994 of 2024, decided on 02.05.2025), High Court of Andhra Pradesh, in paragraph 45, has categorically held that a Revision Petition filed under Article 227 of Constitution of India, against an order passed by the NCDRC under Section 58(1)(b) of the Consumer Protection Act, 2019, as such an order is not appealable and the learned NCDRC answers the description of a “Tribunal”. The said conclusion was reached by placing reliance on the authoritative pronouncement of the Hon’ble Supreme Court in Ibrat Faizan v. Omaxe Buildhome Pvt. Ltd ., (2023) 11 SCC 594 which recognizes the supervisory jurisdiction of the High Court over tribunals. In view of the aforesaid binding precedent and the consensus ultimately recorded between the parties, the objection as to maintainability stands answered, and the present Civil Revision Petitions are maintainable. 18. Definition of “Consumer” under the Consumer Protection Act. i) The present batch of matters requires an authoritative examination of the meaning and ambit of the expression “consumer” as employed in Section 2(1)(d) of the Act of 1986 and its successor provision, Section 2(7) of the Consumer Protection Act, 2019 (hereinafter, “the 2019 Act”). Both enactments are products of Parliament’s resolve to protect individual purchasers and recipients of services from exploitation by economically dominant market actors. The statute is, therefore, remedial and beneficent in nature; its provisions must receive a liberal and purposive construction consistent with the objective of consumer welfare rather than be confined by narrow or technical interpretation. ii) Section 2(1)(d) of the 1986 Act defined a consumer as any person who buys goods or hires or avails services for consideration, but does not include a person who obtains such goods or services for resale or for any commercial purpose, save where such goods or services are used exclusively for earning a livelihood by means of self-employment. This formulation reflects a deliberate legislative balance between consumer protection and commercial freedom. The 2019 Act, through Section 2(7), substantially re-enacts the same language, signifying legislative continuity and endorsement of the interpretation placed upon the earlier Act by the Courts. This formulation reflects a deliberate legislative balance between consumer protection and commercial freedom. The 2019 Act, through Section 2(7), substantially re-enacts the same language, signifying legislative continuity and endorsement of the interpretation placed upon the earlier Act by the Courts. iii) The Hon’ble Supreme Court in Lucknow Development Authority v. M.K. Gupta , (1994) 1 SCC 243 , characterized the Act as a “social-welfare legislation” designed to provide inexpensive and expeditious redressal to consumers. The Court observed that provisions of such welfare statutes must be construed in a manner that advances their object and suppresses the mischief they intend to remedy. The ratio was subsequently reiterated in Kusum Sharma v. Batra Hospital , (2010) 3 SCC 480 , which held that the Act’s reach extends to every sector public or private where goods or services are offered for consideration. iv) The definition of consumer thus admits of two essential elements: a) the existence of a transaction of purchase or hiring for consideration, and b) the exclusion of transactions for resale or commercial purpose. v) The latter exclusion, however, is tempered by the statutory exception for livelihood-based self-employment. The clause was designed to prevent large-scale commercial enterprises from invoking the Act while ensuring that individuals engaged in small or subsistence-based activity are not deprived of its protection. Judicial interpretation has consistently emphasised that this exclusion must be narrowly construed, lest the remedial purpose of the legislation be defeated. vi) The Supreme Court in Laxmi Engineering Works v. PSG Industrial Institute , (1995) 3 SCC 583 , introduced what has come to be known as the dominant-purpose test. It held that the determination whether a transaction is commercial must depend on the dominant purpose for which the goods or services are obtained. Where the dominant purpose is to earn livelihood by self-employment, the purchaser remains a consumer, where it is to engage in large-scale commercial exploitation for profit, the exclusion applies. This doctrinal development has guided subsequent judicial reasoning for nearly three decades. vii) Following Laxmi Engineering (supra), the consumer fora and High Courts have uniformly held that the definition of consumer must be interpreted with functional realism, focusing on the nature of use rather than the scale of activity. The expression “commercial purpose” cannot be read in a rigid economic sense divorced from the statute’s welfare objective. vii) Following Laxmi Engineering (supra), the consumer fora and High Courts have uniformly held that the definition of consumer must be interpreted with functional realism, focusing on the nature of use rather than the scale of activity. The expression “commercial purpose” cannot be read in a rigid economic sense divorced from the statute’s welfare objective. The true test is whether the transaction bears the characteristics of consumption that is, use for personal benefit or livelihood rather than of commerce. viii) In Emaar MGF Land Ltd. v. Aftab Singh , (2019) 12 SCC 751 , the Supreme Court further clarified that the Consumer Protection Act provides an additional and special remedy, and must be construed harmoniously with its underlying policy of consumer welfare. The jurisdiction of the consumer fora is thus to be interpreted expansively to effectuate, not to limit, the right of the consumer to seek redressal. ix) Read conjointly, these authorities establish that the term consumer under both the 1986 and 2019 Acts is not confined to a contractual purchaser in the ordinary mercantile sense but extends to any person who buys goods or avails services for consideration in order to satisfy personal, domestic, or livelihood-related needs. The exclusions for resale and commercial purpose are exceptions to this broad rule and must be strictly proven by the party asserting them. The legislative continuity between the two Acts, coupled with sustained judicial interpretation, reinforces a single principle that the expression consumer must be construed purposively and liberally to promote access to justice for individuals who, as end-users, depend on the fairness, competence, and integrity of suppliers and service-providers. x) Accordingly, this Court holds that for the purpose of adjudication under the Consumer Protection Act, a consumer is any person who purchases goods or avails services for consideration for personal or livelihood use and not for resale or profit-oriented enterprise. The determination in each case must rest upon the dominant purpose of the transaction, viewed in its social and economic context. Such interpretation alone gives full effect to the beneficent purpose of the enactment and aligns with the consistent exposition of the law by the Supreme Court of India. 19. Judicial Recognition of ‘Farmers’ as ‘Consumers’. i) The issue whether a cultivator purchasing seeds for sowing can be regarded as a “consumer” within the meaning of the Consumer Protection Acts has engaged the attention of judicial fora for over three decades. 19. Judicial Recognition of ‘Farmers’ as ‘Consumers’. i) The issue whether a cultivator purchasing seeds for sowing can be regarded as a “consumer” within the meaning of the Consumer Protection Acts has engaged the attention of judicial fora for over three decades. It arises here in a cluster of complaints wherein the respondents small and marginal farmers allege defective hybrid seeds and resultant crop failure. Resolution of this issue turns upon the proper construction of Section 2(1)(d) of the 1986 Act and its successor provision, Section 2(7) of the 2019 Act. ii) Both provisions adopt the same legislative scheme, a consumer is any person who buys goods or avails services for consideration, but does not include one who does so for resale or for any commercial purpose, save where such goods or services are used exclusively for earning a livelihood by means of self-employment. This express saving clause reflects the Legislature’s intent to shield those engaged in livelihood-based activity even where such activity incidentally yields income. The exclusion for “commercial purpose” is thus to be narrowly construed. iii) Applying that principle, the National Commission in Maharashtra Hybrid Seeds Co. Ltd. v. Alavalapati Chandra Reddy , (1998) 6 SCC 738 , held that cultivators who purchased hybrid seeds for their own fields were consumers under the Act, and that the seed company’s plea of “commercial use” was misconceived. The Court observed that the scale of cultivation is immaterial so long as the dominant purpose is livelihood, and rejected the argument that sale of the produce in the market converted the activity into commerce. The ruling marked the first authoritative recognition of agriculturists as consumers within the statutory framework. iv) This reasoning was taken forward in Nandan Biomatrix Ltd. v. Ambika Devi , 2020 13 SCC 130 , where the National Commission held that failure of germination in Jatropha Curcas seeds constituted deficiency in service and that the complainant farmers, having purchased the seeds for their own cultivation and not for resale, were consumers. The Commission emphasized that agricultural operations carried on for livelihood are excluded from the expression “commercial purpose”, even if they yield marketable surplus. v) The law now stands conclusively settled by the Supreme Court in National Seeds Corporation Ltd. v. M. Madhusudhan Reddy , (2012) 2 SCC 506 . The Commission emphasized that agricultural operations carried on for livelihood are excluded from the expression “commercial purpose”, even if they yield marketable surplus. v) The law now stands conclusively settled by the Supreme Court in National Seeds Corporation Ltd. v. M. Madhusudhan Reddy , (2012) 2 SCC 506 . The Supreme Court, after examining the scheme of the Seeds Act, 1966 and the Act of 1986, held that a farmer who purchases seeds for his own use and not for resale is a consumer, and that supply of defective seeds resulting in crop loss amounts to deficiency in service. It was categorically observed that the fact that a cultivator sells his produce in the market does not make the transaction commercial, since such sale is a natural incident of livelihood and not an act of trade. The Court directed the seed corporation to compensate the farmers and reaffirmed that the statute must receive a liberal and purposive interpretation to fulfill its welfare objective. vi) Following Madhusudhan Reddy (supra), a consistent line of authority has developed. In Fortune Hybrid Seeds Ltd. v. Bommala Pedda Swamy , 2015 SCC OnLine learned NCDRC 325 , the learned NCDRC, relying on departmental and laboratory reports that established low germination and genetic impurity, held that the farmers were consumers and that the manufacturer’s plea of adverse weather was untenable in the absence of scientific proof. vii) These precedents collectively establish that the Act must be applied in its social-economic context. Agriculture in India is primarily a means of livelihood, not commerce, the cultivator is a consumer who relies on representations and scientific expertise of seed companies. To exclude such persons would defeat the beneficent purpose of the statute and perpetuate structural inequality between corporate suppliers and rural purchasers. viii) This purposive construction also accords with the constitutional vision embodied in Articles 38 and 39(b) of the Constitution of India, which require the State to secure social and economic justice and ensure equitable distribution of resources. By recognizing farmers as consumers, the judiciary has harmonized consumer law with agrarian policy, ensuring that statutory protection extends to those most vulnerable to market asymmetries. ix) Accordingly, this Court holds that agriculturists who purchase seeds or other agricultural inputs for cultivation undertaken for their own livelihood squarely fall within the definition of consumer under Section 2(7) of the 2019 Act. ix) Accordingly, this Court holds that agriculturists who purchase seeds or other agricultural inputs for cultivation undertaken for their own livelihood squarely fall within the definition of consumer under Section 2(7) of the 2019 Act. The mere fact that such cultivation yields income or involves sale of produce in the market does not alter its character. What is decisive is the dominant purpose that the goods are purchased for use in livelihood and not for commercial resale. x) To hold otherwise would be to deny the very class of persons whom the legislation was designed to protect. The cultivator is not a trader in seeds but an end-user of them, he consumes, rather than markets, the product. In the absence of any contrary legislative intent, the judicial consensus that farmers are consumers under the Act must be regarded as settled law. 20. Definition, Scope and Extent of “Deficiency in Service” i) At this stage, it becomes necessary to delineate the true import, content and extent of the expression “deficiency in service” as envisaged under the Consumer Protection Act. The distinction between defect in goods and deficiency in service lies at the heart of the present controversy, for the outcome in these matters turns upon whether the acts and omissions alleged against the petitioners constitute statutory deficiency. ii) Sections 2(1)(f) and 2(1)(g) of the 1986 Act, define defect and deficiency respectively as a scheme that has been substantially carried forward into Sections 2(10) and 2(11) of the 2019 Act. “Defect” means any fault, imperfection or shortcoming in the quality, quantity, potency, purity or standard required by law or contract to be maintained in relation to goods; while “deficiency” refers to any fault, imperfection, shortcoming or inadequacy in the quality, nature or manner of performance required to be maintained by law or undertaken in relation to any service. iii) Section 2(11) of the 2019 Act now expressly includes within its ambit “any act of negligence or omission or commission and deliberate withholding of relevant information by such person to the consumer.” This legislative amplification acknowledges the asymmetry of information between provider and consumer and broadens the statutory reach to include acts of concealment and misinformation a significant development reflecting the transition from a fault-based to a duty-based model of liability. iv) The Hon’ble Supreme Court in Lucknow Development Authority (supra), interpreting these very provisions, held that both public authorities and private service-providers fall within the ambit of the Act, and that delay, negligence or defective work amount to deficiency in service. The Court observed that while defect in goods may be remedied by replacement or repair, deficiency in service must often be compensated through damages, for it affects the quality and manner of performance itself. v) The expression “service” itself, defined in Section 2(1)(o) of the 1986 Act (now Section 2(42) of the 2019 Act), is of the widest amplitude. It encompasses service of any description made available to potential users and specifically includes facilities relating to banking, finance, insurance, transport, energy, housing, construction, and dissemination of information. vi) The Supreme Court in Lucknow Development Authority (supra) described the definition as three-fold a main clause, an inclusive clause, and an exclusionary clause and observed that the words “any” and “potential” are of wide import, thereby extending the Act’s coverage from one to all categories of service. vii) In Indigo Airlines v. Kalpana Rani Debbarma , (2020) 9 SCC 424 , the Apex Court clarified that any deviation, whether by an act or omission, from the promised or expected standard of performance constitutes deficiency. Likewise, SGS India Ltd. v. Dolphin International Ltd , 2021 SCC Online SC 879 , held that once the complainant discharges the initial onus, the burden shifts to the service-provider to establish that its conduct met the requisite standard. viii) The jurisprudence recognizes three dimensions of deficiency: viii-a) Qualitative, where service is sub-standard; viii-b) Procedural, where there is delay or neglect; viii-c) Informational, where material facts are suppressed. Each is actionable, since the Act intends not merely to compensate but to uphold a standard of reasonableness and diligence expected in service relationships. ix) The Supreme Court in Spring Meadows Hospital v. Harjol Ahluwalia , (1998) 4 SCC 39 , extended the concept of deficiency to professional negligence, emphasizing that lack of due care or timely attention, even without mala fides, attracts statutory liability. Intent is immaterial, what matters is performance below the benchmark of a reasonable and prudent professional. x) The 2019 Act, while modernizing consumer jurisprudence through provisions on product liability and unfair contracts, consciously retained the same definition of deficiency, thereby affirming judicial precedent. Intent is immaterial, what matters is performance below the benchmark of a reasonable and prudent professional. x) The 2019 Act, while modernizing consumer jurisprudence through provisions on product liability and unfair contracts, consciously retained the same definition of deficiency, thereby affirming judicial precedent. This continuity reflects legislative approval of the liberal interpretation that views the Act as a mechanism to enforce standards of care, competence and fair dealing across all service sectors. xi) Thus, deficiency in service is not confined to breach of contract but extends to any failure statutory, contractual or moral to render service with reasonable skill, care and diligence. It may arise in both private and public transactions and encompasses negligent performance, arbitrary delay, or concealment of information. The consumer fora are, therefore, empowered to grant both compensatory and preventive relief, ensuring accountability and deterrence. xii) Viewed in this light, the scope of “deficiency” under the Consumer Protection Act is both remedial and disciplinary. It serves not only to compensate individual loss but also to enforce public standards of reliability and transparency. This Court thus reiterates that the provisions of the Act must be interpreted expansively so as to advance its beneficent object and to secure effective protection of consumer rights. 21. Applicability of “Deficiency in Service” to Goods and Services, including Seeds. i) The legislative scheme of the Consumer Protection Act draws a conceptual distinction between defect in goods and deficiency in service, but recognizes that the two are often interlinked in composite transactions. Section 2(10) of the 2019 Act defines defect as any fault, imperfection, shortcoming or inadequacy in the quality, quantity, potency, purity or standard of goods required to be maintained by or under any law or contract; Section 2(11) defines deficiency with reference to the quality, nature or manner of performance of service. Together, these provisions establish that where a transaction involves both supply of goods and related obligations of testing, storage, certification, or after-sale assistance, the failure of any element attracts statutory liability. ii) The sale of seeds, fertilizers, or pesticides is a paradigm of such a composite transaction. The physical sale of seeds constitutes the goods component, but the processes of laboratory testing, genetic certification, labeling, packaging, and after-sale support from the service component inseparably connected to it. ii) The sale of seeds, fertilizers, or pesticides is a paradigm of such a composite transaction. The physical sale of seeds constitutes the goods component, but the processes of laboratory testing, genetic certification, labeling, packaging, and after-sale support from the service component inseparably connected to it. As observed by the National Commission in several decisions, including Alavalapati Chandra Reddy (supra) and Nandan Biomatrix Ltd (supra), a seed company’s statutory and contractual obligations do not cease upon delivery, they extend to ensuring that the seeds conform to prescribed germination and genetic-purity standards and that all representations made to cultivators are accurate and verifiable. iii) In M. Madhusudhan Reddy (supra), the Supreme Court held that the supply of defective seeds resulting in crop failure constitutes deficiency in service under the Act. The Court reasoned that the responsibility of the seed-producer is twofold, first, to deliver seeds meeting the quality standards mandated by the Seeds Act and Rules; and second, to ensure that such standards were verified and certified through competent laboratories. Failure on either count is a breach of statutory duty. The Court further emphasized that, once a complaint supported by credible laboratory or departmental reports shows sub-standard quality, the evidentiary burden shifts to the manufacturer to establish conformity, bare assertions of pest attack or weather fluctuation are inadequate. iv) The same principle was applied in Fortune Hybrid Seeds Ltd. (supra), where the National Commission found that laboratory analysis revealed genetic impurity and poor germination. The manufacturer’s defense that the loss was caused by climatic conditions was rejected for want of scientific corroboration. The Commission held that the manufacturer’s omission to disclose parent- line data and testing records amounted to deficiency in service within Section 2(1)(g) of the 1986 Act (now 2(11) of the 2019 Act), observing that “suppression of material information concerning quality control is itself a form of negligence.” v) Similarly, in Nandan Biomatrix Ltd (supra), the National Commission held that where seeds fail to germinate as represented, the defect is not confined to the product but extends to the service of ensuring quality, testing, and truthful representation. The complainant is thus entitled to redress under the head of deficiency in service even if the seeds, as tangible goods, are no longer available for testing. The complainant is thus entitled to redress under the head of deficiency in service even if the seeds, as tangible goods, are no longer available for testing. The rationale is that the farmer purchased not merely a physical product but also the assurance of its certified characteristics an assurance forming part of the service element of the transaction. vi)These principles are in harmony with the broader doctrine laid down in Lucknow Development Authority (supra), and Ghaziabad Development Authority (supra), that the Consumer Protection Act must be interpreted to advance its remedial object and to make service-providers publicly accountable for negligence and arbitrariness. The provision is both compensatory and deterrent, it introduces a public-law dimension into private commercial relations by holding those who profit from such relations to standards of fairness and diligence. vii) It follows that the concept of deficiency in service applies equally to goods where ancillary or dependent services form an integral part of the transaction. The manufacturer’s obligation to ensure quality, to test, to label correctly, and to provide truthful information is a continuing service obligation. The breach of any of these duties constitutes deficiency, notwithstanding that the tangible product itself is defective. In such cases, defect and deficiency overlap, and the consumer fora are competent to grant comprehensive relief. viii) Therefore, in transactions involving agricultural inputs, particularly seeds, fertilizers and pesticides, the statutory duty of care imposed upon the producer or distributor is both legal and moral. Any failure to comply with the standards prescribed under the Seeds Act and Rules, or to disclose relevant testing information, amounts to deficiency in service under Section 2(11) of the 2019 Act. The legislative intent is to secure accountability commensurate with the vulnerability of the consumer the farmer who, relying on the technical expertise and representations of the manufacturer, stands at an inherent disadvantage. 22. Burden of Proof and Evidentiary Standards: i) Having delineated the legal framework of deficiency in service, it becomes apposite to consider the rules governing proof and evidentiary burden in consumer disputes, particularly those involving agricultural inputs. The statutory design of the Consumer Protection Act is remedial and informal; its procedure departs from the rigidity of the Evidence Act while retaining its essential principles of fairness and probability. Accordingly, the standard of proof is that of a preponderance of probabilities, not proof beyond reasonable doubt. The statutory design of the Consumer Protection Act is remedial and informal; its procedure departs from the rigidity of the Evidence Act while retaining its essential principles of fairness and probability. Accordingly, the standard of proof is that of a preponderance of probabilities, not proof beyond reasonable doubt. ii) The initial onus rests upon the complainant to assert and substantiate the alleged deficiency. However, consumer jurisprudence has evolved the doctrine of dynamic burden-shifting, recognizing that the consumer especially a farmer is often ill-equipped to access technical data or production records exclusively in the possession of the manufacturer or dealer. Once a complainant places credible material showing prima facie defect or deficiency, the burden shifts to the opposite party to rebut the presumption through contemporaneous and verifiable evidence. iii) In Haryana Seeds Development Corporation Ltd. v. Sadhu , AIR 2005 SC 2023 , the Hon’ble Supreme Court emphasized that when a complainant alleges defective agricultural inputs such as seeds, the consumer forum must carefully evaluate the findings of expert committees constituted for that purpose. The Court held that such expert committee reports carry significant evidentiary weight and that mere allegations without technical scrutiny will not suffice. While applying the definition of “consumer” under the Act, the Court observed that the purchase of seeds for livelihood may bring within its ambit, but the consumer forum must go beyond cursory conclusions and consider the expert evidence relating to soil, water, climate, and seed purity before imposing liability. In doing so, the Court underscored the jurisdictional boundary of consumer forums to adjudicate fact-intensive and technically complex disputes only when the requisite expert findings and procedural safeguards have been complied with. iv) Accordingly, the decision in Sadhu (supra) lays down that liability for defective seeds cannot be presumed merely because the crop failed, the chain of causation must be supported by scientific and expert evidence, and the consumer forum must record reasons for accepting or rejecting such specialist evidence. v) In M. Madhusudhan Reddy (supra), the Hon’ble Supreme Court held that the primary onus to establish the quality, purity and viability of seeds lies with the manufacturer and not the farmer- consumer. v) In M. Madhusudhan Reddy (supra), the Hon’ble Supreme Court held that the primary onus to establish the quality, purity and viability of seeds lies with the manufacturer and not the farmer- consumer. The Court observed that a farmer who acquires seeds for cultivation of livelihood cannot be expected to retain samples, conduct elaborate testing or carry forward scientific records, therefore, the statutory scheme places the burden on the manufacturer to preserve batch samples, facilitate testing and furnish evidence of quality. The Court further affirmed that where the manufacturer fails to produce retained samples or competently rebuts testing of distributed seeds, the presumption of defect crystallizes and a consumer forum will rightly place reliance on such official test reports and expert inspections as being of high evidentiary value. Consequently, the doctrine of burden-shifting in seed-supply disputes mandates that a deficiency in service or unfair trade practice may be inferred from the manufacturer’s non-compliance with its evidentiary obligation without necessitating the farmer-complainant to discharge an onerous technical burden. vi) The National Commission, in a series of decisions including Fortune Hybrid Seeds Ltd. (supra), and Mahyco Seeds Ltd. v. B. Yedukondalu , 2021 SCC Online learned NCDRC 32 , has consistently applied the principle, where credible departmental or expert reports disclose defect, and the manufacturer fails to furnish contemporaneous quality-control documentation, the Commission has drawn an adverse inference of negligence and confirmed deficiency. It has been repeatedly held that “a manufacturer who withholds scientific evidence within his special knowledge cannot escape liability by invoking speculative causes.” vii) This burden structure is also justified by considerations of equity and policy. The consumer fora were constituted to ensure accessible justice without the procedural rigor of civil courts. Imposing upon a small farmer the onerous task of proving scientific defect beyond prima facie probability would defeat the Act’s purpose. Accordingly, once the complainant produces the purchase invoice, departmental inspection report, or any accredited laboratory certificate showing sub-standard quality, the evidentiary equilibrium shifts decisively against the supplier. viii) At the same time, the principle of causation remains vital. The complainant must demonstrate a reasonable nexus between the deficiency alleged and the loss suffered. Intervening causes such as flood, drought or pest attack, if proved by credible scientific evidence, may sever the causal chain. Conversely, where the official report attributes failure to defective seeds, the manufacturer’s liability becomes complete. The complainant must demonstrate a reasonable nexus between the deficiency alleged and the loss suffered. Intervening causes such as flood, drought or pest attack, if proved by credible scientific evidence, may sever the causal chain. Conversely, where the official report attributes failure to defective seeds, the manufacturer’s liability becomes complete. This two-stage analysis proof of defect and proof of causation preserves both fairness and accountability. ix) Accordingly, this Court affirms that in consumer disputes relating to agricultural inputs, the burden of proof is fluid and shifts with control of evidence; that scientific and departmental reports constitute reliable primary evidence; and that manufacturers who fail to produce contemporaneous quality-control data must bear the consequences of adverse inference. Such an approach alone realizes the remedial and preventive purposes of the Consumer Protection Act 23. Summary of the prior orders passed by Consumer fora 23.1. District Forum Order: i) On considering the evidence of the complainant (PW-1), the DNA Expert (PW-2), the District Agriculture Officers (PWs-3 and 4), Exhibits A-1 to A-12, X-series documents including departmental and DNA reports, and the oral and documentary evidence adduced by the opposite parties (RWs 1–4; Exs. B-1 to B-17), the District Forum held that the complainant is a “consumer”, that the Seeds Act does not bar recourse to the Consumer Protection Act; the expert and departmental reports, having remained unrebutted by any independent scientific evidence from the seed company, conclusively established that the seeds supplied were “mis-branded” and that there was deficiency in service and unfair trade practice on the part of all opposite parties. ii) On quantification, the District Forum relying on the market value verification certificates (Exs. A-11, A-12 / X-87 to X-90), took the average market price of chilli as Rs.4,500 per quintal, considered the company’s own yield representation (30 quintals per acre) and the fact that some yield was obtained, determined the loss at 30 quintals per acre. It accordingly awarded Rs.1,35,000/- towards crop loss per Ac.1.00 guntas, Rs.35,000/- per acre towards cultivation expenses including cost of seed, and Rs.10,000/- towards mental agony and litigation expenses, together with interest at 7.5% p.a. from the date of complaint till realization, held that the dealer (OP No.1) and the manufacturer/distributors (OP Nos.2 to 4) jointly and severally liable. Thus, the District Forum partly allowed the complaints by orders all dated 19.03.2020. 23.2. Thus, the District Forum partly allowed the complaints by orders all dated 19.03.2020. 23.2. State Commission order: i) Challenging the said orders, 419 appeals were filed under Section 15 of the Act, 1986, by the manufacturer, to set aside District forums orders dated 30.01.2020. ii) The State Commission, upon re-appreciation of the pleadings and evidence, found that the substratum of the complaints suffered from serious infirmities relating to the authenticity of the purchase bill, the date of purchase, sowing and transplantation, proof of land ownership or lawful cultivation, and correlation between the quantity of seeds purchased and the land allegedly cultivated. The Commission noted that some of the complainants failed to produce original bills, pattadar passbooks, lease documents, proof of irrigation or family members certificates, and that contradictions existed between the pleaded dates and the expert inspection period. Viewing these discrepancies as striking at the root of the claim, the State Commission held that the District Forum had erred in granting relief without addressing these foundational deficiencies. iii) Proceeding on the aforesaid reasoning, the State Commission concluded that the burden cast upon the complainant in a claim alleging defect in goods and deficiency in service had not been duly discharged. It was observed that when the very foundation of the complaint namely, proof of lawful purchase, cultivation, and temporal alignment with the alleged crop failure remains in doubt, the opposite parties cannot be fastened with liability on presumptions or conjectures. The Commission emphasized that appellate interference was warranted where the District Forum had adopted a uniform and mechanical approach in allowing multiple complaints, without undertaking a case-specific examination of essential documents and factual assertions. iv) The State Commission accordingly held that the impugned orders of the District Forum in some appeals suffered from material irregularity and could not be sustained in law. Consequently, State Commission allowed some appeals in part, some appeals in toto and dismissed some appeals. State Commission also dismissed 07 appeals preferred by Manufacturer for default. The appellants in some appeals were permitted to withdraw the statutory amount deposited to the credit of the complainants along with accrued interest. 23.3. National Commission order i) Challenging the said orders passed by State Commission, both the revision petitioners herein and farmers filed revisions and cross-revisions before the learned NCDRC under Section 21(b) of the Act, 1986. The appellants in some appeals were permitted to withdraw the statutory amount deposited to the credit of the complainants along with accrued interest. 23.3. National Commission order i) Challenging the said orders passed by State Commission, both the revision petitioners herein and farmers filed revisions and cross-revisions before the learned NCDRC under Section 21(b) of the Act, 1986. The revision petitions were filed predominantly by VNR Seeds Pvt. Ltd., the manufacturer of VNR-145 hybrid chilli seeds, along with its dealers, while cross-revision petitions were filed by the complainant - farmers, aggrieved by the partial relief granted by the State Commission. ii) the challenge before the learned NCDRC was directed against the State Commission orders whereby, while affirming the finding that the seeds were defective, the State Commission had substantially reduced compensation awarded by the District Forum deleted the interest component, disallowed cultivation expenses including seed cost and confined liability solely to the Manufacturer absolving the dealers granting only a nominal amount towards litigation costs in some appeals. iii) On consideration entire record, the learned NCDRC affirmed the concurrent factual findings of the District Forum and the State Commission on the issue of defect in seeds. The Commission placed significant reliance on the District Level Committee report and the Genetic Purity Test conducted by the Telangana DNA Fingerprinting & Transgenic Crop Monitoring Laboratory, which categorically declared the seeds as “misbranded”. The learned NCDRC noted that these reports were prepared by independent Government experts, were scientific in nature, and had not been rebutted by the seed company through any independent laboratory analysis or expert testimony. Consequently, the contention of petitioners i.e. VNR Seeds Pvt. Ltd. that the crop failure was attributable to climatic factors, agronomic practices, or pest infestation unrelated to seed quality was rejected. iv) On the question of quantum of compensation, the learned NCDRC found serious infirmity in the approach adopted by the State Commission. It held that the State Commission’s method of computing crop loss by mechanically assuming a uniform standard yield of 30 quintals per acre and arbitrarily applying a 75% loss factor was not founded on scientific evidence or contemporaneous market data. The learned NCDRC emphasized that farmers cannot be expected to maintain detailed yield records or preserve bills for agricultural inputs, and that insistence on such documentation would defeat the object of consumer protection in agricultural disputes. The learned NCDRC emphasized that farmers cannot be expected to maintain detailed yield records or preserve bills for agricultural inputs, and that insistence on such documentation would defeat the object of consumer protection in agricultural disputes. The Commission observed that the District Forum had correctly relied on market price verification certificates and expert assessment of crop damage while awarding compensation and had adopted a pragmatic and realistic approach consistent with settled consumer jurisprudence. v) The learned NCDRC further held that the deletion of interest and cultivation expenses by the State Commission was unjustified, as compensation for crop loss would be illusory if it failed to account for actual expenditure incurred by farmers and the time value of money lost due to defective goods. On the issue of liability, the learned NCDRC restored the finding of the District Forums holding the manufacturer, and dealer jointly and severally liable, observing that the supply chain could not be artificially severed to the detriment of the consumer once defect and deficiency were established. vi) With the said reasons and findings, the learned NCDRC partly allowed the revisions filed by the farmers, dismissed the revisions filed by Manufacturer i.e. VNR Seeds Pvt. Ltd., and set aside the reduction effected by the State Commission. The learned NCDRC restored the relief granted by the District Forum in respect of compensation towards crop loss, cultivation expenses, mental agony, and interest. All revision petitions and cross-revision petitions were accordingly disposed of by a common order. vii) Challenging the said order, petitioners filed the present revisions. 24 . Contentions of the Petitioners:- i) The complainants failed to discharge the initial burden of proving that the seeds supplied were defective, as mandated in seed- related disputes, and that no legally admissible or scientifically reliable evidence was produced, contrary to the principles laid down in Mahyco Seeds Ltd. v. G. Shrinivash& Ors , MANU/CF/0310/2012 . and M.B. Yedukondalu (supra). The learned NCDRC erroneously relied on the DNA report dated 01.08.2017, which described the seeds as “misbranded”, overlooking that “misbranding” under Section 2(14) of the Seeds Bill, 2004 relates to false labelling and does not ipso facto establish genetic impurity or defect, particularly when the report merely notes mismatch of molecular profiles. and M.B. Yedukondalu (supra). The learned NCDRC erroneously relied on the DNA report dated 01.08.2017, which described the seeds as “misbranded”, overlooking that “misbranding” under Section 2(14) of the Seeds Bill, 2004 relates to false labelling and does not ipso facto establish genetic impurity or defect, particularly when the report merely notes mismatch of molecular profiles. The sampling and inspection by the Mandal Agricultural Officer were vitiated by non- compliance with Rule 25 of the Seeds Rules, 1968, as the identity of the farmer, survey number, and source of leaf samples were not disclosed, and samples were taken from grown plants, rendering linkage to any specific seed lot impossible. ii) Inspection reports recorded only phenotypical observations, relied on non-representative and infected samples, failed to use appropriate SSR markers, and were conducted prematurely and without notice, depriving the petitioners of an opportunity to assist or provide correct seed samples. The genetic purity testing must involve seed-to-seed or leaf-to-leaf comparison, whereas an impermissible leaf-to-seed comparison was adopted. Although approximately 15 different lots of VNR-145 chilli seeds were marketed, DNA testing was confined only to Lot No. 1870, pertaining to merely 97 out of 466 CRPs, rendering the conclusions unrepresentative. The DNA report is also assailed for not examining statutory parameters such as germination, moisture, pure seed and genetic purity percentages, while the petitioner’s in-house laboratory report dated 04.05.2017 records satisfactory results, which, it is contended, were ignored by the consumer fora, contrary to the principle in Zimidara Agro Center v. Sukhdev Singh , 2017 SCC Online LEARNED NCDRC 39 . The official who conducted the DNA test lacked the qualifications prescribed under Rule 20 of the Seeds Rules, 1968. iii) The petitioner challenges the inter-se comparison between VNR-145 chilli seeds and the ‘Sonali’ variety of Rasi Seeds as scientifically impermissible, as inspection reports themselves record Thrips infestation and viral diseases such as PBNV and CMV affecting both varieties, indicating pest-borne causes rather than seed defect. VNR-145 was never represented as Thrips-resistant that no causal nexus was established between susceptibility and defect, and that the complainant failed to prove adherence to recommended agronomic practices or produce vouchers for fertilizers and pesticides. iv) the crop failure could have resulted from external factors such as climate, pest infestation and irrigation issues, constituting intervening causes, and that Rule 23-A of the Seeds Rules, 1968 was not complied with. iv) the crop failure could have resulted from external factors such as climate, pest infestation and irrigation issues, constituting intervening causes, and that Rule 23-A of the Seeds Rules, 1968 was not complied with. v) The complainant does not qualify as a “consumer” under Section 2(d) of the Act, 1986, being engaged in large-scale cultivation. The improbability of the crop timeline is also stressed, as seeds purchased on 11.05.2017 could not have matured by July 2017. The State Commission had rightly interfered with the District Forum’s orders based on thumb-rule assessment. vi) The finding of the learned NCDRC with regard to deficiency by misreading evidence, disregarding binding precedent, is perversed warranting interference under Article 227 of the Constitution of India. Reliance also placed on State of Haryana v. Jai Singh , Civil Appeal No. 6990/2014 vii) Referring to the Expert Committee Report (Ex. X-21), agricultural literature of Professor Jayashankar Telangana State Agricultural University, and the decisions in M. Madhusudhan Reddy (supra) and Maharashtra Hybrid Seeds Company Ltd. v. Garapati Srinivas Rao, R.P. No. 2602 of 2008 & Ors., decided on 12.02.2014 , petitioners contended that Thrips infestation and viral diseases constitute a novus actus interveniens, inspection reports based on visual assessment without notice are inadmissible, and absence of controlled scientific comparison or examination of other seed suppliers vitiates the findings. viii) Placed reliance on the cancellation of its seed licence dated 21.08.2017, which was set aside by this Court in W.P. No. 40269 of 2017 on the ground of non-compliance with Rule 23-A of the Seeds Rules, 1968, thereby demonstrating that the regulatory action itself was procedurally unsustainable. Ex. B-4 and Ex. B-16 establish compliance with prescribed quality standards and also disclose that variation in yield is dependent upon agro-climatic conditions. The consistent performance and success of the same seed variety in other regions negate any allegation of inherent or systemic defect. In support of these submissions, reliance is placed on Sadhu (supra), M. Madhusudhan Reddy (supra) and Mahyco Seeds Company v. Basappa Channappa Mooki , Civil Appeal No.2428 of 2008 , to contend that liability cannot be fastened in the absence of clear, cogent and scientific evidence establishing defect in the seeds supplied. 25. Case laws cited by the Petitioners: i) In Sadhu (supra), the Supreme Court held that compensation cannot be awarded in the absence of proof that crop failure was attributable to defective seeds. 25. Case laws cited by the Petitioners: i) In Sadhu (supra), the Supreme Court held that compensation cannot be awarded in the absence of proof that crop failure was attributable to defective seeds. The Court referred the expert committee’s report, which attributed poor crop performance to extraneous factors such as soil salinity and irrigation conditions, over a local officer’s certificate. Finding no infirmity in the expert report, the Court concluded that the consumer fora erred in awarding compensation and allowed the appeal. ii) In Mahyco Seeds Company Limited v. Basappa Channappa Mooki (supra), the Supreme Court, relying upon Haryana Seeds Development Corpn. Ltd. (supra), held that mere variation in crop yield cannot be attributed to defective seeds in the absence of cogent evidence. The Court found that several external factors influence crop performance and that the Agricultural Officer’s report did not record any defect or inferiority in the seeds. In the absence of material establishing seed defect, the complaint was held to be unsustainable and the appeal was allowed. iii) In State of Haryana v. Jai Singh (supra), the Supreme Court considered the vesting of unutilized “bachat” land reserved during consolidation and upheld the view that such land continues to vest with the original proprietors if not earmarked for a specific common purpose. Applying the doctrine of stare decisis, the Court emphasized that a legal position consistently followed in over a hundred judgments must be respected to preserve certainty and stability in law. iv) In Banta Ram v. Jai Bharat Beej Company Super Market (supra), the National Commission held that the complainant failed to prove any defect in the seeds supplied, as no statutory laboratory testing was conducted in accordance with Section 13(1)(c) of the Consumer Protection Act, 1986. The Commission ruled that field inspection reports alone are insufficient to establish seed defect in the absence of proper sample testing, and consequently dismissed the complaint. v) In Mahyco Seeds Ltd. v. G. Shrinivash & Ors . (supra), the learned NCDRC held that allegations of defective seeds must be proved through proper laboratory testing as mandated under Section 13(1)(c) of the Act, 1986. The Commission found that the complainants relied only on preliminary and departmental reports without producing legally admissible laboratory evidence. In the absence of such proof and compliance with statutory procedure, the complaint was dismissed. (supra), the learned NCDRC held that allegations of defective seeds must be proved through proper laboratory testing as mandated under Section 13(1)(c) of the Act, 1986. The Commission found that the complainants relied only on preliminary and departmental reports without producing legally admissible laboratory evidence. In the absence of such proof and compliance with statutory procedure, the complaint was dismissed. vi) In Mahyco Vegetable Seeds Ltd. v. G. Sreenivasa Reddy (supra), the learned NCDRC held that the complainants failed to establish that the brinjal seeds supplied were genetically defective. Relying on the Commissioner’s report, the Commission found that crop variation or mixed growth did not conclusively prove genetic defect in the seeds. It was reiterated that the burden of proof lies on the complainants, and in the absence of credible evidence, the orders of the lower forums were set aside and the complaints dismissed. vii) In Mahyco Vegetable Seeds Ltd. v. Ishwarbhai Baburao Thakare (supra), the learned NCDRC held that crop failure could not be attributed to defective seeds in the absence of conclusive laboratory evidence. Though the District Seeds Committee noted sterility and disease, it did not link these findings to seed defect, and no test report of the complainants’ samples was produced. Relying on the petitioner’s laboratory reports showing satisfactory germination and genetic purity and considering environmental factors, the Commission set aside the compensation and dismissed the complaint. viii) In Indo-American Hybrid Seeds v. Vijayakumar Shankarao (supra), the learned NCDRC held that poor crop yield by itself does not establish defect in seeds or deficiency in service. The Commission found that the Agriculture Officer’s report did not conclusively attribute the low yield to defective seeds and noted that external factors such as soil conditions, climate, and pesticide use could affect crop performance. In the absence of scientific testing or credible evidence proving seed defect, the compensatory orders were set aside and the complaint dismissed. ix) In Hindustan Insecticides Ltd. v. Kopolu Sambasiva Rao (supra), the learned NCDRC held that the complainants failed to establish that the insecticide supplied was defective or caused crop damage. The Commission noted non-compliance with the mandatory testing procedure under Section 13(1)(c) of the Consumer Protection Act and relied on laboratory reports certifying conformity with ISI standards. In the absence of conclusive proof of defect or deficiency in service, the revision petitions were allowed. The Commission noted non-compliance with the mandatory testing procedure under Section 13(1)(c) of the Consumer Protection Act and relied on laboratory reports certifying conformity with ISI standards. In the absence of conclusive proof of defect or deficiency in service, the revision petitions were allowed. x) In B. Yedukondalu (supra), the learned NCDRC held that the complainants failed to prove that the chilli seeds supplied were defective. The inspection reports noted deviations and pest infestation but did not attribute crop failure to seed defect, and no laboratory testing was conducted as required under Section 13(1)(c) of the Act, 1986. Holding that the burden of proof was not discharged and that the consumer fora misread the agricultural reports, the Commission set aside the compensation and dismissed the complaints. xi) In Syngenta India Ltd. v. P. Chowdaiah , (2013) 07 NCDRC CK 0003 , the learned NCDRC held that Thrips infestation and viral infection constituted plausible alternate causes for crop failure and could not, by themselves, establish defect in the seeds supplied. The Commission observed that delayed inspections and visual assessments without sample testing were insufficient to prove deficiency in service. Holding that the complainants failed to discharge the burden of proving seed defect, the learned NCDRC set aside the compensation awarded by the State Commission and restored the District Forum’s order. xii) In Garapati Srinivas Rao (supra), the learned NCDRC held that the complainant failed to establish defect in the seeds through scientific or laboratory evidence as mandated by the Seeds Act. The inspection reports were based on delayed visual assessments conducted without notice to the seed company and noted pest and viral infestation as alternate causes of crop failure. Holding that crop loss could result from multiple factors and that the complainant failed to prove sub-standard or defective seeds, the Commission set aside the State Commission’s order and allowed the revision petition. xiii) In Zimidara Agro Center (supra), the learned NCDRC held that allegations of defective seeds cannot be sustained solely on the basis of inspection reports prepared by non-accredited laboratories. The Commission found that the statutory requirement of testing through a notified or accredited government laboratory was not complied with. Due to this procedural infirmity and lack of reliable scientific evidence, the complaints against the seller were dismissed. The Commission found that the statutory requirement of testing through a notified or accredited government laboratory was not complied with. Due to this procedural infirmity and lack of reliable scientific evidence, the complaints against the seller were dismissed. xiv) In Mahyco Seeds Ltd. v. G. Venkata Subba Reddy , (2011) CPJ 99 NC (supra), the learned NCDRC held that the burden to prove genetic impurity in seeds lies squarely on the complainant. The Commission noted that the inspection was conducted only after harvest, at a stage when seed defects could not be scientifically assessed. In the absence of conclusive scientific evidence establishing genetic defect, the claim was rejected and liability was not fastened on the seed manufacturer. 26. Contentions of Respondents :- i) The present Civil Revision Petitions are gross abuse of process, as the petitioners, having suffered concurrent adverse findings before the District Forum, Warangal, the Telangana State Commission, Hyderabad, and the learned NCDRC, have invoked Article 227 of the Constitution of India, only to delay execution of lawful decrees in favour of small and marginal farmers. ii) All three fora, upon exhaustive appreciation of oral and documentary evidence including expert and governmental reports, have consistently held the petitioners guilty of deficiency in service and unfair trade practice in supplying defective VNR-145 hybrid chilli seeds. iii) 1 st respondents – complainants are agriculturists who purchased VNR-145 chilli seeds from the authorized dealer and cultivated in Warangal District, where the crop soon exhibited stunted growth, poor flowering, viral infection and total failure, resulting in loss of livelihood. iv) They deny the allegation that the respondents are “commercial cultivators”. Reliance placed on M. Madhusudhan Reddy (supra), which recognizes farmers purchasing seeds for self-cultivation as “consumers” under Section 2(1)(d) of the Act. v) Crop failure was directly attributable to genetic impurity and mis-branding, supported by the DNA Fingerprinting and Transgenic Crops Monitoring Laboratory Report dated 01-08-2017 (Ex. X-6), the Expert Committee Report dated 28-07-2017 (Ex. X-14), the assessment of Dr. B. Ram Prasad, Entomologist, RARS Warangal (Ex. B-8), and the petitioners’ own documents (Exs. B-9, B-14 and B-15) admitting long-term marketing of VNR-145 as a high-fruiting, heat- set hybrid yielding up to 160 quintals per acre. The District Forum, after analyzing Exs. A-1 to A-12, B-1 to B-16, X-1 to X-90 and testimony of PW-2 to PW-4, rightly fastened joint and several liability on the petitioners and dealer. B-9, B-14 and B-15) admitting long-term marketing of VNR-145 as a high-fruiting, heat- set hybrid yielding up to 160 quintals per acre. The District Forum, after analyzing Exs. A-1 to A-12, B-1 to B-16, X-1 to X-90 and testimony of PW-2 to PW-4, rightly fastened joint and several liability on the petitioners and dealer. Though compensation was reduced by the State Commission, the learned NCDRC, by its reasoned order dated 06-01-2025, restored the District Forum’s order. The learned NCDRC’s decision rests on concurrent findings of fact and law, raising no jurisdictional issue for interference under Article 227 of the Constitution of India. vi) Statutory laboratory and field reports establish non-compliance with the Seeds Act, 1966, Seeds Rules, 1968 and Seeds (Control) Order, 1983, including obligations under Sections 5–9 of the Act and Rules 13(3), 17 and 38, and that sale of mis-branded seed constitutes a per se defect and deficiency under Sections 2(f) and 2(g) of the 1986 Act. The theory of climatic causation is denied with reference to temperature data (2013-2017) annexed to Ex. X-14 and the categorical findings in Ex. X-6. Although licence cancellation was set aside on technical grounds, this Court in W.P. No. 14356 of 2017 expressly preserved farmers’ right to claim compensation. vii) The petitioners have approached this Court without full disclosure of material facts, having selectively withheld the complete set of exhibits and omitted to disclose that no application for re-testing under Section 13(1)(c) of the Act was ever made despite their statutory obligation to preserve samples. Thus, there is suppression of material evidence. viii) The petitioners failed to preserve or seek re-testing of samples as required under Rule 13(3) of the Seeds Rules and Section 13(1)(c) of the Act, attracting the principle in Alavalapati Chandra Reddy (supra), and that objections based on Rule 25 of the Rules, are barred by pleadings in view of Ex. X-2, relying on Neelam Gupta v. Rajendra Kumar Gupta , 232015 SCC OnLine SC 1972 ix) Placing reliance on Ghaziabad Development Authority (supra), complainants contend that prolonged litigation against farmers, defeats the humanitarian object of consumer law. Having waited over eight years for relief, any further delay would amount to denial of substantive justice. X-2, relying on Neelam Gupta v. Rajendra Kumar Gupta , 232015 SCC OnLine SC 1972 ix) Placing reliance on Ghaziabad Development Authority (supra), complainants contend that prolonged litigation against farmers, defeats the humanitarian object of consumer law. Having waited over eight years for relief, any further delay would amount to denial of substantive justice. x) Placed reliance on the judgments in Alavalapati Chandra Reddy ; Nandan Biomatrix Ltd, M. Madhusudhan Reddy , Fortune Hybrid Seeds Ltd., (supra), Seeds works International Pvt, Ltd v. Nampally Sudhakar, Decided by LEARNED NCDRC Delhi 06.05.2015 in R.P. No. 2742 of 2014 batch ; Ghaziabad Development Authority Neelam Gupta (supra); Shrihari Limraj Karanjkar vs Ajeet Seeds Limted , 2021 (1) CPR (NC) 80 ; H.N. Shankara Shastry vs Asst Director of Agriculture Karnataka , 2004 SCC online SC 648 ; VNR seeds Pvt Ltd vs The State of Telangana , WP no. 40269 of 2017 decided on 12.12.2017 VNR seeds Pvt Ltd vs The State of Telangana , WP no. 14356 of 2017 decided on 11.10.2017 ; Waryam Singh vs Amarnath , 1954 SCC Online SC 13 ; Shalini Shyam Shetty vs Rajendra Shankar Patil , (2010) 8 SCC 329 Managing director, Kerela Tourism Development Corporation Ltd vs Deepti Singh , 2019 0 Supreme (SC) 408 ; Estralla Reubber vs Dass Estate Ltd , 2001 SCC online SC 1097 Garmet Craft vs Prakesh Chad Goel , 2022 4 SCC 181 ; Rasi Seeds Pvt.Ltd vs Bhagwan , Revision Petition No. 4598 of 2010 27. Case laws cited by the Respondents: i) The respondents have placed strong reliance upon a series of binding and persuasive precedents. ii) In Alavalapati Chandra Reddy (supra), the Supreme Court held that a farmer purchasing seeds for cultivation and not for resale is a “consumer” under the Consumer Protection Act, 1986. It was clarified that sale of the agricultural produce does not amount to a commercial purpose and that the scale of cultivation or volume of sale is immaterial. The decisive test is whether the dominant intention is livelihood and sustenance, a principle squarely applicable to farmers alleging crop loss due to defective seeds. iii) In Nandan Biomatrix Ltd . (supra), the National Commission held that supply of defective or misbranded seeds constitutes “deficiency in service” under Section 2(1)(g) of the Consumer Protection Act, 1986. The decisive test is whether the dominant intention is livelihood and sustenance, a principle squarely applicable to farmers alleging crop loss due to defective seeds. iii) In Nandan Biomatrix Ltd . (supra), the National Commission held that supply of defective or misbranded seeds constitutes “deficiency in service” under Section 2(1)(g) of the Consumer Protection Act, 1986. The Commission observed that once germination failure or poor yield is established through official inspection or scientific analysis, the burden shifts to the manufacturer to disprove defect, and liability cannot be avoided by attributing loss to climatic or pest-related factors. This principle squarely applies where farmers produce DNA and field inspection reports indicating genetic variation in the seeds supplied. iv) In M. Madhusudhan Reddy (supra), the Supreme Court authoritatively held that supply of defective or substandard seeds resulting in crop loss constitutes “deficiency in service” under the Consumer Protection Act. The Court recognised farmers purchasing seeds for self-cultivation as “consumers” and held seed manufacturers statutorily responsible for maintaining prescribed standards of germination and genetic purity. Liability was held to arise once official testing reveals deviation from such standards, forming a foundational precedent in agricultural consumer jurisprudence. v) In Fortune Hybrid Seeds Ltd. (supra), learned NCDRC held that once defective hybrid seeds or deviation in varietal characteristics is established through official inspection or laboratory analysis, liability under the Act follows, and pleas of adverse weather or pest attack cannot exonerate the manufacturer. The Commission further observed that government testing procedures are presumed valid unless disproved by credible expert evidence and that misleading labelling and non-compliance with mandatory standards constitute both deficiency in service and unfair trade practice, warranting compensation for crop loss and mental agony. vi) In Nampelly Sudhakar (supra), the Supreme Court dismissed petitions filed by a seed manufacturer arising from identical findings of deficiency by the consumer fora and directed payment of compensation to farmers. Though the Court left the question of law open, the dismissal signified affirmation of concurrent factual findings against the manufacturer and lends persuasive weight to the conclusion that such deficiencies warrant consumer redress. vii) In Ghaziabad Development Authority (supra), the Supreme Court held that “deficiency in service” under the Consumer Protection Act encompasses failure to perform statutory or contractual obligations within a reasonable time, including administrative delay and arbitrary conduct causing harassment. vii) In Ghaziabad Development Authority (supra), the Supreme Court held that “deficiency in service” under the Consumer Protection Act encompasses failure to perform statutory or contractual obligations within a reasonable time, including administrative delay and arbitrary conduct causing harassment. Emphasising the welfare nature of the legislation, the Court affirmed the power of consumer fora to award compensation not only for monetary loss but also for mental agony and inconvenience, guiding a broad and remedial interpretation of consumer rights. viii) In Neelam Gupta (supra), the Supreme Court emphasised that judicial interference must be exercised with circumspection where concurrent findings subsist. The Court held that interim protections such as maintenance of status quo are warranted to preserve the subject-matter pending final adjudication and to prevent prejudice arising from multiplicity of proceedings. The decision reinforces the principle that authorities must act within jurisdiction and respect subsisting orders of competent fora. ix) In Alavalapati Chandra Reddy (supra), the Supreme Court held that while agriculture is a livelihood activity, a complainant must establish a clear nexus between defective seeds and crop loss. The Court observed that climatic conditions, soil quality, and agronomic practices are relevant factors, and that crop failure alone does not automatically establish deficiency in service. The judgment strikes a balance between safeguarding farmers and protecting manufacturers from speculative claims absent scientific proof. x) In Shrihari Limraj Karanjkar (supra), the National Commission held that the initial burden lies on the complainant to establish prima facie deficiency. It was observed that field inspections conducted without notice to the manufacturer and without laboratory testing under Section 13(1)(c) of the Act are insufficient to fasten liability. The Commission recognised that agricultural loss may arise from external factors, and unless these are excluded by cogent evidence, deficiency cannot be presumed against the seed supplier. xi) In H. N. Shastry (supra), the Karnataka High Court held that administrative or preliminary reports prepared without strict adherence to the sampling and testing procedures prescribed under the Seeds Rules, 1968 cannot form the basis for penal or regulatory action. The Court emphasised that where statutory provisions mandate testing through notified laboratories, any non-compliance vitiates the entire action. This principle underscores that findings of misbranding or deficiency cannot be sustained without compliance with mandatory procedural safeguards. The Court emphasised that where statutory provisions mandate testing through notified laboratories, any non-compliance vitiates the entire action. This principle underscores that findings of misbranding or deficiency cannot be sustained without compliance with mandatory procedural safeguards. xii) In VNR Seeds (supra), in W.P. No. 40269 of 2017 , the High Court set aside the cancellation of a seed dealer’s licence on the ground that the facts and issues were identical to those decided earlier in W.P. No. 14356 of 2017 and batch. The Court held that once a coordinate Bench has declared the procedure adopted by the licensing authority to be contrary to the Seeds Rules and the Seeds (Control) Order, 1983, administrative consistency mandates that similar cases be decided on the same reasoning. The writ petition was accordingly allowed and the licence restored, underscoring the principle of uniformity in administrative adjudication. xiii) In VNR Seeds (supra), W.P. No. 14356 of 2017 and batch, the High Court held that cancellation of licences of seed distributors without compliance with Rule 23-A of the Seeds Rules, and without recording specific findings of statutory violation, is unsustainable in law. The Court emphasised that authorities must clearly distinguish between the roles of manufacturers and distributors and cannot impose collective liability absent proof of mens rea or procedural compliance. The writ petitions were allowed, licences restored, and the authorities cautioned to strictly adhere to the prescribed inspection and testing procedures in future actions. Analysis and Findings of the Court:- 28. It is apt to note that both learned counsel for the petitioners and learned counsel appearing for respondents on instructions, submitted that 427 Farmers filed complaints under Section 12 of the Act, 1986 against the petitioners before the District Consumer Forum, Warangal, out of which, the District Consumer Forum allowed 419 complaints in part and dismissed 08 complaints for default. 29. Petitioners herein preferred 419 appeals before the State Commission and State Commission allowed 138 appeals in toto and 274 appeals in part. 07 appeals were dismissed for default. It is also brought to the notice of this Court that the restoration applications filed in the said 07 appeals to restore the appeals to its original position are pending in State Commission. 30. It is further submitted that 466 revisions were filed before learned NCDRC by the Manufacturer, dealer and Farmers challenging the said orders passed by the State Commission. 30. It is further submitted that 466 revisions were filed before learned NCDRC by the Manufacturer, dealer and Farmers challenging the said orders passed by the State Commission. learned NCDRC has disposed of the said 466 revisions vide common order dated 06.01.2025. 31. Challenging the said common order, petitioners herein and manufacturers filed the present 466 revisions. Out of them, CRP No.2940 of 2025 was dismissed by this Court on 25.09.2025 as withdrawn. 32. There is no dispute that respondents – Farmers purchased chilli seeds from the petitioners, manufacturer. It is also not in dispute that there was crop failure. 33. It is the specific contention of the 1 st respondents – farmers that the petitioners have supplied defective, mis-branded, genetically poor chilli seeds. Thus, there is defect in manufacturing of the said seeds and there is deficiency in service. According to them, petitioners made them to believe that the seeds are genetically pure, high performing and superior quality hybrid. The said seeds are genetically stable. But the petitioners have supplied defective, mis-branded, genetically poor chilli seeds contrary to the assurance given by them. 34. Whereas, according to the petitioners, they have supplied genetically pure seeds and farmers did not irrigate properly, they did not use pesticides as recommended by them, there was Thrips infestation which is nothing to do with the genetic makeup of the seed, temperature was very high and there are adverse weather conditions in the subject area. 35. It is apt to note that the respondents – farmers examined 04 witnesses i.e. P.Ws.1 to P.W.4 and filed EXs.A.1 to A.12 (the number of exhibits marked by the complainants differ from case to case). 36. Whereas, petitioners herein examined 02 witnesses i.e. R.W.1 and R.W.2, filed Exs.B.1 to B.16. Learned District Consumer Forum marked Exs.X.1 to X.19 through P.Ws.3 and 4. 37. P.W.1 is Farmer – Complainant, P.W.2 is Assistant Director, Agriculture, Hyderabad, P.Ws.3 and 4 are District Agriculture Officers. 38. It is also not in dispute that there was complaint against the petitioners, manufacturers by the huge number of farmers belong to several villages of Atmakur Mandal of Warangal District, alleging that petitioners supplied defective chilli seeds due to which there was crop failure and they sustained huge loss. 38. It is also not in dispute that there was complaint against the petitioners, manufacturers by the huge number of farmers belong to several villages of Atmakur Mandal of Warangal District, alleging that petitioners supplied defective chilli seeds due to which there was crop failure and they sustained huge loss. They have written a letter/complaint to the District Collector, Warangal, with a request to do justice who in turn, informed the same to the Agriculture Officer, Joint Director of Agriculture, Warangal, District Horticulture and Sericulture Officers. 39. The District Agriculture Officer, Warnagal, vide his letter dated 07.07.2017 directed the Mandal Agriculture Officer to conduct joint inspection with Horticulture Officer and report compliance at the earliest. In compliance with the same, vide letter dated 10.07.2017, Mandal Agriculture Officer, informed the Assistant Director of Agriculture, Telangana, DNA Fingerprinting crops, monitoring Lab that he is sending green chillies leaves of 50 plants (randomly selected) for analysis. The Joint District Level Committee conducted a visual inspection on 11.07.2017 and subsequently submitted its report stating that the crop had been severely affected by Thrips incidents, during initial crop growing stage, attributed to the prevalence of high temperatures. The crop was affected by viral diseases such as Peanut Bud Necrosis Virus (PBNV) and Cucumber Mosaic Virus (CMV) which led to poor growth. 40. On 01.08.2017, the genetic purity test report was submitted to the District Agriculture Officer, Warangal, and the Commissioner of Agriculture, Telangana, who in turn drawn conclusion that the genetic purity test revealed that field sample differs from the standard profile , then rendered the sample as ‘mis-branded’. 41. It is also apt to note that petitioners herein, manufacturers of subject chilli seeds and dealers filed counters before the District Consumer Forum. 42. It is also apt to note that Farmers – Complainants examined themselves as P.W.1 and they specifically deposed that petitioners and their dealers came to their villages, gave wide publicity in respect of VNR 145 chilli seeds, assured them and the other farmers of the villages with regard to the quality of the said seed. They have also assured that there would be 100 to 150 qunitals per acre of yield of green chillies. They have also brought photographs, posters and pamphlets of their company seed grown elsewhere. They have also assured that there would be 100 to 150 qunitals per acre of yield of green chillies. They have also brought photographs, posters and pamphlets of their company seed grown elsewhere. They have assured that the said chilli seeds are having resistance to jassids (leaf hoppers) inherently, heavy heat and cool withstand against rain and other diseases. Thus, the petitioners made the farmers including the complainants herein to believe the aforesaid aspects and on the said belief, they have purchased VNR 145 chilli seeds. 43. They have also specifically deposed with regard to details of purchase, cultivation, apply of fertilizer, pesticides, as advised by the petitioners and also about loss of crop including germination and sustenance of loss. In proof of the same, they have filed cash bills, pattadar passbooks, show cause notice, representation submitted to the District Collector etc. 44. Petitioners cross-examined the complainants at length but nothing useful was elicited from them during cross-examination. 45. It is also apt to note that the complainants examined Assistant Director, Agriculture, Hyderabad, who is also DNA Fingerprint expert as P.W.2, District Agriculture Officers as P.Ws.3 and 4. The District Consumer Forum, marked correspondence between them and also reports submitted by them. 46. P.Ws.2 to 4 were cross-examined by the petitioners and nothing useful was elicited from them. 47. It is also apt to note that P.W.2 Assistant Director of Agriculture, who is also DNA Fingerprint Expert, specifically deposed about collection of samples including collection of 50 leave samples from Akkampet village, standard hybrid and parental line samples from the petitioners. She has extracted DNA from each leave using ISSR markers 809, 823 and 886, the molecular profiles were compared with the standard hybrid type sample provided by the petitioners, the laboratory report i.e. Ex.X.6, dated 01.08.2017 and declared the field sample ‘mis-branded’ as its molecular profile did not match the standard parental line. She also gave a clarification with regard to examination of lot No.1870 only as it represented the common parental line supplied to all dealers and therefore, the test results would uniformly apply to all farmers. 48. She further deposed that she requested the petitioners company to furnish gel prints or marker details and petitioners did not furnish the same. 49. However, during cross-examination she has admitted that the gel prints will be supplied and that she has not received the gel prints. 48. She further deposed that she requested the petitioners company to furnish gel prints or marker details and petitioners did not furnish the same. 49. However, during cross-examination she has admitted that the gel prints will be supplied and that she has not received the gel prints. The District Agriculture Officer, will give license to manufacturing companies to sell the seeds in market world, for the purpose of manufacturing the seeds, the Commissioner of Agriculture will accord permission to the seeds companies. After determining the genetic purity and SSR markers and gel prints, the license will be given for the purpose of manufacturing seeds. The centre license is meant for both for manufacturing and for sales. The gel prints will be given to only commissioner of Agriculture. 50. Thus, nothing useful was elicited from her during cross-examination. 51. As discussed supra, petitioners herein examined Sri P.Srinivasa Swamy, Zonal Manager as R.W.1 and Mr. Paraq Agarwal, Breeder as R.W.2, who deposed that the seeds supplied by the petitioners are genetically pure, high quality hybrids and there is no genetic defect in the said chilli seeds purchased by the farmers –complainants. There is no deficiency of service on their part. 52. It is also apt to note that in some complaints, petitioners examined the dealer as R.W.3. 53. On consideration of the said evidence both oral and documentary, vide order dated 30.01.2020, learned District Consumer Forum, allowed the said complaints in part, holding that the seeds supplied by the petitioners are ‘mis-branded’, genetically poor and there is deficiency in service. Learned District Forum also considered Field Inspection Report, District Level Report, and DNA Fingerprint Laboratory Report. Learned District Forum also considered the bills filed by the complainants, pattadar passbooks etc, for the purpose of computation of loss. Ultimately, learned District Forum held that both the manufacture and dealer are jointly and severely liable and directed them to pay an amount of Rs.1,35,000/- towards crop loss per acre along with 7.5% interest per annum from the date of filing of the complaint i.e. 12.06.2018 till date of realization of the same. Learned District Forum also directed the petitioners and dealer to pay an amount of Rs.35,000/- per acre to the complainants towards expenditure incurred by them including costs of seeds, Rs.10,000/- towards metnal agony, legal expenses including costs within one month from the date of receipt of copy of the said order. 54. Learned District Forum also directed the petitioners and dealer to pay an amount of Rs.35,000/- per acre to the complainants towards expenditure incurred by them including costs of seeds, Rs.10,000/- towards metnal agony, legal expenses including costs within one month from the date of receipt of copy of the said order. 54. As discussed supra, learned District Forum, answered all the three points in favour of the complainants. District Forum gave specific reasoning on all the aforesaid three issues including computation. 55. Petitioners herein preferred appeals before the State Commission challenging the said orders passed by the District Forum. The State Commission allowed some appeals filed by the petitioners on the ground that the complainants did not file evidence such as bills in proof of the purchase of the seeds, ownership of the cultivated land, details of family members, use of pesticides and proof of crop loss. However, the State Commission allowed some appeals in part and reduced interest on the ground that complainants have not filed proper documents and without considering the said aspects, District Forum allowed complaints in part and directed the petitioners to pay the compensation in the manner stated supra. 56. It is also apt to note that in some appeals which were allowed, State Commission considered the fact that farmers failed to file bills for purchase of the seeds, land documents, date of purchase and sowing and transplantation of the seedlings. District Forum passed impugned orders in an uniform manner mechanically without examining the aforesaid relevant documents. With the said findings, learned State Commission allowed some appeals filed by the petitioners in toto. 57. Whereas, learned NCDRC considered appointment of Committee, drawing of samples by the Committee, sending the same for examination in the labs and submission of report. learned NCDRC also considered the depositions of P.Ws.1 to 4 more particularly, P.W.2 Assistant Director of Agriculture, DNA Fingerprint Expert, Seed Analysis lab report, dated 04.05.2017, genetic purity analysis, using PCR based marker, Field Inspection Report, Literature/packet of VNR 145 morphological and distinguishable characters of Hybrid chillies and Breeder certificates and also tooth labels of VNR seed. learned NCDRC also considered District Level Committee report, weather report issued by RARS, Warangal, Joint Inspection Report and other documents exhibited through P.Ws.3 and 4 before the District Forum. 58. learned NCDRC also considered District Level Committee report, weather report issued by RARS, Warangal, Joint Inspection Report and other documents exhibited through P.Ws.3 and 4 before the District Forum. 58. It is apt to note that in the said Joint Inspection report, it was reported as follows:- i. Crop is at the stage of flowering to fruiting stage having upward curling with low flowering and fruiting, ii. Plants not shows uniformity, some plants at the stage of pre-flowering, some plants at the stage of flowering to fruiting stage and some plants severely attacked by viral disease. 59. Five Men Committee constituted for the propose of investigation of failure of chilli crops consisting of scientist, horticulture and head HRS, Manepally, Nalgonda. Scientist (Entomology, RARS , Warangal, District Horticulture and Sericulture Officer, Warangal Urban and Rural District, Assistant Director, Agriculture, Horticulture Officer, visited fields and submitted report. 60. It is also not in dispute that on the recommendations of the Committee, a genetic purity test was also conducted after collecting leaves from the fields and VNR 145 hybrid standard type sample submitted by the seed company. A genetic purity test was conducted in Telangana DNA Fingerprinting and Transgenic Crop monitoring lab, Hyderabad. The said genetic purity test revealed that as per the field sample, molecular profile is different from the standard molecular profile, the sample is declared as ‘mis-branded’. The said report was also marked as Exhibit. Petitioners herein failed to falsify the said report during cross-examination or by producing any other contra evidence. 61. Learned NCDRC considered the said aspects and disposed of the revisions filed by the petitioners vide impugned common order. 62. The sum and substance of contentions of the petitioners are as follows:- i. Burden lies on the complainants – farmers to prove that the seeds are defective. ii. Genetic purity cannot be established through visual site inspection. iii. The complainants -farmers have to show nexus between defect in seeds and crop failure, iv. The alleged visual inspection by the Committee was not independent and it was behind the back of the petitioners. v. In-house lab report of the petitioners will prevail over the site inspection report. vi. Procedural lapses on the part of the complainants. vii. Proceedings issued by the Department cancelling the manufacturing license was set aside by the High Court. viii. The alleged visual inspection by the Committee was not independent and it was behind the back of the petitioners. v. In-house lab report of the petitioners will prevail over the site inspection report. vi. Procedural lapses on the part of the complainants. vii. Proceedings issued by the Department cancelling the manufacturing license was set aside by the High Court. viii. There was Thrips infestation which cannot be attributed to the genetic purity of the seeds and farmers did not take necessary steps to control such infestation. 63. In the light of the said submission, it is apt to note that the dispute concerning alleged defective seeds, the complainants must ultimately establish i) the seeds supplied have suffered from defects/substandard quality in a manner materially affecting the performance. ii) and such defect bore a proximity nexus with the loss of crop on the consequential damages claimed. 64. There is no dispute that there was crop failure and such crop failure by itself does not automatically lead to an inference of defective seed. Nonetheless, where the material on record demonstrate genetic deviation ‘ mis-branded’ coupled with consistent field level failure traceable to the supplied variety, the above nexus requirement stands satisfied. 65. A conjoint reading of the Seeds Act, 1966 and the Seeds Rules, 1968 makes it clear that the authority to test and certify the quality, purity and genetic characteristics of seeds is vested exclusively in the Central Seed Laboratory or State Seed Laboratory notified under Section 4 of the Act, and such testing can be undertaken only by duly qualified Seed Analysts appointed in accordance with the Act and Rules. Sections 14 to 16 of the Act, read with Rules 20 to 33 of the Seeds Rules, prescribe a mandatory procedure for sampling, sealing, dispatch and scientific analysis, and confer statutory finality on reports issued by such notified laboratories. The Act does not recognize DNA or genetic testing conducted by non-notified laboratories or by officers not qualified as Seed Analysts. Consequently, any DNA or genetic purity test relied upon for regulatory or adjudicatory purposes must strictly conform to the statutory framework, failing which such reports lack legal sanctity and cannot form the basis for a finding of misbranding, genetic impurity or deficiency in service. 66. It is also significant to note that PWs. Consequently, any DNA or genetic purity test relied upon for regulatory or adjudicatory purposes must strictly conform to the statutory framework, failing which such reports lack legal sanctity and cannot form the basis for a finding of misbranding, genetic impurity or deficiency in service. 66. It is also significant to note that PWs. 2 to 4 are independent and official witnesses, being officers of the State discharging statutory functions under the Seeds Act and the Seeds Rules. They conducted the inspections and tests in the course of their official duties and in accordance with the prescribed procedure. The petitioners have neither alleged nor established any bias or animus on their part in favour of the complainants, and no suggestion to that effect was even put to these witnesses during cross-examination. 67. Section 13 of the Act, 1986 deals with procedure on admission of complaint. Section 13(1) (c) of the Act, 1986 says that the District Forum shall on admission of complaint if it relates to any goods where the complaint alleges in defect in the goods which cannot be determined without proper analysis or test of the goods, District Forum shall obtain sample of the goods from the complainant, obtain report etc. In the present case, District Forum placed reliance on the Field Inspection Report and DNA Fingerprinting report etc. On consideration of the same, District Forum, gave a specific finding that the seeds supplied by the petitioners are of mis-branded, defective and there is deficiency of service. 68. It is also apt to note that by filling the aforesaid documents and by examining P.Ws.1 to 4, the complainants discharged their initial burden. Therefore, petitioners cannot contend that the complainants failed to discharge their burden. Thus, once the complainants have discharged their initial burden, the burden shifts on the petitioners to prove that they have supplied the goods properly without any defect and there is no deficiency in service by rebutting prima facie evidence as held by the Supreme Court in M.Madhusudhan Reddy (supra). They have to lead reliable contra evidence. In the present case, petitioners utterly failed to do so. 69. As discussed supra, petitioners entered appearance before the District Forum and filed their counters. They have cross-examined the complainants’ witnesses and also filed documents. They have not pleaded the aforesaid aspects in the counters. They have to lead reliable contra evidence. In the present case, petitioners utterly failed to do so. 69. As discussed supra, petitioners entered appearance before the District Forum and filed their counters. They have cross-examined the complainants’ witnesses and also filed documents. They have not pleaded the aforesaid aspects in the counters. They have raised several grounds for the first time before the State Commission, learned NCDRC and this Court which they have not raised before the District Forum. 70. It is trite law that the petitioners herein have to plead and prove by producing reliable evidence to show that they have supplied genetically pure seeds and that there was no deficiency in service. They have to disprove the allegations, contentions of the complainants – farmers that the petitioners supplied defective seed and there is deficiency in service. In the present case, petitioners herein failed to plead and prove the same. 71. With regard to the contentions of the petitioners that this Court in a batch of writ petitions set aside the proceedings issued by the Agriculture Department cancelling the manufacturing license issued in favour of the petitioners. However, perusal of the said orders would reveal that this Court set aside the cancellation proceedings pointing out procedural irregularities. The said orders will not have any bearing on the present proceedings. The said order will not preclude the complainant’s remedies under the Act, 1986. 72. It is also relevant to note that complainants filed bills, proof of land owned by them etc. Even then, petitioners failed to dispute the same and did not elicit anything from P.W.1 (complainants). They have not examined the dealer to disprove the said bills and in fact, the said bills are certified by the dealer. 73. It is also apt to note that as per Rule 38 of the Seeds Rules, 1968, a person carrying on a business of seeds shall maintain record i.e. stock record of seeds, record of sale of seeds. Rule 2(g) deals with definition of complete record and it says the information which relates to the origin, variety, kind, germination and purity of seed of any notified kind or variety offered for sale, sold or otherwise supplied. Rule 13 of the Rules, deals with requirements to be complied with by a person carrying on the business of seeds. Rule 2(g) deals with definition of complete record and it says the information which relates to the origin, variety, kind, germination and purity of seed of any notified kind or variety offered for sale, sold or otherwise supplied. Rule 13 of the Rules, deals with requirements to be complied with by a person carrying on the business of seeds. In the present case, the petitioners failed to produce the same to disprove the bills submitted by the complainants and also to disprove the claim of the complainants. 74. It is also apt to note that petitioners did not file any objections to the aforesaid reports. 75. Petitioners have to maintain certain statutory forms in terms of Seeds Rules. They have not produced the said forms. 76. Petitioners did not take any steps before the District Forum to send the samples to lab for conducting genetic purity test in terms of Section 13 of the Act, 1986. Therefore, they cannot contend that all the necessary markers were not considered in the DNA Fingerprinting report. 77. It is also apt to note that State Commission allowed some appeals filed by the petitioners on the ground that the complainants failed to file bills, proper documents regarding purchase of seeds, crop loss etc. Complainants – farmers, cannot be expected to preserve the bills under which they purchased the subject chilli seeds. Farmers being common people, cannot be expected to assume or presume there would be a crop loss. 78. This Court has carefully scrutinized the entire record, including the depositions of witnesses, reports of the District-Level Committee, Laboratory findings of the Telangana DNA Fingerprinting & Transgenic Crops Monitoring Laboratory, Hyderabad, official communications between the Department of Agriculture and the Manufacturer, and ancillary documentary material such as invoices, weather reports, and market-rate certificates. The concurrent findings of the District Forum, State Commission, and National Commission rest upon this comprehensive body of evidence. 79. It is well settled that the ‘Complainants–farmers’ fall within the definition of “consumer” under Section 2(1)(d) of the Act, 1986, and the objection raised by the petitioners on the ground of “commercial cultivation” is untenable. The Supreme Court in M. Madhusudhan Reddy (supra) authoritatively held that farmers who purchase seeds for cultivating their own land, remain consumers, even if the agricultural produce is sold, such activity is essentially for livelihood and sustenance and not a commercial enterprise. The Supreme Court in M. Madhusudhan Reddy (supra) authoritatively held that farmers who purchase seeds for cultivating their own land, remain consumers, even if the agricultural produce is sold, such activity is essentially for livelihood and sustenance and not a commercial enterprise. This principle was reiterated in Alavalapati Chandra Reddy (supra), wherein the Court applied the ‘dominant purpose test’ and clarified that the scale of cultivation or volume of sale is immaterial so long as the primary object is earning livelihood. In the light of these binding precedents, the respondents were rightly treated as consumers by the fora below, and the proceedings under the Act, 1986 are clearly maintainable, warranting no interference on this ground. 80. It is also well settled law that the supply of defective or sub-standard seeds resulting in crop loss constitutes “deficiency in service” within the meaning of Section 2(1)(g) of the Act, 1986. The Supreme Court in M. Madhusudhan Reddy (supra) held that seed manufacturers owe a statutory and contractual duty to maintain prescribed standards of quality, germination and genetic purity, and any deviation therefrom, once established through official inspection or scientific material, attracts liability under consumer law. The NCDRC in Nandan Biomatrix Ltd. (supra) and Fortune Hybrid Seeds Ltd. (supra) further clarified that where prima facie defect or misbranding is demonstrated, the manufacturer cannot evade responsibility by attributing crop failure to climatic or pest-related factors. In the present case, the concurrent findings of the consumer fora, based on expert reports and official inspections, clearly establish ‘deficiency in service’ on the part of the petitioners, and the said conclusion is in absolute consonance with the settled jurisprudence governing seed-related consumer disputes. 81. The Act, 1986 is a beneficial and remedial legislation enacted with the object of providing speedy, inexpensive and effective redressal to consumers, and prolonged litigation runs directly contrary to its legislative intent. The Supreme Court in Ghaziabad Development Authority (supra) underscored that consumer fora must discourage tactics which delay relief and cause continued harassment to consumers, particularly those who are economically vulnerable. In the context of agricultural disputes, where farmers depend on a single crop cycle for their livelihood, repeated and successive challenges to concurrent findings only serve to defeat the very purpose of the Act. In the present case, the dispute relates to the agricultural season of 2017, and the respondents have been compelled to litigate for several years across multiple fora. In the present case, the dispute relates to the agricultural season of 2017, and the respondents have been compelled to litigate for several years across multiple fora. Such protraction of proceedings, in the absence of any demonstrated jurisdictional error, is antithetical to the object of the Act, 1986 and cannot be countenanced. 82. The scope of interference under Article 227 of the Constitution of India, is supervisory and not appellate, and it does not permit re-appreciation of evidence or substitution of factual conclusions reached by competent fora. It is a settled principle that where concurrent findings of fact have been recorded by the tribunals below after due consideration of the material on record, such findings do not warrant interference unless they are shown to be perverse, based on no evidence, or vitiated by jurisdictional error. The Supreme Court in Jai Singh (supra) and this Court in Neelam Gupta (supra) have emphasized that supervisory jurisdiction is to be exercised sparingly and with circumspection. In the present case, the District Forum and learned NCDRC gave consistent findings of deficiency in service founded on scientific and documentary evidence, and no perversity or patent illegality has been demonstrated. Interference under Article 227 of the Constitution of India, in such circumstances would amount to converting the supervisory jurisdiction into an appellate forum, which is impermissible in law. 83. It is relevant to note that on consideration of the aforesaid aspects, learned District Forum allowed the complaints filed by the farmers and awarded compensation. Learned State Commission allowed some appeals filed by the petitioners, set aside the orders passed by the District Forum on the ground that the complainants failed to file bills etc. The said findings of the State Commission are erroneous and contrary to the principle laid down in the aforesaid judgments. However, learned NCDRC considered the said aspects and disposed of the revisions filed by the petitioners herein and complainants vide common order dated 06.01.2025. It is a reasoned order and well founded. Petitioners herein failed to make out any case to interfere with the said order. 84. As discussed supra, there are concurrent findings by the learned District Forum and learned NCDRC with regard to supply of mis-branded defective seeds and there is deficiency in service resulting in crop loss and that farmers – complainants suffered loss. There are concurrent findings with regard to computation of loss. 84. As discussed supra, there are concurrent findings by the learned District Forum and learned NCDRC with regard to supply of mis-branded defective seeds and there is deficiency in service resulting in crop loss and that farmers – complainants suffered loss. There are concurrent findings with regard to computation of loss. But State Commission erred in setting aside some of the orders passed by the District Forum and reducing the compensation awarded by the District Forum in complaints. The said findings are contrary to the object of the Act, 1986, procedure laid down under Seeds Act and Rules, and also principles laid down in the aforesaid judgments. 85. It is also apt to note that learned counsel for the petitioners on instructions, submitted that the liability of the petitioners to comply with orders passed by the District Forum would be around Rs.11 Crores and learned NCDRC would be Rs.9 Crores, in compliance with the interim orders passed by this Court, the petitioners have already deposited Rs.4.5 Crores. 86. As discussed supra, complainants in all the complaints are consumers and the complaints filed by them before the District Forum under Section 12 of the Act, 1986 are maintainable. There is deficiency of service on the part of the petitioners herein. Conclusion :- 87. In the light of the aforesaid discussion, as discussed supra, the impugned common order dated 06.01.2025 passed by the learned NCDRC is a reasoned order and well founded. It does not require interference by this Court by invoking its powers under Article 227 of the Constitution of India. Thus the present revisions fail, they are liable to be dismissed and accordingly dismissed.