Who is Consumer? Discuss with the help of decided case laws.

A consumer is an individual or entity that purchases goods or services for personal use, consumption, or utilization. Consumer rights and protections are established to safeguard the interests of consumers in transactions with businesses and to ensure fair and equitable treatment. Here's a discussion of the definition of a consumer with the help of decided case laws:

1. State of H.P. v. H.P. State Electricity Board (1991):

   • In this case, the Supreme Court of India defined a consumer as "a person who consumes any goods purchased by him for a consideration, either for private use or for use in the manufacturing process, or for any other purpose."
   • The court clarified that the term "consumer" includes not only individuals purchasing goods or services for personal use but also businesses or entities that acquire goods or services for commercial or industrial purposes.

2. LIC of India v. Consumer Education & Research Centre (1995):

   • In this landmark case, the Supreme Court expanded the definition of a consumer to include beneficiaries of services provided by statutory bodies or corporations, even if they did not directly pay for those services.
   • The court held that individuals who benefit from services provided by public utilities, government agencies, or statutory bodies, such as electricity, water supply, or healthcare, qualify as consumers entitled to protection under consumer laws.

3. Haryana Financial Corporation v. Jagdamba Oil Mills (2002):

   • In this case, the Supreme Court emphasized that the term "consumer" under the Consumer Protection Act, 1986, is broad and encompasses not only purchasers of goods or services but also recipients or beneficiaries of those goods or services.
   • The court clarified that the focus of consumer protection laws is on the end-user or beneficiary of goods or services, regardless of whether they directly paid for those goods or services.

4. Municipal Council, Ahmednagar v. Shah Hyder Beig (2000):

   • In this case, the National Consumer Disputes Redressal Commission (NCDRC) held that tenants renting residential or commercial premises are considered consumers under the Consumer Protection Act, 1986.
   • The commission ruled that tenants who pay rent to landlords for the use of premises qualify as consumers entitled to protection against deficiencies in housing facilities or landlord-tenant disputes.

These case laws highlight the inclusive nature of the definition of a consumer under consumer protection laws, encompassing not only buyers of goods or services but also beneficiaries, users, and renters. The decisions of courts and consumer tribunals have expanded the scope of consumer rights and protections to ensure that individuals and entities receive fair treatment, quality products, and satisfactory services in their transactions with businesses and service providers.