Appeal, Finality of Orders and Limitation under the Consumer Protection Act, 2019
The Consumer Protection Act, 2019 is the current central law governing consumer disputes in India. For the subjects formerly dealt with by Sections 23, 24 and 24A of the Consumer Protection Act, 1986, the corresponding provisions are now Sections 67, 68 and 69 of the 2019 Act.
Section 67 - Appeal against order of National Commission
Section 67 provides a statutory appeal to the Supreme Court for a person aggrieved by an order made by the National Consumer Disputes Redressal Commission in exercise of the original jurisdiction specified in Section 58(1)(a)(i) or (ii).
The appeal must ordinarily be filed within 30 days from the date of the order. The Supreme Court may entertain a delayed appeal where it is satisfied that sufficient cause prevented filing within that period.
Where the appellant is required to pay an amount under the National Commission's order, the appeal is not entertained unless 50 per cent of that amount is deposited in the prescribed manner.
Section 68 - Finality of orders
Section 68 states that an order of a District Commission, State Commission or National Commission becomes final if no appeal is preferred against that order under the Consumer Protection Act, 2019.
In practical terms, a party wishing to challenge an appealable order should act within the applicable statutory appeal period rather than assume that the dispute can be reopened later.
Section 69 - Limitation period for a consumer complaint
Under Section 69(1), a District Commission, State Commission or National Commission shall not admit a complaint unless it is filed within two years from the date on which the cause of action arose.
Section 69(2) permits a complaint to be entertained after the two-year period if the complainant satisfies the Commission that there was sufficient cause for the delay. When delay is condoned, the Commission must record its reasons.
Quick comparison of the current provisions
| Subject | Consumer Protection Act, 2019 | Key rule |
|---|---|---|
| Appeal from specified National Commission orders | Section 67 | Appeal to Supreme Court ordinarily within 30 days; 50 per cent deposit where payment is required by the order. |
| Finality of orders | Section 68 | An order becomes final if no appeal is preferred under the Act. |
| Limitation for complaint | Section 69 | Complaint ordinarily within two years from accrual of cause of action; delay may be condoned for sufficient cause with recorded reasons. |
Earlier provisions under the Consumer Protection Act, 1986
For older proceedings governed by the repealed 1986 enactment, Section 23 dealt with appeals from specified orders of the National Commission, Section 24 dealt with finality of orders, and Section 24A prescribed a two-year limitation period for complaints with power to condone delay for sufficient cause.
The former Section 23 also prescribed a 30-day appeal period. Its pre-deposit formulation was different: it referred to fifty per cent of the amount or Rs. 50,000, whichever was less. The current Section 67 instead requires fifty per cent of the amount ordered to be paid.
Official legal resources
For the authoritative statutory text and subsequent updates, refer to the Consumer Protection Act, 2019 on India Code and the Department of Consumer Affairs consumer protection laws and rules page.