Facts: Aashna Roy visited ITC Maurya Hotel's beauty salon for a haircut and, dissatisfied with the service, filed a complaint with the National Consumer Disputes Redressal Commission (NCDRC). The NCDRC initially awarded her ₹2,00,00,000/- as compensation for deficiency in service and medical negligence. ITC Limited appealed this order.
Procedural Posture: The Supreme Court initially disposed of the appeal, upholding the finding of deficiency in service but setting aside the compensation amount due to lack of supporting evidence. The matter was remitted to the NCDRC for re-evaluation of the compensation. After remand, the NCDRC again awarded ₹2,00,00,000/-. ITC Limited then filed the present appeal before the Supreme Court challenging the second compensation order.
Issue: Did the NCDRC err in awarding ₹2,00,00,000/- as compensation to the respondent based on the evidence presented, particularly given the appellant's denial of the authenticity of the respondent's documents and the lack of opportunity to cross-examine the respondent and witnesses?
Holding: Yes, the Supreme Court partially allowed the appeal, modifying the NCDRC's order. The compensation was restricted to the amount already released in favor of the respondent.
Reasoning: The Court found that the NCDRC's decision to award a substantial compensation of ₹2,00,00,000/- was not justified by the evidence on record. The Court noted that the respondent primarily relied on photocopies of documents, the authenticity of which was disputed by the appellant. The respondent also did not take steps to prove the authenticity of these documents, nor were the authors of the documents summoned for examination. The Court emphasized that while the Consumer Protection Act proceedings are not strictly bound by the Indian Evidence Act, the principles of natural justice must be followed. The Court cited previous judgments, including Malay Kumar Ganguly v. Dr. Sukumar Mukherjee and others, emphasizing that quantification of compensation must be based on material evidence, not merely on the claimant's assertion. The Court concluded that the NCDRC erred in relying on mere photocopies and general discussions without properly assessing the actual loss suffered by the respondent.