Facts: The appellant, an undertaking of the State of Maharashtra, invested Rs. 9 Crores in a fixed deposit with Vijaya Bank. Subsequently, the Bank informed the appellant that an overdraft facility had been sanctioned against the said FDR. The appellant alleged that it never applied for such a facility and that the pledge was fraudulent. Upon maturity, the Bank adjusted the outstanding overdraft amount against the FDR value, remitting only the remaining balance of approximately Rs. 50.58 Lakhs. The appellant filed a consumer complaint seeking the full principal amount with interest. The Bank contested the maintainability, arguing that the appellant was a corporate entity using services for "commercial purpose" and that allegations of fraud required trial by a Civil or Criminal Court.Procedural Posture: The National Consumer Disputes Redressal Commission (NCDRC) dismissed the complaint, holding that the appellant was not a "consumer" under Section 2(1)(d) of the Consumer Protection Act, 1986, as the deposit had a direct nexus with profit generation. The appellant then filed this statutory appeal before the Supreme Court of India.Issue: 1. Does a body corporate depositing surplus funds in an interest-bearing FDR automatically fall outside the definition of "consumer" due to "commercial purpose"? 2. Can a Consumer Forum adjudicate complex allegations involving fraud, forgery, and disputed contracts of pledge in summary proceedings?Holding: 1. No, merely earning interest on a deposit does not equate to a "commercial purpose". 2. No, when a complaint involves complex factual disputes of a criminal or tortious nature like fraud, it cannot be decided in summary proceedings under the Act.Reasoning: The Court reasoned that "commercial purpose" requires a close and direct nexus with profit-generating activity. Parking surplus funds for safe custody or to earn basic interest is a standard banking service and does not inherently make the depositor a commercial user. However, regarding the second issue, the Court observed that the Bank set up a subsequent contract of pledge, which the appellant claimed was forged. Following the precedents in "Ravneet Singh Bagga" and "City Union Bank Ltd.", the Court held that "deficiency in service" must be distinguished from tortious or criminal acts. Since the matter involves determining whether a fraud was played or documents were forged, it requires a detailed trial in a Civil or Criminal Court rather than summary proceedings. Thus, the dismissal was upheld on the ground of non-maintainability due to complex factual disputes.