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Supreme Court of India 2020-03-06 dismissed

M/S NANDAN BIOMATRIX LTD vs S.AMBIKA DEVI

Bench: 2 — Mohan M. Shantanagoudar, R. Subhash Reddy

In Brief

A farmer who purchased wet musli seeds from a company for cultivation under a buyback agreement is a 'consumer' under the Consumer Protection Act, 1986. The Supreme Court held that a buyback arrangement does not constitute resale, and small-scale farming for earning livelihood qualifies as self-employment, not commercial purpose. Even with a guaranteed price, such activities fall within the Act's consumer protection. The Court rejected arguments that farmers could be excluded merely because they sold produce back to the seed company. The judgment emphasized the farmer's small landholding, and that the transaction involved services like technical support and crop insurance, making the farmer eligible for consumer redressal mechanisms."

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Consumer Protection Agriculture Seed Companies Commercial Purpose Self-Employment Farmer Protection Buyback Agreements Definition of Consumer

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