In Brief
A small landholding farmer who purchased musli seeds from a seed company and agreed to grow and sell back the crop cannot be excluded from consumer protection merely because the activity is commercial or involves a buyback arrangement. The Supreme Court held that farmers engaging in self-employment on small landholdings to earn livelihood qualify as 'consumers' under the 1986 Act, even when selling produce back to the seed company. The court rejected the seed company's claim that such transactions constitute resale, and criticized frivolous litigation tactics used by corporations to harass small farmers. The appeals were dismissed with cost awards.
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