In Brief
Nandan Biomatrix, a seed company, challenged orders finding that a small farmer (the respondent) who purchased safed musli (wet musli) seeds and cultivated them under a buyback agreement was a 'consumer' protected by the Consumer Protection Act, 1986. The farmer alleged the company failed to buy back her crop as promised. The Supreme Court held that a farmer engaged in growing crops on her own land for earning livelihood through self-employment—even under a buyback arrangement—qualifies as a 'consumer'. The Court rejected arguments that buyback amounts to resale or constitutes commercial activity excluded by the Act. It criticized seed companies for frivolous litigation against farmers and remanded cases to district forums for merit hearing. Costs of ₹25,000 per appeal were imposed on the company.
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