In the last few years, a number of complaints have been aired in newspapers and courts against lapses of universities in various aspects of their services. The lapses range from wrong allotment of roll numbers to conducting exams and declarationo of results. Schools, college and technical institutes are increasingly becoming commercialised, fleecing through exorbitant fees, donations and capitation charges. Others misrepresent by projecting their affiliation to various universities n professional councils when in fact there in no such affiliation. In the process guillible parents are lured to admit their children in these institutions which play around with their careers
Initially the MRTP Commission and the consumer courts played a vital role in curbing the nefarious practices of such institutions. The MRTP Commission had instituted enquiries against a number of school and prevented them from making false claim about their services, curtailed the exorbitant fees charges by the and compelled them to declare the status of their recognition and the exact nature of the affilitation claimed. The Karnataka High Court delivered a judgment in NIITE Education trust caseholding that education is not a service as defined then by the MRTP Act.
However this stance was thereafter changed by the Vishwa Budha Parishad case where it went on to hold that a student in fact is a consumer of education. In light of the differences that are there in the decisions the paper looks to address the state of education under the Consumer Protection Act.
The issues raised by the researcher are the following:
When does education constitute service?
What are the differences between statutory and administrative functions of a University?
Does the same necessarily include only monetary compensation?
How have the courts interpreted higher educations in Universities in terms of it being a service?
What constitutes deficiency of services and what are the the redressals available for such deficiency of services?
I. Consumer Protection and Education.. 3
II. Scope of Education as a Service. 4
II.I Student as a Consumer- 6
II.II. The requirement of Consumer Protection- 7
II.III Expanding Scope in Vishwa Budha Parishad- 8
III.IV Curtailing Scope in Ruchika Jain- 9
III. Role of Regulatory bodies. 10
III.I. Specific Regulatory Bodies- 10
III.II Other Bodies also serving as regulatory bodies- 10
III.III. Establishment of Educational Institution- 11
IV. Deficiency of Service. 12
I. Consumer Protection and Education
The Demand for professional education has risen steeply in the last few years. This cannot be met fully by state-funded or state-aided institutions alone. This is why a new category of private, self-financing institutions have registered a phenomenal growth. They offer courses in engineering and technology, computer, medicine, dentistry, pharmacy, management, teacher education and law, for which there is great demand. Many of these institutions are deficient in matters like infrastructure, competent faculty and even a congenial campus environment. Hence there arises a need for both students and their parents to be aware of their rights and undertake comprehensive assessment of the infrastructure facilities and validity of the courses before committing their hard-earned money to such institutes. The reasons and the need for protection of education as a service are accounted for as follows:
Mushrooming of Institutes for Higher Education-The Demand for professional education has risen steeply in the last few years. This cannot be met fully by state-funded or state-aided institutions alone. This is why a new category of private, self-financing institutions have registered a phenomenal growth.
Commercialization of Education- With the increased demand for higher educational institutes the Government of India has privatised the same. With privatization, education has been treated as service rendered and thus should come under the purview of consumer protection.
Necessity for Quality Check- Many of these institutions are deficient in matters like infrastructure, competent faculty etc. Hence there arises a need for the students who are to be aware of their rights and undertake comprehensive assessment of the infrastructure facilities and validity of the courses before committing.
II. Scope of Education as a Service
The legislative intent behind The Consumer Protection Act, 1986 (hereinafter referred to as the “Act”) was to protect consumers’ rights and provide a simple quasi-judicial dispute resolution system for resolution of complaints. Education has been regarded as an act of imparting knowledge and thus was too noble for a while to be included under the Act. However with in the recent times the demand for professional education like engineering and technology, computer, law, medicine has witnessed a steep increase and this demand cannot be fully met with the small number of state funded or state aided institutions. Thus a supply of private self financing institutions has increased to meet the demand. In absence of the checks and balances that are instated in the former group the new universities more often than not do not meet the required standards with regard to infrastructure, faculty and other facilities as documented in the prospectus. The necessity to ensure that these universities are offering the promised education increases.
To ascertain whether education can be read as a service the definitions of ‘service’ and ‘consumer’ are to be understood. As per the definition of consumer includes both consumer of goods and services furthermore services extends to a service of any descripttion that is made to available to potential users. The indicative list includes banking, financing insurance et al and is restricted with regard to services rendered free of cost or any other service under a contract of personal service. By the rule ofejusdem generis the indicative list can be extended to a service which is made available to potential users when a certain standard of quality is promised against a consideration due from the consumer to the service provider. The scope of the section 2(o) was interpreted in Lucknow Development Authority v. M.K. Gupta where the phrase “any descripttion” was widened and the Supreme Court opined
“…the inclusive clause succeeded in widening tits scope but not exhausting the services which could be covered in earlier part. So any service except when it is free of charge or under a contract of personal service is included”
In Tilak Raj v. Haryana School Education Boards, Bhiwani the Haryana State Commission held that It is true that in the definition to service in clause (o) of subsection 1 of Section 2 of the Act education does not find mention in express terms like other activities which have been specifically so labelled. However, it deserves highlighting that the enumerated services are only part of the inclusive definition and in no way construct the essence and meaning of the word service for the purpose of the Act. that the same has been very widely undefined is manifest from the language employed which says that service means service of any descripttion which is made available to potential users. The legislature has deliberately cast the net very wide to bring within its ambit the services of any descripttion. When rendered for consideration barring those under a contract of personal service. Whenever, education is imparted for a consideration it is obvious that there exists a quid pro quo for the provision that education and a monetary recompense therefore. On principle there does not seem nay logical reason fro excluding education form the ambit of definition of service under the Act. It must therefore be held that on principle precedent sd the language of the stature education would squarely come within the arena of service under the Act.
II.I Student as a Consumer- In Abol Pacheco Gracias v. Principal Baharat Vidyaputh College of Engineering  the complainant’s son was admitted to the college for which he deposited a certain amount towards tuition fee hostel fee and other charges. Afterwards he got admission to Government Engineering College and therefore demanded the refund of fee from the opposite party the opposite party refunded the hostel fee and part of the tuition fee but the major portion of it was retained, the Maharasthra State Commission directed the College to refund the fee to the complainant observed
“A student is essentially a consumer of services in an educational institution. Therefore where there is no service there is no right with the College to appropriate fees. If it insists to collect fees without imparting education it will amount to deficiency”
In S. Venkatapathy v. The Principal Adhyaman College of Engineering (1993) the complainants were selected by the Directorate of Technical Education, Madras for admission to the first year B.E. Degree Course in the respondent college. They joined the College on remitting a fee of Rs.7000 each. Subsequently, the complainants were allotted to various Engineering Colleges in Madras City. When they requested the respondent college for ‘transfer certificate’ the college authorities insisted that they should not claim refund of the fee already paid and the complainants have no other go but to execute such an undertaking and get their ‘transfer certificates’. The Tamil Nadu Commission while ordering the refund of fee and awarding interest and compensation, held that literally the complainants were coerced to give such an undertaking in order to get ‘transfer certificates’ so as to enable them to join the subsequent colleges at Madras. Such an undertaking taken by coercion is not valid in law and cannot confer any right to the opposite party to refuse the repayment of the fees. The commission observed thus
Education is one of the most valuable services in human society and this service is rendered by the opposite party, College to the complainants and it is not rendered freely, but for consideration in the form of fees. The complainants are therefore consumers within the meaning of Section 2 (1)(d)(ii) of the Consumer Protection Act.
II.II. The requirement of Consumer Protection- Some private educational institutions are making very tall claims and thereby creating big business and recover huge amounts by the way of fees. It cannot, therefore, be denied that the relationship between the so called students and such institutes which are imparting/offering education/courses is that of the provider of service and recipient of service. They will fall squarely within the meaning of Section 2 (1)(d)(ii) of the Act. It is known fact that to secure admission in public schools has become a very difficult task and the parents have to knock at the doors of many schools at the same time. For seeking admission to the Nursery Classes not only the wards but the parents are also interviewed which are held for a long period. One even finds very long queues at the stage of registration for such admission. Many amongst these schools do dictate their terms and conditions by compelling the parents to sign printed standard form offering services essentially ‘take it or leave it’ basis. The parents with anxiety to get the children admitted to those institutions have no bargaining power but to accept the conditions offered by the institution. In Apeejay School v. M.K. Sangal, the Delhi State Commission Held that such an agreement cannot be considered to be a conscionable one. The Commission observed that the imparting of education for consideration is covered under the definition of ‘service’ as provided under Section 2 (1)(o) of the Consumer Protection Act, 1986. The Commission rejected the argument that the services rendered by the School were under a contract of ‘personal services’ and, thus held
This sort of service could not be construed as a contract for personal service either, as the school curriculum and its day to day functioning was not being managed, controlled and guided by the students, and under such a situation the service hired by the parents for their wards in such schools could not be considered ‘personal service’.
II.III Expanding Scope in Vishwa Budha Parishad- While expanding the scope of Consumer Law, National Commission opened new doors in Bhupesh Khurana and others v. Vishwa Budha Parishad and othersthat imparting education falls within the ambit of service as defined under CPA. The apex consumer court has resolved the basic question whether educational institutions come under the ambit of consumer courts and held that they too are liable for deficient services rendered. The verdict was in response to complaint field by 12 students, who joined the Buddhist Mission Dental College in Bihar. The College in its admission advertisements for the BDS Course, gave an impression that it is affiliated to Magadh
University and recognized by the Dental Council of India. After joining the College the students to their dismay found that it was neither affiliated to Magadh University nor it is recognized by the Council. As a result, they not only lost two academic years but also the money spent on fees, hostel charges, etc. Holding the service rendered by the College to be deficient, the Commission directed it to refund all admission expenses with interest and pay compensation for the loss of two years and, also the cost of the petition. Apart from the redressal of the grievances of students, the importance of the award lies in the fact, that it brought educational institution under the ambit of the Consumer Protection Act. The Commission observed,
“Imparting of education by an educational institution for consideration falls within the ambit of ‘service’ as defined in the Consumer Protection Act. Fees are paid for service to be rendered by way of imparting education by the educational institutions.” If there is no rendering of service, the question of payment of fee world not arises. The complaints (the student in this case) had hired the service of the respondents (the College) for consideration and so they are consumers as defined in Consumer Protection Act”.
It was thus held that fees are paid for services to be rendered by way of imparting education by educational institutions. This is a great move in the direction of Consumer Protection as many Five stars schools & colleges are mushrooming day by day. These claim of false affiliation with well known Universities in India as well as abroad and charge huge sums in the name of fees and other charges, which is unaffordable for the common man. Many of these institutions appoint unqualified staff and faculty to teach a particular stream and sometimes even such faculty is not available. Examinations are not held in time or results are not declared for months or even years, or certificates are not issued to them. Most of such Institutions are being run by fly- bynight operators with only commercial motives. In the last decade imparting education has become just another business rather than service to the society. To be cheated and lose hard earned money is one thing but more important fact is that the future of many students is at stake. In many such cases, which have come before the National Commission, the apex consumer court has clearly held that providing education is a service and has compensated the aggrieved consumer. In a number of cases the non supply of Roll Number, unexplained delay in deciding the application for admission, misrepresentation in advertisement and prospectus about the recognition of the college, non refund of the initial payment as college fee etc. have been held as deficiency in service.
III.IV Curtailing Scope in Ruchika Jain- However in the 2006 decision of Deputy Registrar (Colleges) & Anr. v. Ruchika Jain & Ors it was held by the National Conumer Disputes Redressal Commission, New Delhi that hirer of education services for consideration and performance of statutory duties by a University or a college such as laying down rules et al. is not service.
In the very recent decision Bihar School Examination Board v. Suresh Prasad Sinha the Supreme Court set aside a concurrent finding of a District Consumer Forum, the state panel and the National Consumer Disputes Redressal Commission (NCDRC), all holding that the boards were liable under the consumer law.
“We are clearly of the view that the (examination) board is not a service provider and a student who takes an examination is not a consumer.”
Thus a distinction between statutory and administrative duties were sought. Hence matters which can be dealt with the consumer forum cannot be matter such as conduct of examination, valuations of papers, fixing standards and syllabus for the courses and examination But malpractices such as claiming affiliation or recognition where there is no conducting courses after receiving frees etc amounting to deficiency of service can b certainly looked into by the Forum.
It was also held by the Supreme Court in GDA v. Balbir Singh that holding examination might be a statutory duty but administrative duties such as issuing correct mark sheets etc is a part of service covered under the Consumer Protection Act under the garb of non-statutory function.
III. Role of Regulatory bodies
Education, including university education is in the State list of the Constitution. However, the Centre is entrusted with the responsibility of coordinated development and maintenance of prescribed standards of education. Accordingly, the University Grants Commission was set up in 1956 followed by the establishment of a number of regulatory bodies called Councils in the field of professional education through parliamentary enactments.
III.I. Specific Regulatory Bodies- While in the pre-independence days there was only one such Council – the Medical Council of India established in 1933 – three are now more than dozen. Besides the Councils, there are three other statutorily constituted regulatory bodies, viz., the Institute of Chartered Accountants of India (ICAI), the Institute of Company Secretaries of India (ICSI) and the Institute of Cost and Works Accountants of India (ICWAI). They are responsible for regulating the standards of education and profession in their respective areas. Unlike the Councils, they themselves conduct the examinations and admit the qualified students as Associate Members as professionals. The most widely known regulatory Council is the All India Council for Technical Education (AICTE), because of the large number of professional and technical disciplines it controls.
III.II Other Bodies also serving as regulatory bodies- Medical student must qualify from a medical college recognised by the Medical Council of India and after fulfilling the specified conditions (e.g., internship in hospitals) becomes eligible for registration with the State level Medical Council to undertake practice legally. In professions, where no such registration is necessary, students qualifying from recognised institutions only are eligible for employment or can pursue further education.
For example, the National Council for Teacher Education, which regulates education, has issued a sort of statutory warning that qualification in teacher education obtained pursuant to courses offered by unrecognised institutions will not be treated as a valid qualification for purposes of employment under Central / State government institutions, universities, colleges, schools or other educational bodies aided by Central / State Governments.
III.III. Establishment of Educational Institution- Elaborate rules and procedures have been prescribed by Government for establishment of private education institutions. The validity and recognition status of degrees awarded by the institution becomes extremely important since getting a degree which is not recognised by the Government is not only a financial loss but results in a valuable loss of time and almost ruins the career of such students who may have taken admission to such institutions. Consumer Courts have taken very serious note of such institutions in which the brochures / prospectus / advertisements of the institutions claimed that the courses were recognised by AICT and UGC etc. but when the candidates who passed out from such institutes it was found that the degrees awarded to them were not recognised. Such instances not only destabilise the financial position of the parents but very importantly the students are devastated mentally and are at loss to decide about their future. Parents and students must therefore check the validity of the degrees by logging on to the Website for All India Council for technical Education (AICTE) www.aicte.ernet.in, University Grants Commission www.ugc.ac.in, National Council of Teacher Education www.ncte-in.org and Medical Council of India www.mciindia.org. The list is indicative.
It is therefore, essential that students must first ascertain whether the institutions in which they are seeking admission are recognised by the concerned regulatory authority. The AICTE which has a comparatively larger number of institutions under its umbrella, publish several directories, each dealing with a group of courses. National Council for Teacher Education (NCTE) and the Rehabilitation Council of India (RCI) have established their own websites. Lists of recognised institutions and courses are available from these sites.
IV. Deficiency of Service
The deficiency in service is assessed on a case to case basis.
In Manisha Samal v. Sambal University when the University of payment of fees for appearing in the examination allotted the same roll number to three different students on the same subject the national Commission held that it was a serious negligence on the part of the University and thus a deficiency of service. In Maharshi Dayanand University, Rohtak v. Shakuntla Chowdhury the results of exam of complainant declared by University was found to be erroneous and incorrect the University pleaded that it was due to oversight and the mistake had been promptly rectified. It was held:
Whenever the University defaults from primal duty of care the examines would clearly be entitled to compensation under the Act for the deficiency in the services rendered and the commission awarded of Rs 500 to the complainant.
It was further observed by the court that nevertheless the University having once undertaken the service of conducting the exam for prescribed fees is obviously under a duty of care to perform the said task efficiently. An incorrect declaration an publication of the candidate result would be an imperfection and shortcoming in performance of duty undertaken. Whenever it thus fails or defaults in the said duty of care it cannot escape the consequence thereof the mere general plea of the large number of examines and inevitable quantum of paperwork involved. In other case V. Murugeshan v. Registrar. University of Madras. The TN State Commission held that where the university held 10 years to issue degree certificate to the complainant it was a case of gross deficiency of service on part of Univ. In this case the complainant app for a degree cert in 1992 and paid the requisite fee. The certificate was granted to him after a decade in 1992. The state commission after awarding a compensation of Rs 10,000, held that there can be no worse deficiency of service on the part of the University. The University is responsible body entrusted with education of student and if the University itself is lethargic and in different in the issue of certificates it is indeed a bad for degree holder. The national commission has held in number of cases that a University or the Board in conducting public examinations, evaluating answer books, resulting results and conducting rechecking of marks of any candidate on application made by concerned candidate is not performing in any service for hire and there is no arrangement of hiring of any service in such a situation as contemplated by the consumer protection act. In a case a complainant got diploma in 1989 it was only 1992 that he made a complain regarding deficiency in training in the examination conducted to test his proficiency to work on computer. The national commission found that there was no commitment on part of the Institution to provide him with a job after completion of course and therefore the commission held that it was not a bonafide consumer complain nor is there any deficiency in service
In Ramdeobaba Engineering College v. Sushant Yuvraj Rode the complainant withdrew from the college to join another institute voluntarily and requested the college for refund of admission which was not made by the college the national commission held that non refund of admission fee is not deficiency in service. Admission fee is consideration for admission and the service which the college was to render to the student tin the matter of his perusing studies it the college after admission it is a quid pro quo of such service. In Akhil Bharatiya Grahak Panchayat v. Secy Sharda Bhavan Educational Society a pharmacy college run by the respondent society deliberately admitted the students to the course in the violation of rules and regulations imposed by the Directorate of Technical education, Maharashtra and Pharmacy Council of India and consequently the students suffered considerable delay in obtaining registration after passing the examination and undergoing the practical training that the facts established cliearlt that there was unfair trade practice as well as deficiency in service ont eh part of the college authorities In Sudhakshar Kumar v. Registrar, Pubjab State Board Technical Education the detailed marks certificates of the student contained incorrect father’s name which caused a lot of harassment to him, the respondent referred to the case Joint Secy Gujarat Secondary Education v. Bharat Narottam Thakker wherein it was observed the checking of the papers was not covered under Section 2(1)(o) The state commission held that the case now in hand is distinguishable because the respondent was supplied the correct name of father but it was misspelt while issuing the certificate. Thus the deficiency was writ large for which the respondent was held liable.
There is an ambiguous conflict in case law on the nature an dscope of cvarius functions of the educational institutions for the applicability of the Consumer Protection Act, 1986. A student is neither a consumer not education service rendered by a University is a service when the University is performing a statutory duty. However if there are malpractices while performing other duties then the University can be held liable under the Consumer Protection Act
Abol Pacheco Gracias v. Principal Baharat Vidyaputh College of Engineering (1992) 1 CPJ 105 (Mahar CDRC)
Akhil Bharatiya Grahak Panchayat v. Secy Sharda Bhavan Educational Society (1994) 2 CPR 583 (NCDRC)
Apeejay School v. M.K. Sangal, Bhupesh Khurana and others v. Vishwa Budha Parishad and others (2000) CTJ 801
Bihar School Examination Board v. Suresh Prasad Sinha 2009 (6) ALT 43
GDA v. Balbir Singh (2004) 5 SCC 65
Joint Secy Gujarat Secondary Education v. Bharat Narottam Thakker
Lucknow Development Authority v. M.K. Gupta AIR 1994 SC 787
Maharshi Dayanand University, Rohtak v. Shakuntla Chowdhury 1993 1 CPR 274 (Haryana CDRC)
Manisha Samal v. Sambal University (1992) 1 CPR 215 (Haryana CDRC).
10. of Deputy Registrar (Colleges) & Anr. v. Ruchika Jain & Ors (2006) 3 CPR 18 (NC).
11. Ramdeobaba Engineering College v. Sushant Yuvraj Rode (1994) 3 CPJ 160 (NCDRC)
12. S. Venkatapathy v. The Principal Adhyaman College of Engineering (1993) ICPR 595 (Tamil Nadu CDRC)
13. Sudhakshar Kumar v. Registrar, Pubjab State Board Technical Education (1999) 3 CPJ 193 (Chand. CDRC)
14. Tilak Raj v. Haryana School Education Boards, Bhiwani (1992) 1 CPJ 76
15. V. Murugeshan v. Registrar. University of Madras. (1993) 1 CPR 190 (Tamil Nadu CDRC).
D. S. Mehta “Education also comes under Consumer Protection Act” 15(03) Legal News and Views (Mar., 2001).
Rajinder Chaudhry Safeguard Your Interests As A Consumer While Seeking Admissions In Educational Institution <https://www.employmentnews.gov.in/career_details-safeguard-your-interests-as-a-consumer-while-seeking-admissions-in-educational-institutions-175-in.html>
Rutika Desai “Is Student “Consumer” and Education “Service” under the Consumer Protection Act, 1986” 49(03) Journal of Indian Law Institute 415, 417 (July., 2004)
V.K. Aggarwal “Accountability of Educational Institutions and the Consumer Protection Act” 87(09) All India Reporter 130, 131 (Sept., 2000)
Rifat Jan, Consumerism and Legal Protection of Consumers 213 (New Delhi; Deep & Deep Pub. Ltd. 2007)
 Section 2(d) “consumer” means any person who—
(i) buys any goods for a consideration which has been paid or promised or partly paid and partly promised, or under any system of deferred payment and includes any user of such goods other than the person who buys such goods for consideration paid or promised or partly paid or partly promised, or under any system of deferred payment when such use is made with the approval of such person, but does not include a person who obtains such goods for resale or for any commercial purpose; or
(ii) hires or avails of any services for a consideration which has been paid or promised or partly paid and partly promised, or under any system of deferred payment and includes any beneficiary of such services other than the person who ‘hires or avails of the services for consideration paid or promised, or partly paid and partly promised, or under any system of deferred payment, when such services are availed of with the approval of the first mentioned person but does not include a person who avails of such services for any commercial purposes;
Explanation.— For the purposes of this clause, “commercial purpose” does not include use by a person of goods bought and used by him and services availed by him exclusively for the purposes of earning his livelihood by means of self-employment;
 Section 2(o) “service” means service of any descripttion which is made available to potential users and includes, but not limited to, the provision of facilities in connection with banking, financing insurance, transport, processing, supply of electrical or other energy, board or lodging or both, housing construction, entertainment, amusement or the purveying of news or other information, but does not include the rendering of any service free of charge or under a contract of personal service;
 V. K. Aggarwal “Accountability of Educational Institutions and the Consumer Protection Act” 87(09)All India Reporter 131 (Sept. 2000)
 AIR 1994 SC 787
 (1992) 1 CPJ 76
 V.K. Aggarwal “Accountability of Educational Institutions and the Consumer Protection Act” 87(09)All India Reporter 130, 131 (Sept., 2000)
 (1992) 1 CPJ 105 (Mahar CDRC)
 ICPR 595 (Tamil Nadu CDRC)
 Supra note 7 at 133.
 Ibid at 593.
 D. S. Mehta “Education also comes under Consumer Protection Act” 15(03) Legal News and Views(Mar., 2001).
 Supra note 7 at 133.
 Supra note 14 at 33.
 Supra note 14 at 33.
 Rutika Desai “Is Student “Consumer” and Education “Service” under the Consumer Protection Act, 1986” 49(03) Journal of Indian Law Institute 415, 417 (July., 2004)
 (1993) 2 CPR 62 (Delhi CDRC)
 Ibid at 63.
 (2000) CTJ 801
 (2006) 3 CPR 18 (NC).
 2009 (6) ALT 43
 Supra note 14 at 131.
 (2004) 5 SCC 65
 Supra note 18 at 417.
 Rifat Jan, Consumerism and Legal Protection of Consumers 213 (New Delhi; Deep & Deep Pub. Ltd. 2007)
 Ibid at 215.
 Supra note 7 at 419.
 Supra note 25 at 214.
 Rajinder Chaudhry Safeguard Your Interests As A Consumer While Seeking Admissions In Educational Institution <https://www.employmentnews.gov.in/career_details-safeguard-your-interests-as-a-consumer-while-seeking-admissions-in-educational-institutions-175-in.html>
 Supra note 25 at 217.
 Supra note 25 at 217.
 (1992) 1 CPR 215 (Haryana CDRC).
 1993 1 CPR 274 (Haryana CDRC)
 (1993) 1 CPR 190 (Tamil Nadu CDRC).
 (1994) 3 CPJ 160 (NCDRC)
 (1994) 2 CPR 583 (NCDRC)
 (1999) 3 CPJ 193 (Chand. CDRC)
 (1994) 1 CPJ 987 (NCDRC)
 Deputy Registrar Colleges and Anr v. Ruchika Jain and Anr 2006 (3) CPR 18 NC.