KOZYFLEX Mattresses Private Limited Vs SBI General Insurance Company Limited And Anr (Supreme Court of India)
A Company Can File Complaint of Deficiency In Services Under Consumer Protection Act, 1986
Summary: In the case of M/S Kozyflex Mattresses Private Limited v. SBI General Insurance Company, the Supreme Court of India ruled that a company is a “person” and can file a complaint for deficiency of services under the Consumer Protection Act, 1986. The dispute arose after Kozyflex’s fire insurance claim was repudiated by SBI Insurance. When Kozyflex filed a complaint with the National Consumer Disputes Redressal Commission, the insurance company argued that a company was not covered by the 1986 Act’s definition of “person.” The Supreme Court rejected this argument, stating that the definition of a “person” in the 1986 Act is inclusive rather than exhaustive. The court’s decision adopted a liberal and purposive interpretation of the law, noting that the legislative intent was to be beneficial to a wide range of complainants. The court also pointed to the updated Consumer Protection Act, 2019, which explicitly includes a “body corporate” in its definition of a “person,” indicating that the exclusion was not the original legislative intent. As a result of this ruling, the Supreme Court remanded the case back to the National Commission, directing them to reconsider the complaint on its merits and to allow Kozyflex the opportunity to rebut the findings of the investigator reports.
