Case Law Details
In re matter of Career Line Coaching (CLC) Sikar (CCPA Delhi)
The Central Consumer Protection Authority initiated suo motu proceedings against Career Line Coaching (CLC), Sikar, over allegedly misleading advertisements published on its website and in a newspaper on 16 February 2025. The advertisements claimed “1650+ CLCians in MBBS, IIT & Others”, “2 CLCians in NEET AIR Top 100”, “3 CLCians at AIIMS Delhi”, “6 CLCians scored 710+ marks”, and “7 Times result growth in AIR-1000”, while prominently displaying photographs and names of successful candidates. The CCPA observed that the advertisements simultaneously promoted various coaching programmes but failed to disclose the specific courses attended by the featured students. Notices were issued under the Consumer Protection Act, 2019 and the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022. The institute responded that the claims were based on publicly available NEET and JEE results and institutional data accumulated since 1996, asserting there was no intention to mislead consumers. However, the CCPA found that the institute failed to provide documentary evidence substantiating the claims despite multiple opportunities during inquiry and investigation.
The Director General (Investigation) reported that the institute failed to furnish enrolment forms, fee receipts, consent records, course details, and other evidence supporting the impugned claims. The report also stated that CLC continued to display the advertisements on its official platforms even after initiation of proceedings. During hearings, the institute argued that terms such as “with XII”, “fresher”, and “repeaters” were commonly understood within the student community and that space constraints prevented disclosure of course details in advertisements. It also stated that some successful students, including a NEET rank holder, had enrolled only in test series courses. The CCPA rejected these explanations, observing that disclosure of the specific course attended, duration, and nature of enrolment was material information for prospective students and parents, particularly because the advertisements targeted minor consumers preparing for NEET and IIT-JEE examinations.
The authority further noted contradictions in the institute’s submissions regarding the claim “1650+ CLCians in MBBS, IIT & Others.” In its written reply, the institute described the figure as cumulative since 1996, whereas during oral hearing it stated that the figure related only to selections in 2024. The CCPA held that the inconsistent positions undermined the credibility of the claim and remained unsupported by documentary proof. It also found that most enrolment forms submitted lacked signatures of students or parents and that many students whose photographs were used in advertisements had only enrolled for test series programmes. The authority additionally observed that no evidence was produced showing written consent obtained from successful candidates after declaration of results, as required under the Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024.
The CCPA concluded that the institute deliberately concealed material information regarding the courses opted for by successful candidates, thereby creating a misleading impression about the efficacy and quality of its programmes. The authority held that such conduct constituted misleading advertisement and unfair trade practice under Sections 2(28) and 2(47) of the Consumer Protection Act, 2019, along with violations of the 2022 and 2024 advertising guidelines. Considering the institute’s continued publication of the advertisements, its wide digital reach, and the vulnerability of students targeted by coaching advertisements, the CCPA directed the institute to discontinue the advertisements immediately, desist from publishing misleading advertisements in future, and submit a compliance report within 15 days. A penalty of ₹5 lakh was also imposed under Sections 20 and 21 of the Consumer Protection Act, 2019.
FULL TEXT OF THE JUDGMENT/ORDER OF CENTRAL CONSUMER PROTECTION AUTHORITY
This is a suo-moto case taken up by the Central Consumer Protection Authority (hereinafter referred as `CCPA’) against Career Line Coaching, Sikar (hereinafter referred as ‘opposite party’) with regard to alleged misleading advertisements on its official platforms including official website (www.cicsikar.com) and newspaper Dainik Bhaskar dated 16.02.2025 wherein following claims were made:-
i. CLCians in MBBS, 11T & Others”
ii. “2 CLCians in NEET AIR- 100”
iii. “3 CLCians at AIIMS Delhi”
iv. “6 CLCians scored 710+ marks (out of 720)”
v. 7 Times result growth in AIR- 1000″
2. Taking cognizance of the issue, the CCPA in exercise of power conferred under the Consumer Protection Act, 2019 (hereinafter referred to as ‘the Act’) conducted a preliminary inquiry to examine authenticity of the claims in the impugned advertisement made by the opposite party.
3. As per the preliminary inquiry report, CCPA prima facie observed that opposite party had published above mentioned claims and prominently featured the names and pictures of successful candidates of the IIT-JEE and NEET UG. Opposite party simultaneously also advertised various types of courses offered by it namely: “Classroom Courses- 11th Foundation, 12th Foundation, Target Batch, CLC High School’ in the impugned advertisement.
4. It is relevant to state that the CCPA is established under Section 10 of the Act for the purpose of regulating matters relating to violation of consumer rights, unfair trade practices and false or misleading advertisements which are prejudicial to the interests of consumers as a class. Further, Section 18 read with Section 9 of the Act also empowers the CCPA to ensure transparency, accuracy and full disclosure in advertisements, and to protect the right of consumers to be informed, so as to enable them to make informed choices. The said provisions confer jurisdiction upon the CCPA to examine, inquire into and take action against misleading advertisements issued by service providers, including coaching institutes.
5. As per the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022, Clause 4 mandates that any claim made in an advertisement must be truthful and should not mislead consumers with unsubstantiated claims. Additionally, Clause 12 places a duty on service providers and advertisers to ensure that claims related to objectively verifiable facts are capable of substantiation and to produce such evidence if required by the CCPA, without exaggerating the accuracy, performance, or service of the product.
6. Accordingly, the CCPA issued a notice dated 16.04.2025 to the opposite party for alleged violation of the provisions of the Act, highlighting the issue of alleged misleading advertisements via concealing important information, i.e., the specific courses opted for by the successful candidates and making tall claims with respect to IIT-JEE and NEET UG. The opposite party was granted an opportunity to furnish a response within 15 days from the date of issuance of the notice.
7. Thereafter, opposite party vide email dated 31.05.2025 filed its reply wherein it submitted the following:-
i. The information published in the said advertisement is factually accurate, based
on verifiable data, and presented with utmost honesty. There has been no intention to mislead the public in any form, nor have any unfair means been employed in our promotional content.
ii. We clarify below the claims made in our advertisement:
a. 1650+ CLCians in MBBS, IIT, and Others: This figure represents the cumulative number of our students who have secured admission in MBBS, IITs, NITs, and other prestigious institutions across India through NEET and JEE. We are submitting a summary report showing the number of selections in various top medical and engineering colleges for your kind verification.
b. Claims 2 CLCians in NEET AIR Top 100,
c. 3 CLCians at AIIMS Delhi,
d. 6 CLCians scored 710+ marks out of 720 in NEET,
e. 7 Times Result Growth in AIR 1000 in NEET,
iii. All of the above are based on publicly available NEET and JEE results issued by NTA and verified through official counselling and admission records.
iv. Since its establishment in 1996, CLC has been a pioneer and a respected name
in medical and engineering entrance coaching. Our legacy is built on commitment, discipline, transparency, and student trust. At CLC, we have always ensured that our advertising reflects genuine achievements and verifiable success.
v. We are committed to maintaining the highest ethical standards and are always open to scrutiny. The summary data enclosed with this reply further substantiates our claims.
vi. RESULT SUMMARY-2024
a. Medical: 1575
b. Engineering : 81
c. TOTAL : 1656
8. Upon examination of the response, CCPA observed that the opposite party failed to provide any evidence to substantiate its claims. Furthermore, opposite party failed to address the main issue of concealment of important information regarding the specific courses opted by successful students featured in the impugned advertisements. Additionally, institute continues to publish the impugned advertisements on its official platforms, including its website.
9. It is important to note that on 13th November, 2024, CCPA issued Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024 in order to prevent coaching centers from making false or misleading claims/advertisements to promote the sale of goods or service and engage in deceptive or unfair practices.
10. Clause 3 and Clause 4 of said Guidelines provide the “Conditions for Misleading Advertisement” and “Obligations of every person engaged in coaching” respectively requiring disclosure of rank secured by the successful candidate, course name and duration of the course attended, whether such course was paid, along with the candidate’s photograph and appropriate disclaimer prominently in the advertisement. The opposite party appears to be violate the said provisions.
11. Further, Clause 4(2) said Guidelines provides that any person engaged in coaching shall not use the name, photograph, testimonial or video of a successful candidate in an advertisement without obtaining the written consent of such candidate subsequent to the declaration of the result/selection.
12. Considering the facts and circumstances of the case, as well as the reply submitted by the opposite party, the CCPA was satisfied that a prima facie case of misleading advertisement under the Consumer Protection Act, 2019 existed. Accordingly, vide letter dated 04.06.2025, the CCPA requested the Director General (Investigation) to conduct a detailed investigation into the matter and to include, in addition to findings on other areas of investigation, the following points in the report:
a. Detail of students claimed in the abovementioned advertisement.
b. Type of course attended by such student.
c. Date of joining of each such student.
d. Duration of the course attended by such student.
e. Fees paid along with the copies of receipt.
f. Requisite data/evidence to substantiate all the impugned claims.
13. The Director General (Investigation) in its investigation report dated 25.11.2025 submitted the following:
i. Investigation wing, in furtherance of the ongoing investigation, sought information and relevant documents from the Institute relating to the impugned misleading advertisements.
ii. Opposite party failed to provide any documentary evidence substantiating its claim. Despite sending final reminder to submit specific records including enrolment forms, consent documents, course details, and fee receipts for the claimed successful students, opposite party failed to provide the requisite information. This non-submission undermines the credibility of the claims made in the advertisement and reflects non-compliance with statutory obligations.
iii. Opposite party conduct amounts to deliberate non-cooperation and obstruction of the statutory inquiry.
iv. Even after initiation of the inquiry, the Institute continues to publish and display multiple claims on its official website without providing any proof or verification. Such unverified representations mislead prospective students and parents regarding the Institute’s performance and success rate.
v. The conduct of the Institute indicates non-compliance with the provisions of the Consumer Protection Act, 2019, particularly with respect to misleading advertisements.
vi. Career Line Coaching (CLC), Sikar leverage advertising to attract consumers, often making bold claims that appeal to the minor students.
vii. In view of the findings recorded, it is established that (CLC), Sikar has violated multiple provisions of the Consumer Protection Act, 2019, and the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022.
viii. Despite being given opportunities, the Institute failed to provide any documentary evidences to substantiate its claim.
ix. Several coaching institutes prominently use the same successful candidate’s names, pictures and videos in their advertisements while deliberately concealing important information from consumers with respect to course opted by such successful candidates. This omission deprives potential aspirants of true and complete information, affecting their ability to make an informed choice and amounting to a violation of consumer rights under Section 2(9) of the Act.
x. Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024 provides that “Obligations of every person engaged in coaching”- any person who is engaged in coaching while making an advertisement shall disclose important information such as rank secured, name and duration of course, whether such course is paid with the candidate’s photograph. Career Line Coaching (CLC) violated the various clauses of Guidelines by deliberately concealing the material information related to specific course opted by the successful candidates from the public, thereby misleading consumers as a class.
xi. This act amounts to misleading advertisement, as defined under Section 2(28) of the Consumer Protection Act, 2019 and also constitutes an unfair trade practice under Section 2(47) of the Consumer Protection Act, 2019.
xii. Additionally, the Institute’s conduct is in violation of paragraphs 4 and 12 of the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 as its advertisements exaggerate students’ achievements and make unsubstantiated claims which likely to mislead consumers regarding the institute’s performance, thereby failing to ensure truthful and honest representation.
xiii. These actions collectively amount to a misleading advertisement designed to induce consumer reliance under false pretenses, thereby attracting regulatory action under the applicable provisions of law.
xiv. In view of the above, as per the investigation conducted, a case relating to the violation of abovementioned provisions under the Consumer Protection Act, 2019 stands established.
14. The Investigation Report submitted by the DG (Investigation) was shared with the opposite party vide letter dated 03.12.2025, requesting it to furnish its comments. Simultaneously, a virtual hearing was scheduled for 12.12.2025.
15. However, no representative appeared on behalf of the opposite party on the said date. Thereafter, the CCPA scheduled another hearing on 22.12.2025, thereby providing another opportunity to the opposite party to present its case.
16. On 22.12.2025, Advocate Navin Yadav appeared on behalf of the opposite party and submitted the following:
i. The opposite party sought an opportunity to submit a detailed reply along with supporting documents in respect of the impugned advertisement.
ii. The opposite party also requested additional time to file its reply to the DG (Investigation) Report.
17. The CCPA considered the request and granted the opposite party additional time to file its comments on the DG (Inv.) Report.
18. After waiting for more than a month, CCPA sent an email on 09.02.2026 to the opposite party conveying the following directions/observations:
i. “Counsel representing the Institute during the hearing dated 22.12.2025 had sought an adjournment and additional time to file its reply to the DG (Investigation) Report.
ii. Please note that your response to the DG (Investigation) Report is still awaited.
iii. You are hereby directed to submit your comments on the DG (Investigation) Report, along with the requisite documents, within 7 days.”
19. CCPA received a response dated 22.02.2026 from the opposite party wherein following submissions were made:-
i. We most respectfully submit our sincere apologies for the delay in submitting the present reply. The delay has occurred on account of the peak academic schedule of the institute, as the relevant period coincided with the ongoing admission process and examination session, which required our full administrative and academic engagement. The same was purely unintentional and neither deliberate nor due to any disregard for the proceedings before the Hon’ble Authority.
ii. This reply is being submitted in continuation and furtherance of our detailed reply dated 31.05.2025, the contents whereof may kindly be treated as an integral part of the present reply.
iii. That Career Line Coaching (CLC), Piprali Road, Sikar, Rajasthan — 332001 is a premier coaching institute established in the year 1996. That the institute has earned a strong reputation and brand value across North India for imparting quality education and producing excellent results in competitive examinations such as NEET, IIT-JEE, NDA and other entrance examinations. That the goodwill of the institute has been built over nearly three decades through genuine academic achievements and the success of its students.
iv. Clarification Regarding the Advertisement and the Figure of 1650+ – That the advertisement referred to in the notice has been published in good faith and the data mentioned therein reflects the academic achievements of the institute over the past several years. That the figure of 1650+ selections is a cumulative and indicative representation of the successful students associated with the institute since its establishment in the year 1996, and the same demonstrates the longstanding academic legacy and consistent performance of the institute. That the said figure has been arrived at on the basis of consolidated outcome data, available result summaries, institutional records, student progression and other academic sources maintained in the ordinary course of its activities over the years.
v. That considering the long span of functioning since 1996, it is not practically feasible to maintain year-wise individual documentary records for each and every selection for the entire period, particularly for the initial years.
vi. That the said figure is therefore a bona fide and approximate representation published in good faith, and there has been no intention whatsoever to mislead the public or to make any false or fabricated claim.
vii. That for the recent years and for the period for which records are available, the institute is ready and willing to produce the same before the Hon’ble Authority for verification.
viii. That all other claims in the advertisement, including ranks, selections and student achievements, are based on verifiable records and official results.
ix. Consent of Students for Use of Photographs and Data- That at the time of admission, every student fills a detailed admission form containing a specific consent/declaration clause authorizing the institute to use his/her name, photograph and academic achievements for academic and promotional purposes. That the photographs published in the said advertisement have been used strictly in accordance with the consent so provided by the concerned students.
x. That for your kind reference and verification, we are enclosing copies of the admission forms of such students whose photographs were published in the advertisement.
xi. That all the information published is factually correct to the extent of available records and bona fide institutional data. That the advertisement has been issued only to reflect the genuine academic achievements and legacy of the institute. That there has been no deliberate intention to mislead students or the general public.
xii. That Career Line Coaching has built its reputation through hard work, quality teaching, discipline, transparency and actual student success, and has always maintained the highest ethical standards and complied with the provisions of the Consumer Protection Act, 2019.
20. Thereafter, an opportunity of hearing was provided to the opposite party on 12.03.2026. The opposite party was represented by Mr. Sunil Shiverayan, Counsellor, CLC, who made the following submissions:
i. With regard to the alleged concealment of course details in the impugned advertisement, it was submitted that the Institute provides information such as the name, photograph, rank, score, father’s name, and place of residence of the successful candidates. And due to space constraints, it does not provide course opted by successful students in the advertisement.
ii. It was further submitted that, in certain cases, terms such as “with XII” and “fresher” are mentioned alongside the names and photographs of successful candidates, which, according to the opposite party, indicate the academic status of the students, i.e., whether the student joined the Institute during Class XII or after completion of school.
iii. Referring to their reply dated 22.02.2026, the representative submitted that enrolment forms of the students have been furnished, which contain details of the courses opted for by such students.
iv. He stated that the term “fresher” denotes a student who joined the Institute after completing Class XII and took a drop year for preparation. Further, in cases where neither “with XII” nor “fresher” is mentioned, such students are considered “repeaters,” meaning those who joined the Institute after taking a drop of two or more years. It was contended that these terms are commonly understood within the student community.
v. The representative submitted that the Institute offers various types of courses, including classroom programmes and test series.
vi. With respect to a specific instance, it was submitted that one Abhishek Chaudhary (AIR 234, NEET UG 2024), whose name and photograph were used in the impugned advertisement, was enrolled only in a test series course.
vii. It was further contended that similar advertisement practices are followed by other coaching institutes, and in most cases, course details are not mentioned.
viii. He further submitted that the opposite party will comply with the applicable guidelines in its future advertisements.
ix. With regard to the claim “1650+ CLCians in MBBS, IIT & Others,”he stated that the said figure pertains to the results of the year 2024 alone, and represents the number of students from the Institute who secured selections in that year.
21. It may be mentioned that Section- 2(28) of the Act defines “misleading advertisement” in relation to any product or service means an advertisement, which—
i. falsely describes such product or service; or
ii. gives a false guarantee to, or is likely to mislead the consumers as to the nature, substance, quantity or quality of such product or service; or
iii. conveys an express or implied representation which, if made by the manufacturer or seller or service provider thereof, would constitute an unfair trade practice; or
iv. Deliberately conceals important information.
22. The Consumer Protection Act, 2019, defines “misleading advertisements” under Section 2(28) of the Act. Further, the Act confers upon consumers the right to be informed, which includes the right to receive truthful and accurate information enabling them to make informed choices. Misleading advertisements undermine this right and adversely affect consumer interest, particularly in the field of education where aspirants invest significant time, effort, and financial resources.
23. It may be noted that what constitutes “important information” in an advertisement varies on a case-to-case basis and must be assessed from the consumer’s perspective. In the present case, specific course opted by successful candidates is an important information for the potential consumer i.e. IIT JEE & NEET aspirants. Reason being this will directly influence the perception of prospective minor aspirants regarding the efficacy, scope, and quality of the services offered by the coaching Institute.
24. With regard to the submission of the opposite party that it provides details such as name, photograph, rank, score, father’s name and place of residence of successful candidates and that, due to space constraints, course details could not be mentioned, the same is not legally tenable. The information such as father’s name and place of residence of the successful candidates is not material for potential minor consumers while evaluating the efficacy of coaching services. What is material and relevant for prospective minor students and their parents is the specific course opted by such successful candidates, the duration of such course, and the nature of engagement with the institute. This selective disclosure of information indicates a deliberate omission and reflects mala fide intent. Information about specific course opted by successful students enables consumers to assess whether the success achieved is attributable to a full-time classroom programme, foundation course, repeater batch, or a short-term test series. In the absence of such disclosures, the advertisement creates a misleading impression regarding the effectiveness of the courses offered by the institute and deprives consumers of their right to make an informed decision regarding enrolment. Therefore, the contention of the opposite party that it has disclosed sufficient information in the advertisement is unsustainable.
25 Further, it is pertinent to note that the CCPA issued the Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024 on 13.11.2024 to ensure transparency in advertisements issued by coaching institutes. Clause 3 and Clause 4 of the said Guidelines specifically require disclosure of rank secured by the successful candidate, name of the course attended, duration of the course, whether such course was paid, along with the candidate’s photograph and appropriate disclaimer. The impugned advertisement admittedly does not disclose the course opted by the successful candidates, thereby violating the aforesaid provisions.
26. The said Guidelines were already in force prior to issuance of the notice dated 16.04.2025 and were specifically referred to in the said notice. Therefore, the opposite party cannot take the defence of ignorance of law. The Guidelines were issued for the benefit of all stakeholders engaged in the coaching sector and laid down obligations of every person engaged in coaching to ensure that advertisements are not misleading. The Consumer Protection Act, 2019 is a consumer welfare legislation aimed at protecting consumer rights, and coaching centers must ensure compliance with Consumer Protection Act, 2019 and Guidelines laid down therein.
27. In the present case, the omission of course details of successful candidates amounts to deliberate concealment of important information. Section 2(28) (iv) of the Consumer Protection Act, 2019 provides that an advertisement shall be considered misleading if it deliberately conceals important information. The specific course attended by successful candidates is an essential fact that directly influences the consumer’s decision-making process. By prominently displaying ranks and selections while concealing whether such candidates were enrolled in long-term classroom programmes or only short-term test series, the opposite party created an exaggerated and misleading impression regarding its performance and the efficacy of its courses. Such selective disclosure amounts to deliberate concealment of material information and squarely falls within the definition of “misleading advertisement” under Section 2(28) (iv) of the Act.
28. Accordingly, the submissions made by the opposite party regarding space constraints and disclosure of other details do not justify non-disclosure of material information. The impugned advertisement, by highlighting successful candidates without disclosing the specific course opted by them, will mislead prospective minor students and parents and therefore constitutes a misleading advertisement and an unfair trade practice under the Consumer Protection Act, 2019.
29. CCPA further observed that in its reply dated 22.02.2026, the opposite party had submitted that “the figure of 1650+ selections is a cumulative and indicative representation of the successful students associated with the institute since its establishment in the year 1996, and the same demonstrates the longstanding academic legacy and consistent performance of the institute.”
30. However, during the hearing held on 12.03.2026, the representative of the opposite party submitted that the said figure of “1650+ CLCians in MBBS, IIT & Others” pertained to the results of the year 2024 alone and represented the number of students from the institute who secured selections in that year.
31. The aforesaid submissions made by the opposite party are mutually contradictory and inconsistent. While in its written reply the opposite party characterized the figure as a cumulative achievement across multiple years, during the hearing it claimed the same to be confined to the year 2024. Such shifting stands undermine the credibility of the claims made in the impugned advertisement and reflect absence of a clear, verifiable basis for the figure publicized. Furthermore, despite being afforded multiple opportunities during the preliminary inquiry, investigation, and subsequent proceedings, the opposite party failed to produce documentary evidence to substantiate either of the versions put forth by it. In the absence of supporting records, the claim “1650+ CLCians in MBBS, IIT & Others” remains unverified and unsubstantiated. Such inconsistency coupled with non-submission of documentary proof indicates that the claim lacks factual foundation and is liable to mislead prospective consumers regarding the actual performance of the institute.
32. With regard to the submission of the opposite party that terms such as “fresher”, “with XII” and “repeaters” are commonly understood within the student community and therefore sufficient to indicate the status of successful candidates, the same cannot be accepted. The advertisements in question are directed primarily towards minor school students preparing for competitive examinations. Such vulnerable minor consumers cannot be expected to interpret informal terminology used by opposite party or infer the exact nature of the course undertaken by successful candidates. The burden cannot be shifted upon prospective consumers to decode ambiguous expressions in order to understand the services actually availed by successful candidates.
33. It is the responsibility of the opposite party, being a service provider, to clearly and expressly disclose the specific course opted by the successful candidates, including the nature and duration of the course, instead of relying upon vague terms such as “fresher”, “with XII” or “repeaters”. These expressions do not indicate whether the candidate enrolled in a full-time classroom programme, foundation course, distance learning programme, crash course or a test series. In the absence of such clarity, the advertisement creates a misleading impression regarding the effectiveness of the courses offered by the institute and influence the decision-making of prospective minor consumers.
34. Accordingly, the contention of the opposite party that such terminology is commonly understood within the student community does not absolve it from its obligation to disclose material information. The opposite party is required to clearly mention the specific course undertaken by each successful candidate whose name and photograph are used in the advertisement, so as to ensure transparency and enable consumers to make an informed choice.
35. It is important to note that the doctrine of “Caveat Emptor” (“let the buyer beware”) has gradually evolved into “Caveat Venditor” (“let the seller beware”), thereby placing a greater onus on sellers and service providers. The doctrine of “Caveat Venditor” developed to impose enhanced obligations on sellers/service providers, and laws were enacted across the globe to protect consumer rights. In the modern world, consumer protection regimes have evolved with a focus on ensuring truthful and fair conduct by sellers, rather than burdening consumers with the sole responsibility of verification.
36. The opposite party submitted certain enrolment forms along with its response dated 22.02.2026. Upon examination of the said forms, the CCPA observed that most of the enrolment forms neither bear the signatures of the students nor those of their parents/guardians. In addition, no fee receipts or other evidences were furnished by the opposite party, despite being granted multiple opportunities and sufficient time to submit documentary evidence in support of its claims. Further, several of the forms submitted by the opposite party were found to be illegible and not clearly readable, thereby limiting their evidentiary value.
37. It was further observed from the available enrolment forms that a majority of the students had enrolled only for test series offered by the opposite party. However, the opposite party deliberately concealed this material information in the impugned advertisement while prominently displaying the names and photographs of such successful candidates, thereby creating a misleading impression regarding the nature of coaching services availed by them.
38. Clause 4(2) of the Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024 specifically mandates that any person engaged in coaching shall not use the name, photograph, testimonial or video of a successful candidate in any advertisement without obtaining written consent of such candidate subsequent to the declaration of the result/selection. The requirement of obtaining consent after the declaration of results is intended to ensure that candidates are fully aware of and voluntarily agree to the use of their achievements for promotional purposes.
39. Opposite party failed to provide any documentary evidence demonstrating that written consent was obtained from the successful candidates subsequent to the declaration of their results for use of their names, photographs, testimonials or other promotional material in the impugned advertisement. The opposite party merely submitted certain enrolment forms containing general clauses; however, such forms cannot be treated as valid consent in terms of the applicable guidelines.
40. In the present case, the opposite party has failed to furnish any such post-selection written consent from the successful candidates whose names and photographs were used in the impugned advertisement. In the absence of such documentary proof, the use of candidate’s identities for promotional purposes is in contravention of Clause 4(2) of the Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024. The conduct of the opposite party, therefore, amounts to non-compliance with the mandatory obligations prescribed under the said Guidelines.
41. The CCPA also observed that, as per the enrolment forms, several students had enrolled in the “Target Course” offered by the opposite party. Upon examination of the official website of the opposite party, it was noted that the “Target Course” is meant for students who have already passed Class XII. However, no such course details were disclosed in the impugned advertisement alongside the names and photographs of the successful candidates. The omission of such information further amounts to concealment of material facts, which are essential for prospective minor consumers to make an informed decision regarding enrolment in the institute.
42. In terms of the Consumer Protection Act, 2019, such conduct falls within the ambit of a “misleading advertisement” as defined under Section 2(28) of the Act, as the opposite party has made representations which are not supported by adequate substantiation and has deliberately concealed material information. The nondisclosure of crucial details, including the nature of the course, duration, and whether the courses were paid or free, amounts to concealment of important information, thereby misleading consumers. Further, such representations constitute an “unfair trade practice” under Section 2(47) of the Act, as they involve making false or misleading statements concerning the standard and quality of services, with the intent to promote the services offered by the opposite party.
43. It is further noted that the impugned claims were published by the opposite party in a full-page newspaper advertisement as well as on its official website. In the impugned advertisement, the opposite party prominently promoted various courses offered by it, including foundation and other classroom programmes, and devoted substantial space to other things highlighting the names, ranks and photographs of successful candidates. However, despite having sufficient space to promote its achievements, the opposite party failed to disclose the specific course opted by such successful candidates.
44. The selective disclosure of information in the impugned advertisement, wherein promotional details of the institute’s courses were highlighted while the course actually attended by the successful candidates was omitted, creates a misleading impression regarding the efficacy of the programmes offered by the institute. Such omission becomes more significant when the advertisement prominently attributes success to the institute without clarifying whether the candidates had enrolled in full-time classroom programmes, foundation courses, target batches, test series or Distance learning programmes.
45. The CCPA after carefully considering the written submissions, the submissions made by the opposite party during the hearings and the investigation report submitted by Director General (Investigation) finds that:-
i. The advertisement is false & misleading as it deliberately conceals important information with respect to the course opted by the said successful candidates from the coaching Institute and mislead potential consumers regarding the nature and quality of the institute’s services.
ii. The opposite party has violated the provisions related to misleading advertisement of the Consumer Protection Act 2019:-
a. Section 2(28) (i) -Falsely describes such product or service.
b. Section 2(28) (iii) – Unfair Trade Practice.
c. Section 2(28) (iv) — Deliberately conceals important information.
d. Section 2(47) – Unfair Trade Practice.
e. Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022.
f. Guidelines for Prevention of Misleading Advertisement in Coaching Sector, 2024.
46. The CCPA is empowered under Section- 21 of the Consumer Protection Act, 2019 to issue directions to the advertiser of false or misleading advertisement to discontinue or modify the advertisement and if necessary, it may, by order, impose a penalty which may extend to ten lakh rupees and for every subsequent contravention may extend to fifty lakh rupees. Further, Section 21 (7) of the above Act prescribes that following may be regarded while determining the penalty against false or misleading advertisement:-
a. the population and the area impacted or affected by such offence;
b. the frequency and duration of such offence;
c. the vulnerability of the class of persons likely to be adversely affected by such offence.
47. As of 01.04.2026, CCPA observed that the opposite party has continued to publish above-mentioned misleading advertisements/claims claims on its official website without disclosing the course opted by the successful candidates. The continued dissemination of such incomplete information amounts to concealment of material facts misleads prospective minor students and parents, thereby violating the right of consumers to be informed under the Consumer Protection Act, 2019. The opposite party operates 7 centres across India and also provides online coaching services. It has a substantial digital presence, including approximately 1.44 lakh subscribers on its YouTube channel. It is further noted that more than 11 lakh students apply for the IIT-JEE examination and approximately 15-20 lakh students apply for the NEET examination every year, thereby highlighting the vast target audience that will be influenced by such advertisements. In view of the wide reach and impact of the impugned advertisements, the CCPA is of the opinion that imposition of a penalty on the opposite party is necessary in the interest of consumers.
48. In view of the above, under Section- 20, 21 read with Section 10 of the Consumer Protection Act 2019, CCPA hereby issues the following directions:-
a. Discontinue the misleading advertisements with immediate effect.
b. In light of the nature of the violations detailed in the foregoing paragraphs, it is necessary (as discussed in above paras) that the opposite party is directed to pay a penalty of X5,00,000 with respect to publishing misleading advertisements.
c. The opposite party shall desist from further publication of misleading advertisement and make truthful & complete disclosures in future advertisements.
d. Submit a compliance report of the directions (a) & (c) above within 15 days of receipt of the Order.
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