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Issues:
Delay in filing appeals before the State Commission, interpretation of Section 15 of the Consumer Protection Act, communication of orders by the District Forum, applicability of Haryana Consumer Protection Rules. Analysis: The judgment pertains to a case involving the appellant Housing Board, a statutory body providing housing facilities, and the additional demands raised due to judicial pronouncements enhancing land compensation. The Housing Board issued demand letters to allottees for increased land prices, leading to complaints by respondents before the District Consumer Forum. The Forum rejected objections by the Housing Board, prompting appeals to the State Commission, which were dismissed as time-barred. Subsequent revision petitions to the National Commission were also dismissed. The appellant argued that the appeals were filed within the prescribed period, citing delay in receiving the signed and dated order from the District Forum. The Court analyzed Section 15 of the Consumer Protection Act, emphasizing the provision for appeal within 30 days of the District Forum's order, with a discretionary clause for entertaining appeals beyond the period for sufficient cause. The judgment highlighted Rules 4(10) and 8(3) of the Haryana Consumer Protection Rules, emphasizing the communication of signed orders to parties free of charge for appeal filing. It underscored the Act's objective to protect consumer interests and ensure timely communication of orders to facilitate appeals. The Court ruled that the starting point for appeal limitation under Section 15 is the date of communication of the signed order, not the pronouncement date. It emphasized the importance of parties receiving orders to formulate grounds for appeal effectively. In this case, the appellant contended delay in receiving the signed order, supported by counsel's affidavit and admission by respondents. The Court determined that the appeals were filed within the limitation period, as the signed orders were received on 30.10.1992, justifying no delay in filing. Consequently, the appeals were allowed, setting aside the National and State Commission's orders and remitting the case to the State Commission for further proceedings. In conclusion, the judgment clarifies the interpretation of Section 15 of the Consumer Protection Act, emphasizing the necessity of timely communication of signed orders by District Forums to parties for appeal filing. It underscores the importance of procedural adherence to protect parties' rights and facilitate effective appellate processes in consumer dispute resolution.
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