Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Consumer RightsSupreme Court of India

M/s Nandan Biomatrix Ltd. v. S. Ambika Devi & Ors.

Civil Appeal · 2020 INSC 289Decided 6 Mar 2020
Civil Appeal Nos. 7357-7376 of 2010
Justice Mohan M. Shantanagoudar · Justice R. Subhash Reddy

Background

A small farmer (the respondent) responded to a seed company's advertisement and entered into a tripartite agreement to grow "safed musli," a medicinal crop, buying wet musli for sowing from the company, which promised to buy back her harvest at a guaranteed minimum price. When the company failed to buy back her produce, much of her crop was destroyed, and she filed a consumer complaint. The seed company argued she was not a "consumer" under the Consumer Protection Act, 1986, because the arrangement amounted to a "resale" of goods or was for a "commercial purpose," both of which are excluded from the Act's protection.

Decision Breakdown

The Supreme Court held that an agriculturist who grows crops using seeds purchased from a company, and who must sell that produce (to the company or elsewhere) to earn a living, is not engaging in "resale" or a "commercial purpose": she is earning her livelihood through self-employment, which is expressly protected under the Consumer Protection Act's definition of "consumer." The Court disapproved contrary National Commission rulings (like Sakthi Sugars) that treated farmer-sellers as automatically excluded, and emphasized the vulnerability of small farmers dealing with large seed companies. The Court dismissed the seed company's appeal, affirmed that the respondent was a "consumer," and imposed costs on the company for pursuing what it called frivolous litigation on a technical maintainability point rather than addressing the farmer's actual grievance.

Lesson Learnt

A small farmer who buys seeds and sells the resulting harvest back to the seller (or in the open market) to earn a livelihood remains protected as a "consumer" under consumer law, even though money changes hands both ways: agricultural self-employment is not treated as "commercial activity" for this purpose.

M/s Nandan Biomatrix Ltd. v. S. Ambika Devi & Ors. – Legal Case Shots | LegalAware