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Surendra Mohan Arora v. HDFC Bank

Civil Appeal · Neutral citation not assigned (Civil Appeal No. 4891 of 2014)Decided 25 Apr 2014
Civil Appeal No. 4891 of 2014
Justice Gyan Sudha Misra · Justice Pinaki Chandra Ghose

Background

After the National Consumer Commission rejected his loan-related complaint and review application, a consumer challenged Regulation 15. He argued that deciding a review by circulation without oral arguments violated his right to be heard. The Delhi High Court rejected his challenge, and he appealed.

Decision Breakdown

The Supreme Court dismissed the appeal and upheld the regulation and the High Court order. The Commission's statutory review power was limited to an apparent record error, and the Act authorised it to regulate the procedure. Regulation 15 allowed oral hearing when the Commission ordered it, but did not require it in every review. The appellant had not even requested oral hearing in his review application, and his additional objection about proxy counsel also failed; the Court did not reopen the loan dispute's merits.

Lesson Learnt

Review is a limited correction procedure and does not necessarily require a fresh oral hearing. If oral submissions are needed, request them expressly and explain the review ground under the governing procedure.

Official source (sci.gov.in)View Judgment (PDF)

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