News Citation : 2026 LN (CGSCDRC) 12
February 17, 2026 : In a significant order dated February 17, 2026, the Chhattisgarh State Consumer Disputes Redressal Commission in Raipur partly allowed an appeal filed by Binni Tripathi against the Chief Engineer of CSPDCL and another official, setting aside a district commission’s earlier dismissal of her complaint.
The case arose from a dispute over an electricity bill issued for August 2024. Tripathi, a resident of Ambikapur in Surguja district, had been regularly paying her electricity dues under connection number 1009062487. However, in August 2024, she received a bill of Rs 25,460, which she claimed was excessive.
After she approached the electricity department, the bill was revised. According to the record, a rebate of Rs 9,629 was granted and the payable amount was recalculated at Rs 16,730 based on minimum slab rates for consumption between January and June 2024. Still dissatisfied, Tripathi sought further clarification and requested a review of the earlier meter.
The dispute followed the replacement of her old meter with a smart meter in July 2024. The department maintained that the August bill was prepared on the basis of combined readings from the old and new meters. It argued that the revised amount reflected actual consumption and that the consumer was unwilling to clear the dues despite adjustments. Records show that Tripathi later paid Rs 4,500 in December 2024, even after filing her complaint.
The District Consumer Commission in Ambikapur dismissed her complaint on February 12, 2025, holding that the matter fell outside its jurisdiction, referring to provisions of Section 126 of the Electricity Act, 2003, which deal with unauthorized use of electricity.
On appeal, the State Commission examined the legal framework more closely. It referred to Supreme Court precedent in U.P. Power Corporation Ltd. v. Anis Ahmad (2013) 8 SCC 491, which clarified that complaints related to unauthorized use under Sections 126 and 135 of the Electricity Act are not maintainable before consumer forums.
However, the Commission also noted that not all electricity billing disputes automatically fall under Section 126. Under Section 42 of the Electricity Act, consumers can approach designated grievance redressal forums and ombudsman authorities for billing disputes not involving allegations of theft or unauthorized use. The Chhattisgarh State Electricity Regulatory Commission’s grievance regulations further define “complaint” to include meter reading and electricity bill-related grievances, except those involving unauthorized use or theft.
Importantly, the State Commission pointed out that the Consumer Protection Act, 2019 does not bar a consumer from approaching a consumer forum unless the dispute squarely falls within the exclusionary provisions of the Electricity Act. It held that the District Commission erred in dismissing the complaint solely on jurisdictional grounds without examining whether the case truly involved unauthorized use.
As a result, the State Commission set aside the district order and remanded the matter back to the Ambikapur District Consumer Commission for fresh adjudication on merits. Both parties have been directed to appear before the district body on March 30, 2026. The Commission clarified that each side will bear its own costs.
The order reopens the door for a substantive hearing on whether the revised electricity bill was justified and whether there was any deficiency in service.
Case Reference : Appeal No. SC/22/FA/116/2025: Binni Tripathi v. Chief Engineer, Electricity, CSPDCL & Another.
