January 13, 2026 : The National Consumer Disputes Redressal Commission (NCDRC) has dismissed a revision petition seeking replacement of a 2014 Maruti Suzuki Celerio, holding that replacement of a vehicle is not an automatic remedy unless an inherent and irreparable manufacturing defect is established.
The Bench comprising Justice A.P. Sahi (President) and Bharatkumar Pandya (Member) passed the order in Revision Petition No. NC/RP/403/2022, titled Vinay Kumar Mishra v. Maruti Suzuki India Pvt. Ltd., affirming the State Commission’s decision to award monetary compensation instead of directing replacement.
Background
The complainant had purchased a Maruti Suzuki Celerio in 2014 and alleged that the vehicle suffered from inherent defects in its braking system. The District Consumer Commission accepted the complaint and, by order dated 16 July 2019, directed replacement of the vehicle along with ₹10,000 as compensation and ₹10,000 as litigation costs.
The manufacturer challenged the order before the State Consumer Commission. The State Commission found no evidence of a manufacturing defect and set aside the replacement direction. Instead, it awarded ₹70,000 as compensation for mental agony and ₹30,000 towards litigation costs, with interest at 9%.
Aggrieved, the complainant approached the NCDRC seeking restoration of the replacement order.
Findings of the NCDRC
From the service records placed on record, the Commission noted that the braking issue had been attended to during service visits. On one occasion, greasing of caliper pins was recorded, and a recommendation was made for replacement of the caliper assembly. Subsequent job cards indicated that no abnormality was found and that the vehicle’s mileage was recorded at 22.9 km per litre.
The Commission also took note that the vehicle had covered over 69,000 kilometres as per the last service record dated 15 January 2024, demonstrating extensive use.
It held that a partial defect in a component that is later rectified cannot justify replacement of the entire vehicle. A “manufacturing defect”, the Commission observed, must be fundamental in nature and beyond repair. Mere allegations or intermittent issues do not meet that threshold.
On Expert Evidence
While reiterating that expert evidence is not mandatory in every case, the Commission clarified that such evidence becomes necessary where the alleged defect cannot be determined without proper technical analysis. In the present case, no laboratory test, expert opinion, or technical report was produced to substantiate the claim of an inherent manufacturing defect.
Referring to settled principles, the Commission observed that Section 13(1)(c) of the Consumer Protection Act requires laboratory testing only where defects cannot be determined without proper analysis. Where sufficient documentary evidence such as service records exists, absence of expert evidence is not fatal. However, in this case, the available record did not establish any persistent or irreparable defect.
Conclusion
The NCDRC found no illegality or material irregularity in the State Commission’s order. Considering the rectification of the braking issue, absence of expert proof of a manufacturing defect, and extensive usage of the vehicle for nearly a decade, the Commission held that the complainant had been adequately compensated. Accordingly, the revision petition was dismissed
