Single-member judicial Benches of the National Commission possess valid jurisdiction and are not coram non-judice.

The petitioner, Smt Sita Devi, filed a consumer complaint alleging non-payment of interest by the respondent bank on her husband's pension arrears and fixed deposits.

Both the District Commission and the State Commission ruled in favor of the petitioner.

The respondent bank filed a revision petition before the National Consumer Disputes Redressal Commission (NCDRC).

A single-member Bench, presided over by the President of the NCDRC, partly allowed the revision by reducing the awarded interest and rendering new factual findings regarding the non-renewal of fixed deposits.

The petitioner challenged this order before the Delhi High Court on grounds of improper quorum (coram non-judice) and excess of revisional jurisdiction.

Whether a single-member Bench of the National Commission comprising a judicial member constitutes a valid quorum under the Consumer Protection Act, 2019.

Whether the National Commission exceeded its revisional jurisdiction by interfering with the concurrent findings of fact rendered by the lower Commissions.

The court applied Section 58(2) of the Consumer Protection Act (CPA), 2019, which stipulates that the jurisdiction of the National Commission may be exercised by Benches constituted by the President with one or more members.

It further invoked Section 64 of the CPA, 2019, which provides that no proceeding shall be invalid due to any defect in the constitution of the Commission.

Regarding revisional powers, the court relied on the principle established in Sunil Kumar Maity v. State Bank of India, holding that revisional jurisdiction under the Act is extremely limited and cannot be used to re-appreciate evidence unless there is a jurisdictional error or material irregularity.

On the issue of quorum, the Court disagreed with the Rajasthan High Court’s view in Iffco-Mc Crop Science Pvt. Ltd., clarifying that the statutory scheme of Section 58(2) of the CPA, 2019 expressly permits single-member Benches.

Since the impugned order was passed by the President (a judicial member), it was consistent with Regulation 12 of the 2020 Regulations, which empowers judicial members to handle complex legal questions.

However, on the merits of the revision, the Court found that the NCDRC improperly acted as a court of first appeal.

By substituting its own factual findings regarding the renewal of fixed deposits and reducing the interest rate without identifying a "material irregularity" in the lower courts' orders, the NCDRC exceeded the narrow restrictive limits of its revisional jurisdiction.

The High Court set aside the NCDRC’s order dated 02.08.2017 and allowed the writ petition, effectively restoring the findings of the District and State Commissions.