CONSUMER PROTECTION ACT 1986 AND LEGAL PROFESSION IN INDIA: SOME NEW

DEVELOPMENTS
Author(s): Gurjeet Singh
Source: Journal of the Indian Law Institute , January-March 1999, Vol. 41, No. 1
(January-March 1999), pp. 56-65
Published by: Indian Law Institute
Stable URL: https://www.jstor.org/stable/43951696

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NOTES AND COMMENTS

CONSUMER PROTECTION ACT 1986 AND LEGAL PROFESSION

IN INDIA: SOME NEW DEVELOPMENTS

I Introduction

B Y VIRTUE of its section 1(4), the Consumer Protection Act 1986 (CPA) has be
made applicable to "all goods and services." However, attempts by the consum
forums, envisaged and established under this Act, to bring various types of servic
within its ambit have met with considerable resistance. Despite strong and repeate
protestations from some of the concerned sectors, the issues concerning inclusion
of services rendered by airlines, banks, housing boards, insurance companie
railways, roadways and telecommunications within the jurisdiction of CPA h
been by and large settled now. It may also be appropriate to mention here that th
attempts by the consumer forums to bring at least three types of services (
housing, medical and educational services) within the fold of CPA had met w
resistance to such an extent that in two cases (i.e., housing and medical profession
the matters went up to the Supreme Court for a final word and the third issue (i.
educational services) is also likely to be debated there. Thus with the pronoun
ments of the apex court in Lucknow Development Authority v. M.K.Gupta[ and in
the case of Indian Medical Association v. V.P.Shantha 2 the issues relating to
services rendered by the housing boards/societies/corporations and the ones r
dered by the medical professionals respectively appear to have been settled. Ho
ever, as far as applicability of CPA to the educational services is concerned, th
have been a large number of decisions - both in favour3 as well as against4 th
inclusion within the ambit of CPA - which has given rise to a lot of controver
and speculation. Nevertheless, the inevitable conclusion is that till the final w
on this issue too comes from the Supreme Court, the matter will certainly remain
in contention.5

1. (1993)1 CTJ 929 (SC).

2. (1995)3 CTJ 969 (SC).
3. See, e.g., Tilak Raj of Chandigarh v. Haryana School Education Board, Bhiwani, I (1992)
CPJ 76; Abel Pacheco Gracias v. Principal, Bharati Vidyapith College of Engineering, I (1992
CPJ 105; Controller of Examination, Board of Intermediate Examinations, Hyderabad v.
Kandukuri Uma Devi, 1 (1993) CPJ 572; Mumbai Grahak Panchayat, Bombay v. Registrar.
University of Bombay, I (1993) CPJ 37; and V. Murugesan v. Registrar, University of Madras .
1993 (1) CPR 190.
4. See, e.g., Nirmal Taneja v. Calcutta District Forum , II (1992) CPJ 591; Seema Bhatia v.
Registrar, Rajasthan University, II (1992) CPJ 899; Registrar, Evaluation University of K a rnatak
v. Poornima G. Bhandari , (1994)2 CTJ 408 (NC); Kurukshetra University v. Viney Parkash
Verma, (1994)2 CTJ 429 (NC); and Registrar, University of Madras v. Union of India. (1995
3 CTJ 100 (HC).
5. For details, see, Gurjeet Singh, "Increasing Ambit and Amplitude of the Consumer
Protection Act, 1986 - A Case Study of its Applicability to Educational Services", I (9) CTJ
166-87 (Sept. 1993); and, "Applicability of the Consumer Protection Act, 1986 to Educational
Services: Need for a Final Word from the Supreme Court of India", 3(5) CTJ 70-72 (May 1995).

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1999] CONSUMER PROTECTION ACT 1986 AND LEGAL PROFESSION IN INDIA 5 7

II Concept of contract of personal service under CPA

and liability 'of professionals

It may be appropriate to mention here that whereas CPA has been made appli
cable to "all goods and services"6 two types of services have categorically
kept out of the purview of this Act. These are, (i') services rendered free of cha
and ( ii ) services rendered under a contract of personal service.8 Whereas, there
hardly been any controversy with regard to the first term, the second term 'cont
of personal service' has been vehemently debated before the consumer forum
a large number of cases.9 In the context of medical profession, for instance
highest decision-making body under CPA - the National Consumer Dispute
Redressai Commission - has observed that a "contract of personal service' is
one which involves a "master and servant relationship"10 and which is wh
different from a "doctor-patient relationship."11 Thus according to the Nat
Commission, the service rendered by a medical doctor to his patients canno
called as 'personal service' coming within the exempted category mentione
section 2(1 )(o) of CPA.12
The aforesaid issue was ultimately debated at length before the Supreme Cour
in the case of Indian Medical Association v. V.P. Shantha .l3 It was in this casé th
the Supreme Court had finally held that CPA was applicable to the medical
fession in India. The Supreme Court had defined, distinguished and elaborat
discussed the two allegedly controversial terms, i.e., 'contract for services'
'contract of service' in this case and had observed:

A 'contract for services' implies a contract whereby one party undetakes

to render services e.g. professional or technical services, to or for another
in the performance of which he is not subject to detailed direction and
control but exercises professional or technical skill and uses his own
knowledge and discretion.... A 'contract of service' implies relationship
of master and servant and involves an obligation to obey orders in the work
to be performed and as to its mode and manner of performance.14

6. S. 1(4).
7. S.2(l)(o).
8. Ibid.

9. See, e.g., Motibai Dalvi Hospital v. M.I.Govilkar , 1991(1) CPR 334; Mappooyan v.
Premavathy Illango , 1991(2) CPR 460; Navaneethan v. Dr.Rathinasamy , 1992(1) CPR 41:
A.C.Modagi v. Cross Well Tailor, II (1991) CPJ 586 (NC); and Cosmopolitan Hospitals v.
Vasantha P. Nair , I (1992) CPJ 302 (NC). However, for a detailed discussion of these various
other cases and the issues contested therein, see, Gurjeet Singh, "The Concept of * Contract of
Personal Service' Under the Consumer Protection Act, 1986", 2(3) CT J 51-56 (March 1994).
10. See, Cosmopolitan Hospitals v. Vasantha P. Nair, id. at 310.
1 1 . Ibid.
12. Ibid. For a detailed analysis and comprehensive study of various cases, issues and
arguments advanced for and against the inclusion of medical profession within the jurisdiction
of the Consumer Protection Act 1986, see, Gurjeet Singh, "The Consumer Protection Act, 1986
and the Medical Profession in India: Conflicts and Controversies", 37 JILI 324-63 (1995).
13. Supra note 2.
14. Id. at 984.

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58 JOURNAL OF THE INDIAN LAW INSTITUTE [Vol. 41 : 1

According to the Supreme Court, the parliamentary dr

well accepted distinction betwen 'contract of service'
and that he had deliberately chosen the expression 'con
the expression 'contract for services' in the exclusionar
'service' in section 2(1 )(o) of CPA.15 The Supreme Co
cluded:

It is no doubt true that the relationship between a medical practitioner and

a patient carries within it certain degree of mutual confidence and trust,
and, therefore, the services rendered by the medical practitioner can be
regarded as services of personal nature but since there is no relationship
of master and servant between the doctor and the patient, the contract
between the medical practitioner and the patient cannot be treated as a
contract of personal service but is a contract for services and the service
rendered by the medical practitioner to his patient under such a contract
is not covered by the exclusionary part of the definition of 'service'
contained in section 2(1 )(o) of the Act.16

With the aforesaid verdict of the Supreme Court, at least the controvers
relating to the applicability of CPA to the medical profession in India appears
have been finally settled, notwithstanding the views expressed in favour17 an
against the verdict.18
As a matter of fact, a thorough study of the verdict of the Supreme Court in
general and a clear understanding of the interpretation of the two words 'contract
of service' and 'contract for services' given by the apex court in particular shou
have brought a clear cut message for other professionals that they too were within
the ambit and jurisdiction of CPA. However, this did not happen. This is notwit
standing the fact that many consumer protagonists have been time and again
arguing about it. For instance, one of the consumer activists had observed:

All professionals - Advocates, Architects, Chartered Accountants, Doc-

tors, Engineers, Interior Decorators and others - are covered under the
Consumer Protection Act, 1986.... All the professionals are licenced and
covered under respective laws of the land. So it does not mean that
profesionāls are not liable for due compensation under the Consumer
Protection Act for their 'negligence' and 'deficiency' in service.19

He had further observed:

It is no doubt true that the relationship between a professional man and a

consumer carries with it certain degree of mutual confidence and trust, and

15. Ibid.
16. Id. at 985.
17. See, e.g., Sheeraz Latif A. Khan, "Patient as Consumer", 2(2) CPJ 4-7 (June 1996
18. See, e.g., C. Manickam and K.R.Mythili, "Medical Profession and the Consumer Pro
tection Act in India", 1(2) CPJ 1-6 (Feb. 1997).
19. P.D. Dalmia, "Consumers Versus Professional", 1(4) CPJ 15 at 16 (April 1996).

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1999] CONSUMER PROTECTION ACT 1986 AND LEGAL PROFESSION IN INDIA 59

therefore, the services rendered by a professional man can be regarded as

service of personal nature but since there is no relationship of 'Master' and
'Servant' betwen the professional man and the consumer, the contract
between them cannot be treated as 'contract of personal service' but it is
'contract for service' and the service rendered by a professional man to his
customer or client under such a contractais not covered by the exclusion-
ary part of the definition for 'service'. Hence all professionals are answer-
able and covered under the Consumer Protection Act, 1986 which is
unique piece of legislation.20

Notwithstanding the above and similar other observations from various con-
sumer protagonists, the professionals, especially the advocates, continued to con-
sider themselves outside the jurisdiction of CPA. Another factor that contributed
to the apathy of the advocates towards the consumers/litigants was a decision of
the National Consumer Disputes Redressai Commission in K. Rangaswamy v. J ay a
Vittal 21 which was pronounced as far back as in the year 1990. In this case, the
Commission had categorically stated that the service offered by an advocate to ą
litigant was the one under the 'contract for personal service' and therefore could
not be considered as the 'service' within the meaning of CPA. However, the Madras
High Court has recently pronounced a landmark decision on the said issue which
is completely opposed to the one pronounced by the National Commission. In the
following sub-sections of the present paper, are discussed the cases and some of the
issues therein have been highlighted as well as the probable implications of these
decisions for the legal profession in the country.

Ill Consumer Protection Act and legal profession in India

Roscoe Pound defines professions as "callings in which men pursue a learned

art and are united in the pursuit of it as a public service."22 According to another
scholar, Marshall, "Professions are a select body of superior occupants where
commercialisation cannot be tolerated and which are pursued not for pecuniary
gains but out of a sense of duty to serve society."23 Service to individuals in a
private relationship of trust betwen the practitioner and the client is inherent in the
idea of professionalism. Thus a profession differs from business in that it is com-
mitted to public service and the earnings resulting from such a service is only an
incidental one.24
The lawyers' calling is a profession as it has all the ingredients of a profession
namely, (/) collective organisation (the Bar); ( ii ) a spirit of service (a duty to the
community often transcending the duty towards a particular client); (Hi) learning
and status.25 As a matter of fact, the profession of law has been characterised as

20. Ibid.
21. I (1991) CPJ 685 (NC).
22. Roscoe Pound quoted in M.K.Ramesh, "Consumer Interest in Legal Profession: Problems
and Perspectives", Cochin U L Rev 405 at 408 (1989).
23. T.H. Marshall quoted in M.K.Ramesh, ibid.
24. M.K. Ramesh, Ibid.
25. Ibid.

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60 JOURNAL OF THE INDIAN LAW INSTITUTE [Vol. 41 : 1

'noble profession' for good reasons. A case is won or lo

or inability of the lawyer to cope and tackle with the
bringing his ingenuity, ability, mental resourcefuln
advocacy to bear upon it.26
The legal profession in India has a history of over tw
of Indian struggle for freedom is interwoven with that o
positive role in the evolution and establishment of the
India and during the testing times of Emergency (1975
sion in a very high public esteem.27
Though it may seem paradoxical, it is a hard fact th
law which is expected to provide specialised services t
their causes, is nowadays witnessing resentment amo
example, ever since the implementation of CPA, unlik
which came up against the medical profession, though
cases involving issues relating to the legal profession
consumer forums,29 this does not indicate a healthy tr
least two of the cases and the contradictory decisions
cases as well as their probable implications which is t
present paper.
Perhaps the first reported case on the issue was K. Ran
The complainant in this case had engaged the services
for conducting a civil writ petition before the Karnata
consolidated fee of Rs.2500. The complainant alleg
advocate through two cheques. When the said writ pet
it was, passed over to the next day on account of the a
counsel. The said case was not reached on the next date, to
respondent demanded Rs.3000 more but the complaina

26;,Gurjeet Singh, "Some Observations on the Art of Advoca

U 57 (July 1984).
27. M.K. Ramesh, supra note 22 at 409.
28. For a detailed study of the role and responsibilities of
indepth analysis of the various -problems being faced by consum
especially in the light of the Consumer Protection Act 1986, s
29. As far as the reported case law on consumer protection is
leading Indian Consumer Law Reporters, i.e., Consumer Prot
Protection Reporter , and Consumer Protection and Trade Pract
enabled us to find only the following cases on the subject. The
Vittal^ supra note 21, Kankati Annapurnamma v. A. P. State Le
(1) CPR 418 (NC); S. P. Thirumala Rao v. Bar Council of India
Pandhi v. District Magistrate , II (1992) CPJ 883; S. Mahendran v.
1992 (2) CPR 668; R. Sathyanarayan v. Registrar, Supreme Cour
B. Bakshappa v. Registrar General, High Court of Karnataka , I
v. Akhil Bharatiya Grahak Panchayat , II (1993) CPJ 816; Kan
Seth , Advocate , III (1993) CPJ 1270; P.N. Rangaswamy v. Rupe
1258; Akhil Bharatiya Grahak Panchayat v. State of Gujarat , I
Panda v. Krushna Chandra Dehuri , III (1994) CPJ 397; and Kumaran Apartments Owners
Association v. Civil Rights Cell, 1994(3) CPR 491.
30. Ibid.

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1999] CONSUMER PROTECTION ACT 1986 AND LEGAL PROFESSION IN INDIA 61

to pay the said amount. The respondent failed to appear on behalf of the com
ant on the day of the next hearing and the case of the complainant was accor
dismissed. On being informed about the dismissal of the writ petition, the re
dent advised the complainant to file an appeal before the Supreme Court
promised to help the complainant by entrusting his appeal to some of his
at New Delhi on the payment of a fee of Rs. 10,000. The complainant h
spurned his offer and instead filed a complaint against the respondent f
professional misconduct. Thus the main issue involved in this case was whethe
services rendered by an advocate to a litigant for a fee was a 'contract of per
service'? The National Consuitier Disputes Redressai Commission answer
question in the affirmative and held that the service offered by the responde
the complainant was one under the 'contract of personal service' and the
could not be considered as 'service' within the meaning of CPA. According
Commission, the complainant was not a consumer within the meaning of
2 (d) of CPA and the dispute between him and the respondent could not be te
as a "consumer dispute".31
The above issue has, once again, been vehemently contested in Srimci
Union of India?2 - a recent case decided by the Madras High Court. In th
the court held that the consumer forums have got the necessary jurisdiction
with the claims- against the advocates. The decision in this case has given
another controversy and that concerns the applicability of CPA to the leg
fession in India.
The Madras High Court in this case was dealing with a bunch of writ petitions
which had been filed by the practising advocates against whom claims had been
filed by certain persons in the respective cases before the consumer disputes
redressai forums. The common question raised in these writ petitions was regarding
the validity of section 3 of CPA and a prayer was made in all the writ petitions for
a declaration that section 3 of the Act was unconstitutional being opposed to the
objects of the said Act. It may be mentioned here that section 3 of the Act lays down
that this Act is "in addition to and not in derogation of the provisions of any other
law for the time being in force." According to the petitioners, if section 3 was struck
down as unconstitutional, it would not be possible for any person to drag the
advocates before the consumer forums as the claim will be outside the scope of the
said Act. It.was further submitted that in a proceeding before the consumer forum,
no court fee is payable and that it may be possible for any person to file a frivolous
action against the advocate in that forum and even if that persons fails ultimately,
he would lose nothing. However, on the other hand, if the advocate concerned
wanted to file a claim for damages, it could not be filed without the payment of
the court fee by him in the civil court. According to the petitioners, such provisions
could cause "undue hardship and place the advocate in a hazardous situation
thereby making his profession worthless".33

31. Id. at 687.

32. (1997) 5 CTJ 99.
33. Id. at 100.

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62 JOURNAL OF THE INDIAN LAW INSTITUTE [Vol. 41 :

The Madras High Court, after referring to the sta

reasons of CPA rejected the petitioners' contentions.

We are unable to find anything in the Statement o

which runs counter to the provisions of section 3
section 3 of the Act says is that the provisions o
addition to and not in derogation of the provision
other words, the Act does not have the effect of o
ments with reference to matters dealt with in the
provides that it will be open to any person to claim t
and also avail himself of the provisions of other enact
inconsistency of conflict and if he is not barred ot
principles of law, like estoppel or election.34

With regard to the contention that once section 3

tional, no person could institute any proceeding befor
High Court held that even if the section was declared
other sections of the Act will continue to be intact and if the services of the
advocate fall within the definition of service under Section 2 (o) of the Act,
it will certainly be open to a client to proceed against the advocate before
Consumer Redressai Forum/'35 The court further observed that the object of
petitioners to exclude the advocates from the purview of the consumer redr
forum could not be achieved by the grant of the prayer made in the writ petitio
namely, to declare section 3 of the Act as unconstitutional.36
Another argument put forward by the petitioners was that they were govern
by the provisions of the Indian Advocates Act and that they shall not be mad
answer the claims under CPA. It may be appropriate to mention here that an exac
similar plea was taken by the medical professionals before the Supreme Cour
the case of Indian Medical Association v. VāP.Shantha}n However, while rejec
their plea, the apex court had categorically held:

The fact that medical practitioners belong to the medical profession and
are subject to the disciplinary control of the Medical Council of India aild/
or State Medical Councils constituted under the provisions of the Indian
Medical Council Act would not exclude the services rendered by them
from the ambit of the Act.38

In raising the contention that the advocates were governed by the Indi
Advocates Act, the petitioners placed reliance on the decision in the case o
Nathamal Ashok Kumar v. Western Railway}9 The main issue involved in that
was whether a complaint filed before the consumer forum under section 12

34. Id. at 101.

35. Ibid .
36. Ibid.

37. Supra note 2.

38. Id. at 989-90.
39. 1 (1991) CPJ 618.

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1999] CONSUMER PROTECTION ACT J 986 AND LEGAL PROFESSION IN INDIA 63

with section 17(l)(a) of CPA was barred by the provisions of section 15 o

Railway Claims Tribunal Act 1987. Section 15 of the 1987 Act bars the jurisdict
of any court or other authority in relation to the matters referred to in sub-
1 of section 13 of that Act. According to the Rajasthan State Commission, the
made before the said forum fell within the scope of section 13 and conseq
the bar under section 15 of the said Act would apply. Hence it was held th
proceedings before the forum were not maintainable, inasmuch as, they were
by section 15 of the Railway Claims Tribunal Act.40
The Madras High Court, however, rejected this contention, too. On this
the court held:

The ruling cannot help the petitioners herein as it is a question of inter-

pretation of the relevant provisions of the Act. It is seen that there is a
specific section in the Railway Claims Tribunal Act barring the jurisdic-
tion of other courts and authorities. But, there is no such provision in the
Advocates Act to bar the jurisdiction of other courts and authorities or
Tribunals in relation to matters connected with the advocates or disputes
arising between the clients and their advocates. Section 6 of the Advocates
Act sets out the functions of State Bar Council. There is no provision in
the Advocates Act to enable the Bar Council to deal with the dispute
between the client and the advocate if the clients seek a remedy of
damages or refund of money paid to the advocates or sums on monetary
claim. The Bar Council can deal with only disciplinary matters and con-
sider whether the advocate is guilty of misconduct which will fall under
Section 6(1) of the Advocates Act. Hence, there is no substance in the
contention that the Advocates Act will prevail over the Consumer Protec-
tion Act and Consumer Redressai Forum will have no jurisdiction to deal
with claims against the advocates.41

The Madras High Court also rejected the argument that an advocate will have
to pay court fee if he wanted to proceed against his client for damages or other
remedies, whereas the client did not require to pay the court fee if he went before
the consumer redressai forum. According to the High Court, that could not in any
way invalidate the provisions of CPA.
The petitioners finally argued that a client who engaged an advocate for
professional services, was not a 'consumer' under section 2(1 ){d) of CPA. This
contention was also rejected by the High Court. The court held that the language
of the said section was very wide and that it used the expression 'avails of any
service for a consideration'. Thus according to the court, "that will not certainly
exclude the services rendered by an advocate."42 The High Court referred to the
definition of the term 'service' as given in section 2(1 )(d) of CPA. A reference was
also made to a landmark decision of the Supreme Court, that is the case of Lucknow

40. Id. at 620.

41. Supra note 32 at 101.
42. Id. at 102.

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64 JOURNAL OF THE INDIAN LAW INSTITUTE [Vol. 41 : 1

Development Authority v. M.K.Gupta š43 In the said case, for

Court, while referring to the word 'service' had made the

The term has a variety of meanings. It may mean any b

resulting in promoting interest or happiness. It may be co
sional, public, domestic, legal, statutory, etc. The con
very wide.44

Thus, the Madras High Court, rejected all arguments o

dismissed all the writ petitions. According to the court,
redressai forums had the necessary jurisdiction to deal w
advocates. Referring to the definition of the term 'serv
observed that, "the first part of the section makes it cle
description will fall within the scope of the section"45 and
include the service of lawyer to his client."46

IV Implications and conclusion

According to the consumer protagonists, and rightly so, th

Madras High Court has spelled out what was "already an ac
services of advocates were covered under the Consumer Protection Act."47 As a
matter of fact, there is hardly any need for repeating the arguments put forward by
the advocates for keeping them outside the jurisdiction of CPA for there appears
to be no real substance in those arguments. Nevertheless one important point which
deserves mention here is that there are now two inherently contradictory decisions
involving exactly the same issue, that is, the applicability of CPA to the legal
profession. It may be recapitulated here that whereas the National Commission in
K. Rangaswamy v. Jaya Vittal 48 had held that advocates were not governed by the
provisions of CPA and that the dispute between an advocate and consumer did not
constitute a 'consumer dispute', the Madras High Court in its decision in Srimathi

43. Supra note 1.

44. Id. at 935.
45. Supra note 32 at 102.
46. Ibid.
47. Rosy Kumar, "Advocates and the Consumer Protection Act", 5(2) CTJ 29-30 at 30 (
1997). Also see, Rajesh Gupta and Gunjan Gupta, "Pervertive Professional and Per
Consumer: Dr. Subramanian's Case - A Critique", 2(4). CP J 33-44 (Aug. 1994). In this
the learned authors who are themselves practising advocates, while expressing their v
on legal services have argued that "although judiciary being sovereign function of th
outside the ambit of the Act, Advocates are not." {Id. at 37). Similar opinion has been
by another scholar who finds "no reason why lawyers should be excluded from the Act
the fact that they like doctors are professionals and are subject to the disciplinary c
^he State Bar Council and the Bar Council of India." According to the learned author,
Indian advocate, Soli J. Sorabjee also feels the same. The author further laments tha
"catalogue of grievances against lawyers, about high charges, negligence by which th
get barred by limitation and incompetent advice, is formidable." For details, see, She
A. Khan, supra note 17 at 4-7.
48. Supra note 21.

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1999] CONSUMER PROTECTION ACT 1986 AND LEGAL PROFESSION IN INDIA 65

v. Union of India*9 has held the opposite. Once again, this issue too is likely
be debated before the Supreme Court. Therefore, till the final word comes from
apex court, the matter shall remain in contention. Till then, one thing is clear, a
that is with the aforesaid thought provoking decision by the Madras High C
holding that advocates were within the jurisdiction of CPA no professional
seems to be outside its purview. While concluding the discussion, once again
may be argued that with the implementation of CPA and as a result of some of
far reaching decisions pronounced by the consumer disputes redressai forums, t
is a clear message for accountability on the part of every segment of society
general and that of the professionals in particular. Irrespective of the nature
style of their job and duties, they would now have to be accountable and ans
able to the society in general and to the consumers who engage them in particul

In summing up, a consumer activist has rightly observed:

Medical professionals are not the only ones being held liable for profes-
sional negligence under the Consumer Protection Act. The long arm of the
law extends to almost everyone who renders service for a fee - lawyers,
architects, engineers, chartered accountants.50

Therefore, the inevitable conclusion of the above discussion is that if us

properly, CPA which is a benevolent, beneficial and indeed a consumer frie
legislation, can definitely ensure accountability in almost every profession. W
is required is the necessary awareness amongst consumers about their rights
above all their willingness to assert for these rights as well as the determination
confidence to expose the negligent and insensitive professionals.

Gurjeet Singh*

49. Supra note 32.

50. Pushpa Girimaji, "All Professionals Come under CPA", The Times of India , p. 14, 22 J
1996.
* Reader in Law, Guru Nanak Dev University, Amritsar, Punjab.

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