Consumer forum powers are confined by statute: District Forums and State Commissions cannot review or recall ex parte orders.

Consumer fora under the Consumer Protection Act, 1986 can exercise only the powers expressly conferred by statute. The scheme of Sections 12, 13, 17, 22 and 22A shows that review and power to set aside ex parte orders were specifically conferred on the National Commission, not on District Forums or State Commissions. The contrary view recognising an inherent power to restore matters dismissed for default was held inconsistent with the legislative scheme and intention. Accordingly, District Forums and State Commissions lack power to recall, set aside, or review their own ex parte orders, and that power remains confined to the National Commission.

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Issues: Whether the District Consumer Forums, State Commissions, and the National Commission under the Consumer Protection Act, 1986 have the power to recall, set aside, or review their own ex parte orders.

Analysis: The Consumer fora are statutory tribunals and can exercise only such powers as are expressly conferred by the Act. Section 13(4) confers limited civil-court powers for specified purposes, and the scheme of Sections 12, 13, 17, 22, and 22A shows that the legislature specifically conferred review and ex parte-setting-aside power on the National Commission, while not extending the same power to the District Forums or State Commissions. The later view treating such fora as having inherent power to restore matters dismissed for default was held inconsistent with the statutory scheme and legislative intention. The amendment introducing Section 22A was understood as a deliberate conferment of the power only on the National Commission.

Conclusion: The District Forums and State Commissions do not have power to recall, set aside, or review their own ex parte orders. The contrary view was rejected, and the statutory power is confined to the National Commission as provided by the Act.

Ratio Decidendi: A consumer forum, being a creature of statute, cannot assume inherent power to review or recall its own ex parte order unless such power is expressly conferred by the Consumer Protection Act, 1986.

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