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Issues: Whether Section 230 of the Contract Act applies to proceedings before consumer fora and whether an agent can rely on that provision in defence of a consumer complaint.
Analysis: The Contract Act was held to apply to litigants before consumer fora as well. An agent is entitled to invoke Section 230 of the Contract Act in proceedings under the Consumer Protection Act, and such a defence cannot be rejected merely because the proceeding is a consumer complaint. The contrary view of the National Commission was found erroneous.
Conclusion: Section 230 of the Contract Act is applicable to consumer proceedings, and the agent's defence based on that provision is maintainable. The decision of the National Commission was set aside and the order of the State Commission restored.