Statutory registration and stamp-duty functions are not consumer services, so consumer fora lack jurisdiction over related complaints.

Performance of statutory functions under the Registration Act and the Indian Stamp Act does not amount to a consumer "service" under the Consumer Protection Act, 1986. The Sub-Registrar and Collector, when examining stamping, impounding instruments, determining duty, and dealing with registration, act in discharge of statutory and, in relevant respects, quasi-judicial duties rather than in a service provider capacity. Payment of registration charges or stamp duty does not make the presenter a consumer, and consumer fora lack jurisdiction over complaints based on these acts. The statutory remedies and safeguards under the registration and stamp laws remain the proper framework for such disputes.

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Issues: Whether the authorities functioning under the Registration Act and the Stamp Act, while determining stamp duty and dealing with registration of an instrument, render a "service" to the presenter so as to bring the dispute within the Consumer Protection Act, 1986, and whether the consumer fora had jurisdiction to entertain a complaint alleging deficiency in service.

Analysis: The definitions of "consumer", "service" and "deficiency" under the Consumer Protection Act, 1986 were examined in the context of the statutory scheme governing registration and stamp duty. The process of registration and stamp-duty determination was held to be primarily part of the State's revenue machinery. The Sub-Registrar and the Collector, when examining whether an instrument is duly stamped, impounding it, determining the proper duty, and acting upon refusal or registration, discharge statutory duties and, in relevant parts, quasi-judicial functions. The payment of registration charges or stamp duty does not convert the presenter into a consumer, nor does it transform the discharge of statutory functions into a consumer service. The statutory safeguards and remedies under the Registration Act and the Indian Stamp Act, together with the protection afforded to judicially acting officers, further indicated that the complaint did not fit within the consumer jurisdiction.

Conclusion: The consumer fora had no jurisdiction and the complainant was not a consumer in respect of the acts complained of.

Final Conclusion: The appeal failed because the dispute arose from statutory revenue functions under the Registration Act and the Indian Stamp Act, not from a consumer-service relationship.

Ratio Decidendi: Performance of statutory or quasi-judicial duties in the collection and adjudication of stamp duty and registration charges is not a "service" under consumer law, and the person invoking those statutory procedures is not a "consumer" for that purpose.

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