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Issues: Whether limitation for filing an appeal under Section 15 of the Consumer Protection Act, 1986 commenced from the date of pronouncement of the District Forum's order in open court or from the date on which a signed and dated copy of the order was communicated to the parties free of charge under the Rules.
Analysis: Section 15 prescribes a 30-day period for appeal from the date of the order, while Rule 4(10) requires the District Forum's order to be signed, dated, and communicated to the parties free of charge. Rule 8(3) also contemplates a certified copy of the order accompanying the memorandum of appeal. Reading these provisions together, the limitation scheme was held to protect the right of appeal by ensuring that the affected party has access to the signed order containing the reasons and contents before the period begins to run. Mere pronouncement in open court was held insufficient where the signed and dated copy had not yet been communicated.
Conclusion: Limitation began only when the signed and dated copy of the order was made available and communicated, and the appeals filed on that basis were within time.