Limited revisional power under consumer law cannot upset concurrent findings where premium receipt and delayed policy issuance showed deficiency of service.

The revisional jurisdiction under Section 21(b) of the Consumer Protection Act, 1986 is limited to jurisdictional error, illegality, or material irregularity, so concurrent findings are not to be disturbed on mere reappraisal of facts. On the record, the finance company had admitted receipt of the insurance premium through the demand draft, the loan and insurance formed a composite transaction, and the policy was issued only later. The deduction from the loan account did not displace the finding that premium had been received. As risk under Section 64VB(2) of the Insurance Act, 1938 could not attach before premium payment, delay in forwarding the amount for policy issuance amounted to deficiency of service and the relief in favour of the complainant was restored.

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Issues: Whether the National Commission was justified in interfering in revision with the concurrent findings that the finance company had received the premium amount, delayed forwarding it for issuance of the insurance policy, and thereby committed deficiency of service.

Analysis: The revisional power under Section 21(b) of the Consumer Protection Act, 1986 is narrow and is to be exercised only where there is jurisdictional error, illegality, or material irregularity. The record showed that the finance company had itself admitted receipt of the demand draft towards insurance premium and that the loan and insurance were part of a composite interlinked transaction. The deduction from the loan account was not a separate factual basis to dislodge the claim, and the policy was obtained only later. Under Section 64VB(2) of the Insurance Act, 1938, the risk could not be assumed earlier than the date on which the premium was paid.

Conclusion: The National Commission's interference was unjustified, the delay in obtaining the insurance policy amounted to deficiency of service, and the concurrent relief in favour of the complainant was restored.

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