Corporate buyer not a "consumer" under Section 2(1)(d) - commercial software license aimed at profit-making not personal livelihood

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....The SC held that the complainant, a corporate entity, was not a "consumer" under Section 2(1)(d) of the Consumer Protection Act, 1986 because the purchase of a software license was for commercial purposes to automate operations and maximise profits, not for self-employment or personal livelihood. The Court distinguished self-employed individuals from corporate entities, observing that the Explanation excludes only goods/services used exclusively for earning livelihood by self-employment. Both the State Commission and the National Commission correctly found lack of maintainability of the complaint on the consumer law forum. Consequently, the complaint was non-maintainable under the Act and the appeal was dismissed.....