LAXMI ENGG.WORKS vs PSG INDUSTRIAL INSTITUTE

The Supreme Court interpreted the definition of 'consumer' under Section 2(d) of the Consumer Protection Act, 1986, specifically addressing the exclusion of individuals obtaining goods for 'any commercial purpose'. The Court clarified that the amendment made by Ordinance 24 of 1993, which states that 'commercial purpose' does not include goods used exclusively for self-employment, applies only to complaints filed after the amendment's effective date. The Court held that since the appellant's complaint was filed prior to this amendment, the appellant qualifies as a consumer under the original definition, allowing the complaint to proceed.