Charan Singh vs Healing Touch Hospital & Ors

The Supreme Court held that under Section 23 of the Consumer Protection Act, 1986, the National Consumer Disputes Redressal Commission's dismissal of the appellant's complaint without addressing the merits was improper. The Court emphasized the need for a realistic claim to be considered by the appropriate forum, and that the time spent before the Commission should be accounted for in the limitation period. The Court directed that the appellant's grievances regarding medical negligence and lack of consent for surgery should be properly adjudicated by the State Commission or District Forum.