On 13 November 1995, a three-judge bench held that medical services rendered for consideration fall within 'service' under the Consumer Protection Act 1986, opening the consumer fora to patients alleging deficiency in treatment.
Decided on 4 April 1995, this judgment defined the 'commercial purpose' exclusion from the meaning of 'consumer' and held that the 1993 self-employment Explanation brings back the person who buys goods to earn a livelihood.