On 24 August 2020 a two-judge bench of the Supreme Court — Justices D.Y. Chandrachud and K.M. Joseph — held that DLF's failure to hand over possession of flats in 'Westend Heights', Begur, Bengaluru, within the contractual 36-month period constituted 'deficiency in service' under the Consumer Protection Act 1986; that flat-buyers were not confined to the meagre Rs 5 per square foot per month delay-compensation cap in the one-sided Apartment Buyer's Agreement; that the consumer forum could award just and reasonable compensation; and that 6% per annum simple interest on the entire amount paid was awardable in addition to the contractual delay compensation. The judgment crystallised the one-sided clause doctrine months before its formal articulation in IREO Grace Realtech (January 2021).