SpiceJet Ltd. v. Ranju Aery

An airline cancelled a connecting flight, refused a refund, and offered no alternative — leaving a family to book a replacement flight themselves at nearly four times the original fare. Three consumer forums in a row, right up to the national commission, agreed this was exactly the kind of deficiency in service the Consumer Protection Act exists to remedy.

Parties

SpiceJet Ltd. — petitioner (opposite party/airline); the revision petitioner before the National Consumer Disputes Redressal Commission.

Ranju Aery — respondent/complainant; a passenger who had booked flights for herself and family members.

Facts

Ranju Aery booked air tickets online, through the website Yatra.com, for herself and her family members for travel from New Delhi to Bagdogra on 23 June 2015, with a return journey from Bagdogra to Kolkata on a connecting SpiceJet flight.

SpiceJet cancelled the connecting flight the complainant and her family were booked on. The airline neither refunded the fare the family had already paid for the cancelled flight, nor provided any alternative flight to get them to their destination. As a result, the family had to arrange and pay for an alternative flight themselves, at a significantly higher cost than the original fare, to complete their journey.

Ranju Aery filed a consumer complaint seeking a refund of the original fare of Rs. 20,000, along with 12% interest, reimbursement of the additional Rs. 80,885 spent on the alternative flight, Rs. 1.5 lakh as compensation for the mental harassment caused, and Rs. 22,000 towards litigation costs. The District Consumer Disputes Redressal Forum ruled in her favour, and the U.T. State Consumer Disputes Redressal Commission, Chandigarh, upheld that order on appeal. SpiceJet then filed a revision petition before the National Consumer Disputes Redressal Commission (NCDRC) under Section 21(b) of the Consumer Protection Act, 1986, challenging the concurrent findings of the two forums below.

Issues Raised

1. Did SpiceJet's cancellation of the connecting flight, without a refund or an alternative flight, amount to a deficiency in service under the Consumer Protection Act?
2. Was the complainant entitled to reimbursement of the additional cost incurred in booking a replacement flight, and to compensation for the harassment caused, in addition to a refund of the original fare?
3. Given that two forums below had already ruled concurrently in the complainant's favour, was there any legal basis for the National Commission to interfere in its limited revisional jurisdiction?

Arguments Contended

On behalf of SpiceJet (Petitioner): SpiceJet challenged the concurrent orders of the District Forum and the State Commission, contesting its liability for the full quantum of compensation awarded, including the reimbursement of the higher-cost alternative flight and the compensation for mental harassment, in a revision petition to the National Commission.

On behalf of Ranju Aery (Respondent): It was argued that the airline had simply cancelled the connecting flight and left the family to fend for themselves, without a refund or any alternative arrangement, forcing them to book a much more expensive replacement flight at short notice to complete a journey they had already paid for — a clear failure to provide the service paid for, and a deficiency in service under the Act, entitling her to full reimbursement of her losses and compensation for the harassment this caused her family.

Court's Reasoning

The National Consumer Disputes Redressal Commission examined the concurrent findings of fact and law reached by both the District Forum and the State Commission below, both of which had found SpiceJet liable for deficiency in service in cancelling the flight without providing a refund or an alternative, forcing the complainant to bear the additional cost of a replacement flight at a much higher fare. The Commission found no error, illegality, or jurisdictional defect in the concurrent findings of the two forums below that would justify interference in its limited revisional jurisdiction under Section 21(b) of the Act, which does not permit the National Commission to reappreciate evidence afresh as if hearing a first appeal, but only to correct jurisdictional errors or material illegality.

Judgement

The National Consumer Disputes Redressal Commission dismissed SpiceJet's revision petition, upholding the concurrent orders of the District Forum and the State Commission that had held the airline liable for deficiency in service and directed it to reimburse the complainant's losses and pay compensation.

Legal Principle / Ratio

An airline that cancels a booked flight without providing either a refund of the fare paid or a reasonable alternative arrangement to complete the passenger's journey commits a deficiency in service under the Consumer Protection Act, and is liable to reimburse the passenger's resulting additional expenses and to pay compensation for the harassment caused. In its revisional jurisdiction under Section 21(b), the National Commission will not ordinarily disturb concurrent findings of fact reached by the District Forum and State Commission below, absent jurisdictional error or material illegality.

Significance

SpiceJet Ltd. v. Ranju Aery is a routinely cited illustration of how Indian consumer forums apply the deficiency-in-service framework to air travel — a sector that generates a large volume of consumer complaints over cancellations, delays, and refunds. It reinforces that airlines cannot simply cancel a booked flight and leave passengers to independently arrange and fund a costly replacement without consequence, and it illustrates the limited scope of the National Commission's revisional jurisdiction, which respects concurrent factual findings of the forums below rather than re-litigating them.

Exam-Important Points

• Facts in one line: SpiceJet cancelled a connecting flight without a refund or alternative; the family paid nearly four times the original fare to book a replacement.
• Holding: cancelling a flight without a refund or alternative arrangement is a deficiency in service — the airline was liable to reimburse costs and pay compensation.
• Procedural point: the National Commission's revisional jurisdiction under Section 21(b) is limited — it does not re-examine evidence like a first appeal, only correcting jurisdictional error or material illegality, and here found none in the concurrent findings below.
• Amounts claimed: refund of Rs. 20,000 fare, reimbursement of Rs. 80,885 for the replacement flight, Rs. 1.5 lakh for mental harassment, Rs. 22,000 litigation costs.
• Often paired with Om Prakash v. Reliance General Insurance Co. Ltd. (2017) as illustrations of deficiency-in-service claims under the Consumer Protection Act.

Facts and citation verified against IndianKanoon's report of the judgment.