Facts: The appellant, an advocate, was retained by the respondent, Mr. D.K. Gandhi, to file a complaint under Section 138 of the Negotiable Instruments Act for a dishonored cheque. The respondent alleged that the appellant received a DD/pay order of ₹20,000/- and a crossed cheque of ₹5,000/- from the accused but failed to deliver the cheque and demanded ₹5,000/- in cash instead. The appellant subsequently filed a suit for recovery of ₹5,000/- as fees. The respondent filed a complaint with the District Consumer Disputes Redressal Forum, seeking compensation for mental agony and harassment.

Issue: Whether a complaint alleging "deficiency in service" against advocates practicing legal professions is maintainable under the Consumer Protection Act, 1986, as re-enacted in 2019.

Observation: The Supreme Court examined whether the District Consumer Forum had jurisdiction over disputes involving advocates. The District Forum initially rejected the jurisdictional objection, but the State Commission held that services of advocates did not fall under "service" as defined by Section 2(1)(o) of the CP Act, 1986. The NCDRC later ruled in favour of the respondent, affirming the District Forum's decision on jurisdiction and merits.