My Lord, Clarificatory Amendments – Retrospective Effect?
“An Explanation was added by The Consumer Protection (Amendment) Act, 1993 to the definition of the expression ‘consumer’ under Section 2(1)(d) of The Consumer Protection Act, 1986. In Laxmi Engineering Works, (1995) 3 SCC 583 the consumer complaint in question was filed before adding of the said Explanation. The SC ruled that the Explanation was clarificatory in nature and applied to all pending proceedings. It merely made explicit what was implicit in the Act. It was not as if the law was changed by the said Explanation; it had been merely made clearer.”
– Hon’ble Justice Dipak Misra, Bunga Daniel Babu v. Vasudeva Constructions, [Civil Appeal No. 944 of 2016].