Section 230 of The Indian Contract Act, 1872 categorically makes it clear that an agent is not liable for the acts of a disclosed principal subject to a contract of the contrary. In Marine Contained Services South Pvt. Ltd. v. Go Go Garments, (1998) 3 SCC 247 the SC held that the defence under Section 230 is available in cases under The Consumer Protection Act, 1986 to the agents of the principal with whom the complainant had an agreement.
Also see, Virender Khullar v. American Consolidation Services Ltd., [Civil Appeal No. 4861 of 2012] decided on 16.08.2016.