Consumer court limitation: two years from when, exactly?
The two years is easy. Deciding the date they run from is the whole of the difficulty — and it is not the date on the invoice.
Free · No signup · Section 69 checked 11 September 2026
Two years from when, exactly?
The two years is the easy half. Deciding which date they run from is the whole of the difficulty — so pick your situation and the tool will name the date before you enter it.
Not the date you decided to do something about it, and not the date of your last email to them.
Two years from the date the cause of action arose — s. 69(1) of the Consumer Protection Act, 2019. Not two years from when you decided to act, and not from your last email to the company. A commission may entertain a later complaint under s. 69(2) if you satisfy it that there was sufficient cause for the delay, but it has to record its reasons, and it is not something to plan around.
Key takeaways
- The clock starts at the cause of action, which is almost never the date of purchase.
- Chasing a company does not buy time. Eighteen months of polite follow-up leaves you with six months, not twenty-four.
- The commission has to apply the two years on its own motion. The other side staying silent about it is no protection at all.
- Where the failure is still going on — possession never given, a service still failing — it may be a continuing wrong, and a fresh cause of action can arise from day to day.
- This tool counts two years from a date you supply. Choosing that date is the legal question, and a wrong start date produces a confidently wrong deadline.
Which date the clock starts on
The worked dates all assume the same underlying transaction — a purchase made on 12 January 2024 — so the rows can be compared against each other rather than each against a different calendar.
- A one-time failure — the refund was refused
- Clock starts
- The date of the refusal
- Worked date
- Refused 3 Mar 2024 → file by 3 Mar 2026
Not the purchase on 12 Jan 2024. Asking again later does not create a fresh refusal.
- The goods were defective when they arrived
- Clock starts
- The date of delivery
- Worked date
- Delivered 20 Jan 2024 → file by 20 Jan 2026
The deficiency existed and was apparent on delivery.
- A latent defect appeared months later
- Clock starts
- When it appeared, or could reasonably have been discovered
- Worked date
- Appeared 9 Jan 2025 → file by 9 Jan 2027
The onus of showing it was not discoverable earlier is on the complainant.
- An insurance or warranty claim was rejected
- Clock starts
- The date of the written rejection
- Worked date
- Rejected 14 Jun 2024 → file by 14 Jun 2026
A later rejection of a review of the same claim is usually not a fresh cause of action.
- Possession was never given, and still has not been
- Clock starts
- The promised date — but the wrong continues
- Worked date
- Promised 30 Sep 2024 → 30 Sep 2026, and arguably later
A continuing wrong under s. 23 of the Limitation Act can give a fresh cause of action from day to day. Plead it; do not assume it.
| Your situation | The clock starts on | Worked date |
|---|---|---|
| A one-time failure — the refund was refused | The date of the refusalNot the purchase on 12 Jan 2024. Asking again later does not create a fresh refusal. | Refused 3 Mar 2024 → file by 3 Mar 2026 |
| The goods were defective when they arrived | The date of deliveryThe deficiency existed and was apparent on delivery. | Delivered 20 Jan 2024 → file by 20 Jan 2026 |
| A latent defect appeared months later | When it appeared, or could reasonably have been discoveredThe onus of showing it was not discoverable earlier is on the complainant. | Appeared 9 Jan 2025 → file by 9 Jan 2027 |
| An insurance or warranty claim was rejected | The date of the written rejectionA later rejection of a review of the same claim is usually not a fresh cause of action. | Rejected 14 Jun 2024 → file by 14 Jun 2026 |
| Possession was never given, and still has not been | The promised date — but the wrong continuesA continuing wrong under s. 23 of the Limitation Act can give a fresh cause of action from day to day. Plead it; do not assume it. | Promised 30 Sep 2024 → 30 Sep 2026, and arguably later |
Five situations, five different start dates, and a spread of nearly two years between the earliest and the latest. This is why the date matters more than the arithmetic.
s. 69(1), Consumer Protection Act, 2019, read with s. 23 of the Limitation Act, 1963 for the continuing-wrong rows. Checked 11 September 2026. These are the ordinary versions of each situation; your facts may not be the ordinary version.
When the cause of action actually arises
Section 69(1) is short: a commission "shall not admit a complaint unless it is filed within two years from the date on which the cause of action has arisen". Everything difficult about limitation in consumer matters sits in the last six words.
The cause of action is the moment the wrong was complete — the point at which you could have walked into a commission and asked for relief. That is not the purchase, because buying something is not a wrong. It is usually the failure: the defect appearing, the service not being delivered, the refund being refused, the claim being rejected. Most people date it from the transaction and lose months they still had.
The table on this page maps the situations people arrive with to the date the clock runs from, with a worked date on each so the rule is shown rather than asserted. Where your facts do not fit any row cleanly, that is worth knowing: a contested start date is something to plead deliberately, with the reasoning on the face of the complaint, rather than to pick and hope.
What does not restart the clock
This is the expensive misunderstanding, and it is expensive because the behaviour that causes it is entirely reasonable. You complained. They said they were looking into it. You followed up. They asked for the invoice again. You sent it. A year and a half went by, and none of it moved the date the cause of action arose.
- Follow-up emails, calls and chat transcripts. However many there are, they are evidence of the wrong, not a new one.
- The company’s assurances that it is "being escalated". A promise to look at something is not an admission that restarts anything.
- A grievance filed with the company’s grievance officer, or with a sector regulator, or with the National Consumer Helpline. These are worth doing and they run in parallel — but the two years keep running while they do.
- Your own illness, absence or ignorance of the deadline. Those go to condonation under s. 69(2), if anywhere. They do not change when the cause of action arose.
- A part payment or a written acknowledgement of the debt. Sections 18 and 19 of the Limitation Act, 1963 extend time on a money claim in a civil suit on that basis. Section 69 is worded differently and does not incorporate them.
Filing. A complaint filed in time can be settled, withdrawn or mediated afterwards and you have lost nothing. A complaint not filed in time may never be heard. If you are inside the last few months while the company is still "looking into it", file and let them settle it after.
Nobody has to raise it for you to lose on it
Section 69(1) does not say a complaint filed late is defensible. It says the commission "shall not admit" it. That wording is a direction to the commission, not a defence handed to the opposite party, and the Supreme Court read the identical words in s. 24A of the 1986 Act exactly that way in State Bank of India v. B.S. Agricultural Industries: the expression is a legislative command to the forum to examine on its own whether the complaint is within time.
Three things follow, and none of them is obvious from reading the section alone. The commission must look at limitation whether or not anybody pleads it. The other side saying nothing about your delay is worth nothing to you. And a complaint decided on the merits when it was out of time is an illegality that can be set aside on appeal — so a favourable order on a time-barred complaint is not safe, and a company with an appeal available knows that.
The practical consequence is that limitation is not a risk you can take quietly. If your complaint is late, the right move is to say so and apply under s. 69(2), not to hope nobody notices.
Condonation under s. 69(2), and what it actually requires
Section 69(2) allows a commission to entertain a complaint filed after two years where the complainant satisfies it that there was sufficient cause for not filing within the period — and adds a proviso that no such complaint shall be entertained unless the commission records its reasons for condoning the delay. Both halves matter. It is discretionary, and it is reasoned.
So condonation is an application, made with the complaint, explaining the delay and supported by something. It has to cover the whole of the period of delay rather than part of it: an illness that explains three months of an eleven-month delay leaves eight unexplained. And it is decided before the complaint is admitted, so it is the first thing that happens rather than a point taken later.
| The reason | How far it goes |
|---|---|
| Serious illness or hospitalisation of the complainant, with records covering the period. | The strongest kind of reason, because it is verifiable and it explains a specific stretch of time. |
| A death in the immediate family. | Generally accepted for a proportionate period. It does not cover two years. |
| A previously instructed advocate’s genuine mistake, evidenced. | Argued regularly, and it succeeds more readily where the complainant acted promptly on discovering it. |
| Time spent bona fide before a body that could not grant the relief. | Arguable, and it works best where the choice was reasonable and the move was prompt. Nothing in s. 69 excludes that time automatically. |
| Waiting for the company to respond, or continuing to negotiate. | Weak on its own. The whole premise of the two years is that you are expected to file rather than wait. |
| Not having known about the two-year limit. | Not a reason. Ignorance of a limitation period is not sufficient cause. |
None of this is a tariff. Sufficient cause is decided on the facts by the commission hearing it, and the same reason can succeed in one case and fail in another. Plan on the two years; treat s. 69(2) as a rescue.
What this tool models, and what it refuses to
It adds two years to a date you give it and reports the result. That is the entire computation, and it was never the hard part.
The hard part is the date, and the tool cannot supply it. It asks what happened and tells you which date that situation usually runs from, which is genuinely useful — but "usually" is doing real work in that sentence. Whether a defect was latent, whether a refusal was final, whether a failure is continuing, and whether your facts are the ordinary version of the situation you picked are all questions of fact, and the answer decides the deadline. A confident date computed from the wrong starting point is worse than no date, because you will act on it.
It also has nothing to say about whether you should file, where, or what it costs. Those have their own pages and are linked below.
Worked examples
Example 1: A refund refused, then chased for eighteen months
- Paid
- 12 January 2024
- Refund refused in writing
- 3 March 2024
- Follow-up emails
- Regularly, to September 2025
- 1.The cause of action arose on 3 March 2024, the date of the refusal. Not 12 January 2024, because buying something is not a wrong.
- 2.Two years from 3 March 2024 is 3 March 2026.
- 3.The eighteen months of follow-up changed nothing about that date. They are useful evidence of the refusal and of the company’s conduct, and they bought no time at all.
- 4.By September 2025 there were about six months left — and a reader who had assumed the clock restarted with each reply would have believed there were twenty-four.
Deadline 3 March 2026. The correspondence is worth having in the complaint and worth nothing in the limitation calculation.
Example 2: A defect that appeared eight months after delivery
- Delivered
- 5 May 2024
- Defect appeared
- 9 January 2025
- Question
- Which date starts the two years?
- 1.If the defect was apparent on delivery, the cause of action arose on 5 May 2024 and the deadline is 5 May 2026.
- 2.If it was genuinely latent — not discoverable on reasonable inspection — the cause of action arises when it manifested, on 9 January 2025, and the deadline is 9 January 2027.
- 3.Which of those applies is a question of fact, and the onus of establishing that the defect was latent is on the complainant.
- 4.The safe course is to work to the earlier date wherever it is still open, and to plead the later one with the reasons for it if the earlier date has gone.
Either 5 May 2026 or 9 January 2027, and the difference is twenty months. This is exactly the case where the tool computes correctly from whichever date you give it and cannot tell you which one is right.
More questions about this page
Is the consumer court time limit two years from purchase?▼
Does complaining to the company extend the two years?▼
What if the opposite party never raises the delay?▼
Can a consumer complaint be filed after two years?▼
My builder still has not given possession. Has my time run out?▼
What counts as sufficient cause for delay?▼
What if the last day is a holiday?▼
Official sources checked
The statutes, rules and regulator pages the statements on this page were checked against.
- Two years from the date the cause of action arose. Delay may be condoned under s. 69(2) on sufficient cause, but only where the commission records its reasons.
- State Bank of India v. B.S. Agricultural Industries (I), (2009) 5 SCC 121"Shall not admit a complaint" is a legislative command to the consumer forum to examine limitation on its own. The duty arises whether or not the opposite party pleads it, and deciding a time-barred complaint on merits is an illegality.
- Samruddhi Co-operative Housing Society Ltd. v. Mumbai Mahalaxmi Construction Pvt. Ltd., 2022 INSC 33A developer’s continuing failure to obtain the occupancy certificate is a continuing wrong under s. 23 of the Limitation Act, 1963, so a fresh cause of action arises from day to day.
- Three years for a money claim, and how a written acknowledgement or part payment restarts it.
- The consumer commission filing portal since 1 January 2025, when it absorbed eDaakhil, OCMS, CONFONET and the NCDRC case management system.
You are here
You know your deadline
What to do next
- 1
Work out which commission, and what it costs
Decided by what you paid, not what you are claiming — and filing in the wrong one means starting again with less time left than you had.
Fee and jurisdiction estimator → - 2
Draft the complaint
It has a shape a commission expects, and most self-filed complaints are returned on formatting rather than on the merits.
Consumer complaint format → - 3
File it
A complaint filed in time can be settled, mediated or withdrawn afterwards. One filed late may never be heard.
How to file, step by step →
Not legal advice. GetNyay is not a law firm and does not practise law. Section 69 was checked on 11 September 2026 and is cited in the sources above. Which date your cause of action arose on, whether a defect was latent, and whether a failure is a continuing wrong are questions of fact for an advocate on your own papers — and they decide the deadline, which this tool only counts from. All free tools.