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A member of Employees' provident fund scheme is a 'consumer' and delay in settlement of provident fund claim would amount to deficiency in services, and the provision of the Consumer Protection Act can be invoked against the provident fund commissioner by a member of the employees' provident fund scheme. The Supreme Court observed that the P.F scheme is a 'service' and the administrative charges to be paid under the scheme show that the scheme is for consideration.
[Trustee, Birla Jute & Industries Ltd. V Bhabatosh Mukherjee, 1999 (III CPJ 36 (SC) -- Relied in 2004 (III) CPJ 382]


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