The order was passed by a Bench comprising Chief Commissioner Nidhi Khare and Commissioner Anupam Mishra in a suo motu proceeding initiated against the institute over promotional claims made on its official website following the declaration of the UPSC CSE 2023 results.

The CCPA examined three principal claims made by the institute:

1. "8 Rank Holders in the Top 10 are from Vajiram & Ravi";
2. "Every year, more than 30% of the officers selected through UPSC Civil Services Examination are students of Vajiram & Ravi"; and
3. "37 Rank Holders in the Top 50 are from Vajiram & Ravi."

According to the Authority, these claims were displayed alongside advertisements for the institute's paid courses without disclosing the specific course actually attended by the successful candidates, thereby creating the impression that the toppers had undergone the institute's comprehensive coaching programmes. The Authority held that such omission amounted to concealment of material information and misled prospective UPSC aspirants.

During the proceedings, Vajiram & Ravi submitted that it had provided details of 413 successful UPSC CSE 2023 candidates associated with the institute. However, the CCPA found that 258 of these candidates had enrolled only in the Interview Guidance Programme, a short-duration programme offered after candidates had independently cleared the Preliminary and Main examinations. The Authority observed that projecting such candidates as products of the institute's broader coaching programmes while simultaneously advertising full-fledged paid courses was misleading.

The investigation further revealed that seven of the eight Top-10 rank holders claimed by the institute had enrolled only for the Interview Guidance Programme, while the remaining candidates had enrolled in optional subject coaching or test series rather than the advertised comprehensive courses. Likewise, among the 37 Top-50 rank holders, a substantial number had only participated in the Interview Guidance Programme.

Rejecting the institute's defence that any person enrolling in any course at any stage of the examination process could be described as its student, the CCPA held that the decisive question was whether consumers were informed about the nature and extent of the coaching actually received. It observed that non-disclosure of course-specific information deprived aspirants of material information necessary to make informed decisions.

The Authority also rejected Vajiram & Ravi's argument that UPSC aspirants are educated and discerning consumers capable of seeking further clarification. It held that consumer protection obligations rest on service providers and cannot be diluted merely because the target audience is well-informed. Referring to the evolution of consumer jurisprudence, the CCPA observed that the doctrine of "Caveat Emptor" (let the buyer beware) has increasingly given way to "Caveat Venditor" (let the seller beware), placing a greater obligation on service providers to ensure truthful and complete disclosures.

The Authority concluded that the advertisements violated the Consumer Protection Act, 2019 as well as the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022, by concealing material information and exaggerating the institute's achievements.

Accordingly, the CCPA imposed a penalty of ₹7 lakh on Vajiram & Ravi IAS Study Centre LLP under the Consumer Protection Act and directed the institute to discontinue such misleading advertisements and refrain from making similar claims in the future.

Case No.: CCPA-2/24/2024-CCPA.

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