The National Consumer Disputes Redressal Commission critcized the District Consumer Redressal Commission Jaipur, (DCRC) for issuing bailable warrants as well as other orders against Salman Khan, over an alleged misleading advertisement by Rajshree Pan Masala starring the actor, without making a "minimum effort" to explore distinction of a misleading ad from shadow marketing.

The commission said that the district forum had passed order as if the appellant (Khan) and the company (Rajshree) had already committed a violation or a breach without a trial having proceeded.

For context, on April 8 the NCDRC had kept in abeyance bailable arrest warrants issued by district forum against the actor. The actor is the brand ambassador of 'Silver Coated Elaichi' a product of Rajshree Pan Masala. Respondent no. 1, a practicing advocate in Jaipur filed a consumer complaint with the District Forum alleging that the advertisement for the product was misleading and sought a ban on the running of the advertisement as well as a penalty.

It was alleged that the ad was being misused for the promotion of a pan masala product by introducing the caption saffron infused product and it was alleged that the product is injurious to health.

Though the matter was listed on January 15, however it was taken up on January 6 and an interim order was passed by the district commission directing the company and the actor from engaging in any misleading publicity until a response to the complaint is filed and the matter was listed on February 6.

A division bench of President Justice AP Sahi and member Mr. BharatKumar Pandya said that the procedure adopted by the District Commission, Jaipur in passing orders one after the other on 15.01.2026 and then the subsequent orders dated 09.02.2026, 23.03.2026 and 24.03.2026 raise vital issues of exercise of judicious discretion and of orderly procedure in compliance with the principles of natural justice.

The commission said that the reason why it had entertained the present plea was to ascertain the manner of functioning of the District Commission in the present case in the context of the nature of the orders passed by it.

"It is evident that the interim order dated 06.01.2026 was ex-parte and had been passed on M.A. No. 114/2025, a copy Whereof is stated to have not been served on the appellant. The appellant was not aware of the passing of the interim order dated 06.01.2026 on the said application till 15.01.2026

Strangely enough, on 15.01.2026, a couple of more orders were passed simultaneously as mentioned above. These orders were passed on two applications. One was an application for proceeding under Section 72 of the Act. This application was filed on the same day i.e. 15.01.2026 and without giving any opportunity to the appellant, who had already put in appearance through his counsel, the order issuing Bailable Warrants were passed against the appellant. The second application moved was for appointment of a Court Commissioner to verify the genuineness of the signatures of the appellant and the said application was also allowed on the same day".

The commission said that the actor appellant and the company both challenged the district forums order dated 06.01.2026 before the State Commission, which had passed an interim order on 06.02.2026 directing the District Commission not to issue any arrest warrants and also directed the District Commission to decide the application filed by the appellant under Order 7 Rule 11 as early as possible.

It however noted that instead the district commission on 23.03.2026 passed an order for constituting a Special Task Force with a direction to the Commissioner I Deputy Commissioner of Police, Jaipur, in order to ensure service of Bailable Warrants on the appellant

"Prima facie these were orders passed in the background as if the appellant and the respondent no. 2 had already committed a violation or a breach and the interim order dated 06.01.2026 had e attained finality without there being evidence led or the trial having proceeded by production of any evidence treating the order dated 06.01.2026 to be sacrosanct and final," the court said.

The commission said that interim order had been passed ex-parte and the District Commission proceeded attaching finality to the same without the trial having been proceeded and the evidence have been led.It also found that the State Commission in spite of making observations in the order proceeded to confirm the interim order dated 06.01.2026.

The NCDRC said that from the material on record prima facie, in its interim order passed on 06.01.2026 by the District Commission it has assumed that the advertisement is misleading as it relates to Rajshree "Pan" Masala which is a tobacco product and its contents are harmful for the health of public at large that may lead to affliction of serious diseases like cancer.

"The said order on a prima facie basis has finally assumed and adverse impact of the advertisement which the appellant and the respondent e no. 2 have clearly stated is with regard to Silver coated cardamom flavoured with saffron and in no way is a tobacco product. The advertisement itself says that it does not contain tobacco or nicotine. The District Commission does not seem to have attempted to mention it in its order dated 06.01.2026 much less analysing it or expressing any prima facie opinion of the said factual aspect.

The District Commission did not even make the minimum effort to explore the distinction of a misleading advertisement or shadow marketing and in effect arrived at an abrupt conclusion that the product was meant to promote and advertise some tobacco produce. There is a complete absence of even a prima facie assessment about the product and the same appears to be lacking in the order of the State Commission as well," the commission said.

It said that there was a complete absence of even a prima facie assessment about the product and the same appears to be lacking in the order of the State Commission as well.

The commission however said noted two Writ Petitions have already been filed including one by the actor against orders of the district and state commissions.

For context, the high court had on April 7, stayed proceedings pending against actor before the District Consumer Disputes Redressal Commission Jaipur II, over an alleged misleading advertisement.

The NCDRC said that since the high court had stayed the operation of the order of district forum and the State Commission dated 16.03.2026–whereby the State Commission had declined to interfere with DCDRC's order dated January 15 issuing warrants against the actor–"it would be appropriate for the appellant to avail of the said remedy before the High Court instead of pursuing the present appeal at this stage".

The commission disposed of the actor's plea with a direction to the DCDRC, Jaipur-II to await orders to be passed by the Rajasthan High Court in the Writ Petitions.

Case title: Salman Salim Khan v/s Yogendra Singh Badiyal & Ors.

Dy No. 7520/NCDRC/2026

Senior advocate Ravi Prakash, along with advocates Parag Khandhar, Chandrima Mitra, Tapan Redkar, Yatharth Shukla, Sarthak Sehgal appeared for the actor.

Advocate Indra Mohan Singh appeared for Yogendra Singh Badiyal

Advocates Varun Singh, Shikhar Upadhyay, Utkarsh Sahu and Prerna Priya appeared for respondent no. 2.

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