Exploring Remedies for Insurance Disputes: Understanding the Legal Remedies  



Exploring Remedies for Insurance Disputes: Understanding the  Legal Remedies


Insurance disputes arise when there is a disagreement between the insured and the insurer regarding policy terms, claims, or coverage. To address these disputes, several legal remedies are available, designed to protect the interests of policyholders and ensure fair treatment by insurance companies. One primary legal remedy is filing a lawsuit. Policyholders can sue their insurer for breach of contract if the insurer denies a legitimate claim or fails to fulfill its policy obligations. Courts can award damages to compensate for the loss incurred due to the breach. In some jurisdictions, policyholders may also claim punitive damages if the insurer’s conduct is found to be particularly egregious. Another common remedy is arbitration. Many insurance policies include arbitration clauses that require disputes to be resolved through arbitration rather than litigation. Arbitration is typically faster and less formal than court proceedings, and the arbitrator’s decision is binding and enforceable. Mediation is a less adversarial alternative where a neutral third party helps both sides negotiate a mutually acceptable resolution. While mediation is not binding, it often leads to a quicker and less costly settlement. Administrative remedies are also available through state insurance departments or regulatory agencies. Policyholders can file complaints against insurers with these agencies, which can investigate and, if necessary, impose penalties or require corrective actions against the insurer. In addition, some jurisdictions provide for statutory remedies, such as the right to attorney’s fees, interest on delayed payments, or additional damages under consumer protection laws. These remedies incentivize insurers to handle claims promptly and fairly. Policyholders should also consider the possibility of class action lawsuits when numerous individuals face similar disputes with an insurer. This can be an effective way to address widespread issues and achieve collective redress. the legal remedies for insurance disputes include litigation, arbitration, mediation, administrative complaints, and statutory protections. These mechanisms aim to ensure that policyholders receive the benefits they are entitled to and that insurance companies adhere to fair practices.


Insurance Disputes, Legal Remedies, Claim Denial, Breach of Contract, Bad Faith, Arbitration, Mediation, Litigation, Insurance Claim Appeal, Policyholder Rights, Declaratory Judgment, Consumer Protection Laws, Regulatory Complaint Punitive Damages, Compensatory Damages, Reformation, Rescission, Insurance Fraud, Coverage Dispute, Settlement Negotiation, Class Action Lawsuit, Policy Interpretation, Subrogation, Equitable Relief, Dispute Resolution, Clause Notice of Loss, Proof of Loss, Legal Counsel, Insurance Commissioner, State Insurance Department.



In India, insurance is provided in the form of an indemnity agreement between the insurance company and the client. The majority of insurance disputes are often civil, but they can sometimes be criminal in nature because they Centre on a contractual term and how it should be interpreted, as well as the coverage’s extent. Insurance may be effectively viewed as a social tool that functions with other social structures to diminish the financial risk that might result from the loss of life or property. It is a tool that aggregates enough exposure units so that the sum of their individual losses may be predicted. In order to guarantee the recovery of a significant unpredictable financial loss which may happen to him owing to the occurrence of some specified uncertain event, the insured person willingly agrees to incur a little financial loss i.e. the regular payment of the premium amount. Today, this action is seen as a crucial component of a person’s effort toward prudent fiscal planning and risk mitigation. In India, the rate of insurance penetration is among the world’s lowest, and almost 80% of the population lacks life insurance. There are 57 insurance companies in the Indian insurance market; 24 are engaged in the life insurance sector, and 34 are non-life insurance companies. LIC is the only company in the public sector that provides life insurance. In the non-life insurance business, there have been 6 public sector insurers. In addition to these, General Insurance Corporation of India is the only national reinsurer (GIC Re). Agents (corporate and individual), brokers, surveyors, and third-party administrators handling health insurance claims are other market participants in India. The size of the insurance market in India is enormous, and it is expanding at a speed of 15-20 per cent every year. The Insurance Act of 1938, as revised from time to time, and the Insurance Regulatory and Development Authority Act of 1999, which created IRDA, the statutory supervisor of the market, are the main laws that govern the insurance industry. An important turning point in India’s history of insurance regulations was the creation of the IRDA. The purpose of this Act is to both guarantee the interests of the insured as stated in its preamble and to encourage the industry’s orderly growth. In fact, these two pieces of legislation have established the legal framework under which the insurance sector must operate going forward. Other organizations and self-regulatory bodies play important roles in the implementation of this fundamental legislative framework, in addition to IRDA.

Insurance Litigation Process in India

India does not use the jury system. The judge decides on all claims, and the norms of pleading and evidence are fairly similar to those used in other countries. Most insurance plans have provisions addressing venue and the contract governing law. The clause which specifies the courts that will have the authority to resolve any disagreements that might develop with the policy. However, since parties cannot exclude the jurisdiction of a court with territorial jurisdiction and grant the same to a court without it, any court with territorial jurisdiction generally can hear a case. The details regarding the policy’s or contract’s relevant and governing law are provided in the governing law clause***. Foreign law cannot be chosen as the policies governing legislation by two Indian parties. Indian courts can resolve any argument relating to how to interpret the jurisdiction and controlling law provision. Section 44-A of CPC 1908, when read in conjunction with Section 13, governs the acceptance and enforcement of foreign judgements and decrees in India. In the case of “reciprocating territories” or other territories, a foreign judgment that is conclusive under Section 13 of the Code may be implemented by instating execution proceedings under Section 44-A read with Order XXI of the CPC, 1908, or by instituting a civil suit on the judgment. If the insurance does not contain a jurisdiction clause, the issue may be decided by any court to whom jurisdiction has been granted in accordance with the Code of Civil Procedure, 1908. The civil court or consumer court in which the problem is determined relies upon the cost of the dispute and the geographical regulations of the defendant’s coverage company’s office, in which the reason of motion for the dispute arose. Both civil courts and consumer forums have territorial and pecuniary jurisdiction.

Legal Remedies Available in Case of Insurance Disputes

Insurance disputes can arise for a variety of reasons, including claim denials, delayed payments, underpayments, and policy cancellations. When such disputes occur, policyholders have several legal remedies at their disposal. This article outlines the primary legal avenues available to individuals and businesses facing insurance disputes:

  1. Reviewing the Insurance Policy

Before taking any legal action, policyholders should thoroughly review their insurance policy. Understanding the terms, conditions, and exclusions is crucial, as these documents serve as the foundation for resolving disputes. In many cases, disputes arise from misunderstandings or misinterpretations of policy language.

  1. Internal Appeals Process

Most insurance companies have an internal appeals process designed to resolve disputes without litigation. Policyholders should take advantage of this process by submitting a formal appeal to the insurer, including all relevant documentation and evidence supporting their claim. This step is often a prerequisite before pursuing external legal remedies.

  1. State Insurance Department Complaints

If the internal appeals process does not yield a satisfactory result, policyholders can file a complaint with their state’s insurance department. State insurance regulators oversee insurance companies and enforce compliance with state laws and regulations. They can investigate complaints, mediate disputes, and sometimes even impose penalties on insurers for unfair practices.

  1. Alternative Dispute Resolution (ADR)

Alternative Dispute Resolution methods, such as mediation and arbitration, offer a less formal and often quicker way to resolve insurance disputes compared to court litigation.

  1. Mediation: This involves a neutral third-party mediator who facilitates negotiations between the policyholder and the insurer to reach a mutually acceptable resolution. Mediation is non-binding, meaning either party can still pursue litigation if the mediation fails.
  1. Arbitration: In arbitration, a neutral arbitrator hears evidence and arguments from both sides and then makes a binding decision. Arbitration can be quicker and less expensive than court proceedings, but the parties typically must abide by the arbitrator’s decision.
  2. Litigation

When all other avenues fail, policyholders may file a lawsuit against their insurance company. Litigation is often the last resort due to its time-consuming and costly nature. However, it can be necessary for resolving complex disputes or when significant amounts of money are involved.

  1. Breach of Contract: The most common legal basis for an insurance dispute lawsuit is breach of contract. The policyholder must prove that the insurer failed to fulfill its obligations under the policy terms.
  2. Bad Faith Claims: If an insurer’s actions are particularly egregious, policyholders can sue for bad faith. Bad faith claims arise when insurers deny benefits without a reasonable basis, fail to investigate claims properly, or unreasonably delay payments. Successful bad faith claims can result in the policyholder receiving compensation beyond the original claim amount, including punitive damages.
  3. Declaratory Judgment: In some cases, policyholders seek a declaratory judgment from the court to interpret the insurance policy’s terms. This can clarify the rights and obligations of both parties without waiting for an actual breach to occur.
  4. Class Action Lawsuits

In situations where multiple policyholders are affected by similar issues with an insurer, a class action lawsuit may be appropriate. Class actions can be an efficient way for individuals with smaller claims to pool resources and challenge large insurance companies. Successful class actions can lead to significant settlements or changes in the insurer’s practices.

  1. Seeking Assistance from Insurance Attorneys

Navigating insurance disputes can be complex, and legal representation can be invaluable. Insurance attorneys specialize in these types of disputes and can offer expert advice, negotiate with insurers, and represent policyholders in court if necessary.

Limitation Period for Filing an Insurance Claim:

The way of evaluating the limitation period for insurance claims is given under Article 44(b) of the Limitation Act 1963, which expresses that time is to be determined from ‘the date of the event causing the misfortune, or where the case on the arrangement is denied either part of the way or completely, the date of such rebuttal’. The recommended limitation period for filing a case in the civil court or mediation is three years, while the limited time frame for documenting a case in the consumer court is two years.

Judicial Interpretation

  1. Janina Construction Company v. The Oriental Insurance Company Limited and Ors. I (2022) CPJ119(SC)

Policy type- Motor Insurance Policy

The insurer repudiated the insured’s claim in toto on the ground that there was a delay in informing the insurance company regarding the theft of the vehicle. The condition in question mandated the insured to give immediate notice to the insurer of the accidental loss/damage but was given by the insured after a lapse of 5 months from the loss. Relying on Gur Shinder Singh v. Shriram General Insurance Co. Ltd. and Anr. 2020 (11) SCC 612, the Supreme Court observed since the FIR was lodged immediately on the next day of the occurrence of theft of the vehicle by the insured and the vehicle could not be traced out, a delay of about five months in informing and lodging the claim with the insurer would not be fatal. The Court held that when the insurer has repudiated the claim only on the ground of delay, and the claim of the insured was not found to be not genuine, the insurer’s repudiation could not be sustained.

  1. Jacob Punnen and Ors. v. United India Insurance Co. Ltd. I (2022) CPJ87(SC)

Policy type- Medical Insurance Policy

The Supreme Court rejected the insurer’s argument that the consumer was under an obligation to inquire about the terms of the policy, and any changes that might have been introduced, in the standard terms. The state of the law as observed was that an insurer was under a duty to disclose any alteration in the terms of the contract of insurance, at the formation stage or as in this case, at the stage of renewal. The insurer cannot be heard to say that the insured was under an obligation to satisfy itself, if a new term had been introduced. In the facts of the case, the Court observed that medical or health insurance cover becomes crucial with advancing age; the policy holder is more likely to need cover; therefore, if there are freshly introduced limitations of liability, the insured may, if advised properly, and in a position to afford it, seek greater coverage, or seek a different kind of policy. Further, most policies – health and medical insurance policies being no exception, are in standard form. One who seeks coverage of a life policy/a personal risk, such as accident or health policy has little choice but to accept the offer of certain standard term contracts. Therefore, relying on the IRDA (Health Insurance) Regulations, 2016, the Court observed that it is the insurer’s obligation to inform every policy holder, about any important changes that would affect her or his choice of product.

3.Khatema Fibers Ltd. v. New India Assurance Company Ltd. and Ors. IV (2021) CPJ1(SC)

Policy type- Standard Fire and Special Perils

In the instant case, the Supreme Court observed that in cases where the insurance company admitted the insured’s claim, to the extent of the loss as assessed by the surveyor, the jurisdiction of the special forum constituted under the Consumer Protection Act, 1986 is limited. To establish deficiency, the insured should be able to establish, that the surveyor did not comply with the code of conduct in respect of his duties, responsibilities and other professional requirements as specified by the Regulations made under the Insurance Act, 1938. The Court finally held that a Consumer Forum which is primarily concerned with an allegation of deficiency in service cannot subject the surveyor’s report to forensic examination of its anatomy. Once it is found that there was no inadequacy in the quality, nature and manner of performance of the duties and responsibilities of the surveyor, in a manner prescribed by the Regulations as to their code of conduct and once it is found that the report is not based on ad hocism or vitiated by arbitrariness, then the jurisdiction of the Consumer Forum to go further would stop.

4.Reliance Life Insurance v. Rekhaben Nareshbhai Rathod – Supreme Court litigation.

This case was about a basic principle of insurance law: if the insured does not reveal important information when signing an insurance contract, the insurer can reject policy claims.


In the complex landscape of insurance, disputes are an unfortunate but inevitable reality. These disagreements can arise from various sources, including coverage denials, claim delays, disputes over policy interpretation, and disagreements regarding the extent of damages. When these conflicts emerge, policyholders often find themselves in a vulnerable position, grappling with financial strain, emotional stress, and uncertainty about their rights and recourse. Fortunately, the legal system provides avenues for resolution in the event of insurance disputes, offering a range of remedies designed to protect policyholders and ensure fair treatment. These remedies serve as crucial safeguards, balancing the interests of insurers and insured parties while upholding the principles of justice and accountability. One of the primary legal remedies available to policyholders facing insurance disputes is litigation. Through civil lawsuits, aggrieved parties can seek judicial intervention to enforce the terms of their insurance policies, challenge wrongful denials or delays, and pursue compensation for damages incurred. Litigation offers a formalized process for presenting evidence, arguing legal interpretations, and obtaining a binding resolution from a court of law. While litigation can be time-consuming, costly, and emotionally draining, it remains a potent tool for holding insurers accountable and securing just outcomes. Alternative dispute resolution mechanisms also play a Crucial role in resolving insurance disputes outside of traditional courtroom proceedings. Mediation, arbitration, and negotiation offer policyholders and insurers the opportunity to engage in constructive dialogue, facilitated by neutral third parties, with the goal of reaching mutually acceptable settlements. These approaches can offer advantages such as faster resolution times, reduced expenses, and greater flexibility in crafting creative solutions tailored to the specific circumstances of each case. The legal landscape offers a diverse array of remedies for policyholders grappling with insurance disputes. From litigation and alternative dispute resolution to regulatory oversight and contractual mechanisms, these remedies serve as essential safeguards, ensuring that insured parties have access to fair treatment, timely resolution, and meaningful recourse when conflicts arise. By understanding their rights and options under the law, policyholders can navigate insurance disputes with confidence, secure in the knowledge that the legal system stands ready to uphold their interests and enforce accountability within the insurance industry.

Written By: Hari Raghava JP


The Legal Heirs of A Deceased Partner are not held Liable for the Liability of Partnership Firm upon the Partner’s Demise : The Supreme Court

Case title: Annapurna B. Uppin & Ors. V. Malsiddappa & Anr.

Case no.: Arising Out Of SLP (C.) No.11757 Of 2022

Order on: 5th April 2024

Quorum: Justice Vikram Nath and Justice Satish Chandra Sharma


The case concerns the retrieval of an investment made by the complainant in a partnership firm from the legal heirs of the deceased partner, pursuant to the Consumer Protection Act of 1986. The complainant aimed to recover the investment from the appellants, who were the legal heirs of the deceased partner, arguing that they had inherited the estate of the deceased partner and therefore could not evade responsibility for fulfilling the payment owed to the complainant, who was respondent no.1.

The respondent, Malsiddappa, filed a complaint alleging that he had invested Rs. 5 Lakhs in the partnership firm M/s Annapurneshwari Cotton Co. on May 21, 2002, with a promised repayment after 120 months with interest at 18% per annum. Despite multiple requests for premature payment, the payment was denied. The complaint was filed before the District Consumer Disputes Redressal Forum (DCDRF) alleging deficiency in service.


The appellants, legal heirs of the deceased managing partner of the firm, argued that they were never part of the partnership and that the complaint was not maintainable under the Consumer Protection Act, 1986.

The present appeal is not maintainable in view of the recent judgment of this Court in the case of Universal Sompo General Insurance Company Ltd. vs. Suresh Chand Jain and Another[1]:

wherein this Court has held that the remedy of Article 226 of the Constitution before the High Court would be available to an aggrieved party where the NCDRC[2] has decided an appeal or a revision but no such remedy would be available where it was an original complaint before the NCDRC. The present petition should be dismissed on the ground of alternative remedy.


Respondent contended that the appellants, as legal heirs of the deceased partner, were liable for the payment, and the complaint was maintainable under the 1986 Act.


  • Whether the complaint filed under the Consumer Protection Act, 1986, is maintainable.
  • Whether the appellants were liable for the investment returns as legal heirs of the deceased partner.
  • And Availability of alternative legal remedies.


The Supreme Court observed that the respondent was deemed a partner of the firm as per the registered partnership deed. The investment being commercial in nature fell outside the purview of the Consumer Protection Act.

It was held that legal heirs do not automatically become liable for the firm’s debts upon the death of a partner unless explicitly stated and dismissed the complaint.

It advised the complainant to seek redressal in a civil court. The Supreme Court’s decision set aside the orders of lower consumer forums and provided guidance on resolving partnership investment disputes.

This judgment underscores the importance of understanding the legal framework governing partnership firms and consumer protection laws. It clarifies the scope of the Consumer Protection Act and the liability of legal heirs in partnership matters.

“PRIME LEGAL is a full-service law firm that has won a National Award and has more than 20 years of experience in an array of sectors and practice areas. Prime legal fall into a category of best law firm, best lawyer, best family lawyer, best divorce lawyer, best divorce law firm, best criminal lawyer, best criminal law firm, best consumer lawyer, best civil lawyer.”

Judgement Reviewed by – Chiraag K A

Click Here to View Judgement

[1] (2023) SCC Online SC 877

[2] National Consumer Disputes Redressal Commission


A way towards transparency : CCPA on dark patterns

Introduction :

Dark patterns are a consumer tactic that is used to manipulate the choices of the user. For example, when someone is purchasing from an online store, the price of the product is exclusive of the taxes and delivery charges. The price the consumer opted for is more than what was shown in the initial stage. Dark pattern is a blanket term in which the user has to deliberately make a choice to consume what they need. There are many circumstances where exploitation of the consumer takes place due to these underlying dark patterns. Examples include unnecessary pop-up boxes which automatically drive the consumer away from the product or service they require[1].

The government of India has legislated the use of these patterns in the guidelines issued by the Consumer Protection Authority of India called the “Guidelines for Prevention and Regulation of Dark Patterns, 2023”

Other authorities on Dark Patterns :

In India, the major shield consumers have against any exploitation is the Consumer Protection Act, of 2019. Section 2(9)[2] defines consumer rights and it includes the right to be protected against harmful marketing and, right to be informed about the nature of the goods or services. The act of tricking a consumer into buying something or not providing the whole truth initially can be labelled as a violation of consumer rights along with unfair trade practices dealt with under Section 47[3] of the Act.

In the event of a violation of consumer rights, the Central Consumer Protection Authority issues guidelines to prevent unfair trade practices. Noncompliance with any orders passed by CCPA can lead to imprisonment of 6 months or a fine of up to Rs.20 lakhs or both[4]. In addition, the CPA punishes creating deceptive or misleading advertisements that harm customers’ interests. Penalties include up to two years in prison and a fine of up to Rs 10 Lakh. Moreover, a maximum sentence of five years in prison and a maximum fine of Rs.50 lakh may be applied for repeat offences. These penalties can also be applied for each additional violation[5].

The E-commerce Rules, 2020 is a regulatory framework which governs the goods and services bought online. It prohibits all sorts of unfair trade practices causing the dominant position of one particular company. Rule 4(3)[6] provides that “ No e-commerce entity shall adopt any unfair trade practice, whether in the course of business on its platform or otherwise.”

On June 15, 2023 the Advertising Standards Council of India, a self-regulatory body released the guidelines called the “Guidelines for Online Deceptive Design Patterns in Advertising”. It aimed to prevent drip pricing, which is the concept of deceiving the consumers from the actual prices at the end. The practice of baits in online advertisements were also prohibited by the guidelines or providing alternative products instead of the original one. Alongside these prohibitions, the guidelines also focussed on preventing disguised advertisements from other sites in the product page.

Guidelines for Prevention and Regulation of Dark Patterns, 2023

The central consumer protection authority exercises of its powers under Section 18 of the Consumer Protection Act, 2019[7] and issued the guidelines on November 30th, 2023. The guidelines define dark patterns as :

“ “Dark patterns” shall mean any practices or deceptive design patterns using UI/UX (user interface/user experience) interactions on any platform; designed to mislead or trick users into doing something they originally did not intend or want to do; by subverting or impairing the consumer autonomy, decision making or choice; amounting to misleading advertisement or unfair trade practice or violation of consumer rights;”[8]

Under Section 5 of the guidelines, if any person or platform does something that is under Annexure I, will be said to have engaged in dark patterns. Annexure I of the guidelines contains the specified dark patterns which are strictly prohibited. There are in total 10 specified dark patterns which are prohibited.

Specified Dark Patterns :

The CCPA has outlined specific deceptive designs or illustrations as to what constitutes a dark pattern, they are[9] :

  1. False Urgency : It means falsely implying the product is running out of stock or creating a sense of urgency to mislead a user into buying the product. For example, A website showing only 2 are in stock while 30 others are looking to buy the same thing falsely is prohibited.
  2. Basket sneaking : It means the inclusion of additional products which was not added by the user during checkout wherein the total amount payable has increased as a result. However, in the proviso it was mentioned that providing complementary samples is not basket sneaking.
  3. Confirm Shaming : It means when the provider uses shame, guilt or fear in the user for not buying or using their product. For example, A platform that adds a charity in the basket using a phrase “charity is for rich, I don’t care.” would be deemed as a dark pattern.
  4. Forced Action : It means when the user is forced to take some action which would require them to buy an additional product or sign up for a service. Eg: Forcing the user tp subscribe to a newsletter to purchase a product.
  5.  Subscription trap : This occurs when the user is unable to cancel their subscription or when the process is too lengthy or elaborate. It also includes forcing auto-debits without easy cancellation policy.
  6. Interface interference : It means designing a feature wherein the user is manipulated into doing something they normally wouldn’t do if not for the feature. For example, An ‘X’ icon on the top-right corner of a pop-up screen leads to opening-up of another ad rather than closing it.
  7. Bait and Switch : It refers to the practice of advertising a particular outcome based on the user’s action but deceptively serving an alternate outcome. Eg : A seller offers a quality product at a cheap price but when the consumer is about to pay/buy, the seller states that the product is no longer available and instead offers a similar looking product but more expensive.
  8. Drip Pricing : Means when the prices are changed or different while checkout would be referred to as a dark pattern.
  9. Disguised advertisement : It means a practice of posing, and masking advertisements as other types of content such as user-generated content or new articles or false advertisements.
  10. Nagging : It refers to when a website causes a lot of interruptions while browsing such as requests, options, information which are unrelated to the purchase disrupting the intended transaction. Eg : Websites asking a user to download their app, again and again.


This guideline can act as a step towards transparency in the e-commerce market regime of India. However, it also requires the authorities to keenly ensure companies follow it and in the right circumstances curb these actions. The objective of the guidelines is to provide a better online experience to users and prevent them from exploitation. The same can only be brought into reality if there is proper enforcement.

“PRIME LEGAL is a full-service law firm that has won a National Award and has more than 20 years of experience in an array of sectors and practice areas. Prime legal fall into a category of best law firm, best lawyer, best family lawyer, best divorce lawyer, best divorce law firm, best criminal lawyer, best criminal law firm, best consumer lawyer, best civil lawyer.”

Written by- Sanjana Ravichandran

[1] Gargi Sarkar, Govt Issues List of 13 Dark Patterns Plauging Ecommerce Websites, INC42 (Dec 04, 2023) https://inc42.com/buzz/govt-issues-list-of-13-dark-patterns-plaguing-ecommerce-websites/

[2] The Consumer protection Act, 2019 No. 36, Acts of Parliament, 2019 (India)

[3] Sec 47, “unfair trade practice” means a trade practice which, for the purpose of promoting the sale, use or supply of any goods or for the provision of any service, adopts any unfair method or unfair or deceptive practice. The Consumer protection Act, 2019 No. 36, Acts of Parliament, 2019 (India)

[4] Advait Luthra, Ananya Mishra, India: ASCI Guidelines On Dark Patterns And The Way Forward, MONDAQ, (Aug 29, 2023) https://www.mondaq.com/india/dodd-frank-consumer-protection-act/1358384/asci-guidelines-on-dark-patterns-and-the-way-forward#:~:text=Dark%20patterns%20are%20basically%20user,for%20reviews%2C%20and%20so%20on.

[5] The consumer Protection (E-commerce) Rules, 2020.

[6] The consumer Protection (E-commerce) Rules, 2020.

[7]  Guidelines for Prevention and Regulation of Dark Patterns, 2023

[8] Section 2(6) of Guidelines for Prevention and Regulation of Dark Patterns, 2023.

[9] Annexure 1 of  Guidelines for Prevention and Regulation of Dark Patterns, 2023.