The limitation is  years but If it is recurring cause of action then it extends. You can rely on that judgement and at then most file complaint within 2 yrs from date of rejection of earlier complaint 

Even your remedy of appeal was applicable before state commission that fime

Sir/Ma’am

If you need any further assistance for the same.You can approach me through Kaanoon or LinkedIn.

https://www.linkedin.com/mwlite/in/prashanth-nayak-5477b138

You can file 3 separate complaints in Thane consumer forum 

2) limitation period can be counted from date of dismissal of earlier complaint in 2024 

According to the Consumer Protection Act, even if a consumer complaint is initially rejected due to technical reasons, the limitation period for filing a new complaint remains the same - two years from the date the cause of action arose; meaning you must file a new complaint within two years of the incident that led to the complaint, regardless of the previous rejection. 

The "cause of action" is the date on which the deficiency in service or defect in goods occurred, marking the starting point for the two-year limitation period.

Even if your first complaint was rejected due to a technical error in filing, the time limit to file a new complaint does not extend.

While the general limitation is two years, always consult the specific consumer forum where you are filing your complaint to ensure you are adhering to their guidelines.

You are within limitation as from 2018 to 2024 period of limitation is suspended. You can file fresh complaints on same cause of action complying with objections taken by registrar of State Commission.

1. Yes, as the cause of action against the three is different , then you should file separate complaint against each of the parties. 

2. The opportunity must be given by the Court at the time of dismissal , otherwise you should withdraw the cases with the opportunity to refile the case 

- However, the limitation can be run from the date of filing of the complaint before the first forum.

3. If rejected then you can approach the higher commission against the said order .

(i) Filing Three Separate Complaints Under the 2019 Act in Thane Consumer Court

Yes, you can file three separate consumer complaints under the Consumer Protection Act, 2019, in the appropriate Thane Consumer Forum if the cause of action is still within the limitation period. However, two key factors must be considered:

• 
  Jurisdiction: Under the 2019 Act, you can file the complaint where the complainant resides (Thane), unlike the 1986 Act, which primarily required filing at the place of business of the opposite party.
• 
  Cause of Action: Since the earlier complaint was dismissed on technical grounds (multiple causes of action against multiple parties), you can refile separately, provided limitation is not a hurdle.

(ii) Whether the Limitation of Two Years Runs from the Date of Dismissal of the First Complaint in 2024

• The general principle in consumer cases is that the limitation period of two years runs from the date of the cause of action, i.e., when the deficiency in service or defect in goods was first noticed.
• However, you are referring to the Supreme Court's ruling in Indian Evangelical Lutheran Church Trust Association v. Sri Bala & Co., where it was held that when a complaint is dismissed on technical grounds, the limitation period can restart from the date of dismissal if the complainant was bona fide litigating.
• You may rely on this judgment to argue that the fresh complaints are within limitation from the date of dismissal in 2024.

(iii) If the Limitation of Two Years from Dismissal is Not Applicable, What Would Be the Limitation?

If the consumer forum does not accept the argument under Indian Evangelical Lutheran Church Trust Association case, then the standard limitation of two years from the date of cause of action applies.

• If the original deficiency in service or defect was discovered before 2018, the limitation may have already expired unless you can show continuing cause of action (e.g., persistent deficiency, failure to provide service).
• You can also seek condonation of delay under Section 69 of the 2019 Act, if you can prove sufficient cause for delay in refiling.

Suggested Action:

• File the complaints separately in Thane Consumer Court and mention the dismissal order from the State Commission as a reason for delay.
• Cite Indian Evangelical Lutheran Church Trust Association case to justify why the limitation should restart.
• If the court does not accept this argument, request condonation of delay under Section 69 of the 2019 Act.

It would be best to consult a consumer law expert for precise drafting of your complaint to avoid technical dismissals again.

Thanks and Regards,
Advocate Aman Verma
Legal Corridor