CCPA Imposes ₹8 Lakh Penalty on Narayana Educational Institutions for Misleading JEE Advanced 2024 Advertisement

Background and Overview

The Central Consumer Protection Authority (CCPA) initiated suo motu proceedings against Narayana Educational Institutions after taking cognizance of allegedly misleading advertisements published across the institution's official website (www.narayanagroup.com), its Facebook page, and in The Times of India dated 10 June 2024. The advertisements, which were connected to JEE Advanced 2024 results, raised two fundamental concerns: first, that both AIR 1 and AIR 11 were attributed to the same student, Mr. Matcha Balaaditya; and second, that the names and photographs of successful candidates were prominently displayed without any indication of the specific courses those candidates had enrolled in at the institution.

The matter traversed through preliminary inquiry, a detailed investigation by the Director General (Investigation), exchange of replies, and a formal hearing before culminating in a penalty order. This case carries significant implications for the coaching industry at large, where result-based advertising is a routine practice and material disclosures are frequently absent or illegible.

Statutory Framework and Regulatory Authority

The CCPA derives its authority from Section 10 of the Consumer Protection Act, 2019, which establishes the Authority for the purpose of addressing violations of consumer rights, unfair trade practices, and false or misleading advertisements that are prejudicial to the interests of consumers as a class.

Section 18 read with Section 9 of the Consumer Protection Act, 2019 empowers the CCPA to ensure that advertisements are transparent, accurate, and complete in their disclosures, and to protect every consumer's right to be informed so as to facilitate genuinely informed decision-making.

Additionally, the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 (hereinafter referred to as the "2022 Guidelines") impose substantive obligations on advertisers:

  • Clause 4 mandates that all claims made in an advertisement must be truthful and must not mislead consumers through unsubstantiated assertions.
  • Clause 11 requires that disclaimers be clear, prominent, and legible to a normally-sighted person reading the communication once, from a reasonable distance and at a reasonable speed, and that the font used in disclaimers must be identical to the font used for the primary claim.
  • Clause 12 places an affirmative duty on service providers to ensure that objectively verifiable claims are capable of substantiation and to produce supporting evidence upon demand by the CCPA.

Key Provision: Section 2(28) of the Consumer Protection Act, 2019 defines a "misleading advertisement" in relation to any product or service as one which falsely describes such product or service; gives a false guarantee or is likely to mislead consumers as to nature, substance, quantity or quality; conveys an express or implied representation that would constitute an unfair trade practice if made by the manufacturer or service provider; or deliberately conceals important information.

The Impugned Advertisements: What Was Published

The advertisements prominently featured the photographs, names, and ranks of several successful JEE Advanced 2024 candidates. Simultaneously, the institution promoted its various commercial programmes, including:

  • Two-year Regular Integrated Classroom Programme
  • Narayana's Apex/Spark Integrated Programme for IIT-JEE Main & Advanced
  • One-Year NEET Dropper/Repeater Classroom Programme
  • Three-year Foundation Course
  • One-year Foundation Course

The advertisements did not, however, disclose whether the featured candidates had attended any of these programmes specifically, or whether they had been enrolled in distance learning programmes (DLP), test series, short-term programmes, or workshops. This omission formed the crux of the CCPA's concern.

CCPA Notice and Institutional Response

Notice Issued on 24 June 2024

Upon completion of its preliminary inquiry, the CCPA issued a formal notice to Narayana Educational Institutions on 24 June 2024 seeking the following information:

  1. An explanation of how two distinct All India Ranks — AIR 1 and AIR 11 — could be attributed to the same student, Mr. Matcha Balaaditya
  2. The specific course type attended by each featured rank-holder
  3. Duration and date of joining for each such student
  4. Fee details along with certified copies of fee receipts
  5. Evidentiary basis for the dual-rank claim

Institution's Reply

After multiple reminders dated 23 July 2024, 9 September 2024, and 29 May 2025, the institution eventually filed a substantive response on 13 June 2025. The key submissions were:

  • On the dual rank: Mr. Matcha Balaaditya had secured Rank 1 in the OBC category and Rank 11 in the General category, both of which were verified through the official JEE Advanced 2024 rank card issued by the Joint Admission Board (JAB).
  • On course disclosure: The institution acknowledged that specific course details had not been mentioned in the advertisement, attributing this to "space constraints" and a focus on student achievements rather than institutional particulars.
  • On enrolment: Admission forms of featured students were submitted, though the institution argued that no legal prohibition exists against showcasing the achievements of students enrolled in any of its bona fide programmes.

CCPA's Initial Observations

The CCPA, upon reviewing the response, identified three significant deficiencies:

  • Fee receipts for featured students were not produced despite specific direction
  • The institution itself admitted that course information was withheld due to space constraints
  • A substantial majority of the submitted admission forms were unsigned by parents or the minor students involved, and lacked dates — rendering the enrolment records incomplete and unreliable as documentary evidence