1. Legal Issue in Simple Terms

When a platform:

• Shows a lower price initially
• Adds “fees” only at final payment stage
• Does not disclose full cost upfront
• Creates misleading impression of cheaper pricing

➡️ It may amount to:

(A) Unfair Trade Practice (Section 2(47), Consumer Protection Act 2019)

Because it involves:

• Misleading representation of price
• Concealment of material facts
• “Drip pricing” (adding unavoidable charges later)

(B) Deficiency in Service (Section 2(11))

Because the service is not transparent or as promised.

2. Legal Principles Applied by Courts

Indian courts and commissions consistently hold that:

A consumer must know the total price before purchase, not after reaching payment stage.

Hidden or “last-minute” charges violate:

• Transparency
• Fair choice
• Informed consent

3. Important Case Laws 

1. Emirates Airlines v. Dr. Keshab Nandy (Maharashtra SCDRC, 2025)

• Airline charged seat selection fees
• Free seats were actually available
• Consumer misled into paying extra

Held:

• Non-disclosure of free alternatives = unfair trade practice
• Creating impression of scarcity = misleading conduct

➡️ Principle: Hiding cheaper/free options = deception

2. PVR Ltd v. State of Maharashtra (Bombay High Court, 2025)

• Government tried to ban convenience fees
• Court struck down restriction

Held:

• Convenience fee itself is legal only if transparently disclosed
• Charging for online booking is valid commercial practice

➡️ Principle:
✔ Fees allowed
❌ But must be clearly disclosed upfront

3. IRCTC Service Charges Case (CCI Findings, 2015)

• Challenge against mandatory service charges in railway e-ticketing

Held:

• Charging service fees is not illegal per se
• But concerns raised about fairness and transparency

➡️ Principle:

• Even monopoly platforms must ensure non-exploitative pricing

4. BookMyShow Convenience Fee Dispute (Tax/Consumer Litigation Line of Cases)

• Multiple challenges regarding “convenience fee” and hidden charges

Courts/Tribunals consistently observed:

• Convenience fee is valid only when:
  • Clearly displayed before booking
  • Not disguised or merged later

➡️ Principle:
“Drip pricing violates informed consumer choice”

5. Maharashtra SCDRC v. Online Booking Platforms (Dark Patterns recognition line of reasoning)

• Seat selection and booking interfaces studied

Held:

• Manipulative UI design that pushes users toward paid options = unfair trade practice

➡️ Principle:
“Interface design can itself be misleading”

6. BookMyShow & CCI Abuse of Dominance Complaint (2026)

• Allegation: hidden convenience fees + platform control over pricing

Held:

• No abuse of dominance established
• But fee structures are subject to transparency obligations

➡️ Principle:
Even if pricing is legal, lack of transparency can still be questioned under consumer law

7. RTI-based Consumer Case (BookMyShow Internet Charges Case, 2019)

• Complaint that “internet handling fees” were not authorised by RBI

Held (consumer forum discussion):

• Non-transparent charges can amount to unfair trade practice

➡️ Principle:
If fee is not properly authorised/disclosed → consumer can challenge

4. Key Legal Tests Derived from Case Law

Courts generally ask:

1. Was total price disclosed upfront?

If NO → unfair trade practice

2. Was consumer misled about “final cost”?

If YES → violation

3. Was fee optional or unavoidable?

If unavoidable but hidden → illegal

4. Was there suppression of material information?

If YES → deficiency in service

5. Application to Exam-Seat Booking Scenario

Typical exam platforms (like entrance test portals or seat booking systems) often:

• Show base exam fee only
• Add “service charge / convenience fee / GST / processing fee” at checkout
• Do not show full cost on first page

Legal consequence:

This can be challenged as:

• Unfair Trade Practice
• Misleading Advertisement (price misrepresentation)
• Deficiency in Service

6. Remedies Available to Consumers

Under Consumer Protection Act, 2019:

You can file complaint before:

• District Consumer Commission (if claim ≤ ₹1 crore)
• State Commission (₹1–10 crore category varies)

Reliefs possible:

• Refund of hidden charges
• Compensation for mental harassment
• Order directing platforms to display full pricing upfront
• Penalty for unfair trade practice

7. Strong Legal Position Summary

Indian consumer jurisprudence is moving toward a clear principle:

“A consumer must see the final payable price before clicking pay, not after.”

So even if companies argue:

• “fees are valid”
• “terms & conditions mention it”
• “optional service”

Courts still strike them down if:

• Hidden until checkout
• Not clearly disclosed in advance
• Creates misleading price impression