The power of TRAI under Sections 11 and 13 of the TRAI Act to issue directions for securing compliance with statutory regulations is regulatory in nature and does not amount to adjudication of disputes between service providers. TRAI may enforce compliance and initiate prosecution for violation of its lawful directions, but it cannot determine contractual rights or adjudicate inter se disputes, which fall exclusively within the jurisdiction of TDSAT under Section 14, while criminal liability under Sections 29 and 34 is to be determined only by the competent criminal court. 2026 INSC 742.

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Telecom Regulatory Authority of India Act, 1997 – Sections 11, 13, 14, 29, 34 & 36 – Regulatory powers of TRAI – Whether issuance of directions to enforce compliance with statutory regulations amounts to adjudication of disputes between service providers? – Held, No.

Disputes arose between a Multi-System Operator (MSO) and several Local Cable Operators (LCOs) regarding disconnection of cable television signals. Acting on complaints and pursuant to the directions of the Madras High Court, TRAI issued directions under Sections 11 and 13 of the TRAI Act requiring the MSO to comply with the Interconnection Regulations. Upon receiving a report indicating non-compliance, TRAI issued a show-cause notice proposing prosecution under Sections 29 and 34 of the Act. The Telecom Disputes Settlement and Appellate Tribunal (TDSAT) quashed the directions and the show-cause notice holding that TRAI had assumed adjudicatory jurisdiction exclusively vested in TDSAT. Whether issuance of regulatory directions and initiation of enforcement proceedings by TRAI amount to adjudication of disputes between service providers? – Held, No.

The Supreme Court held that the functions performed by TRAI under Sections 11 and 13 are regulatory and administrative, whereas adjudication of disputes between service providers is exclusively vested in TDSAT under Section 14. A direction issued by TRAI to secure compliance with statutory regulations neither determines the contractual rights of the parties nor adjudicates their inter se disputes. Likewise, issuance of a show-cause notice proposing prosecution for violation of statutory directions is merely a step towards regulatory enforcement and does not amount to adjudication. TRAI may issue binding directions, record a prima facie opinion regarding non-compliance, and initiate prosecution under Section 34, but it cannot finally determine disputes, award damages, quantify claims, entertain counterclaims, or mould relief, all of which remain within the exclusive jurisdiction of TDSAT or the competent criminal court. The judgment of TDSAT was accordingly set aside.

Ratio Decidendi

The power of TRAI under Sections 11 and 13 of the TRAI Act to issue directions for securing compliance with statutory regulations is regulatory in nature and does not amount to adjudication of disputes between service providers. TRAI may enforce compliance and initiate prosecution for violation of its lawful directions, but it cannot determine contractual rights or adjudicate inter se disputes, which fall exclusively within the jurisdiction of TDSAT under Section 14, while criminal liability under Sections 29 and 34 is to be determined only by the competent criminal court. 2026 INSC 742.