Solar Net Metering Complaint: MSEDCL Bill Dispute

One of my clients recently had a case which I am explaining below and if you are stuck in such similar situation, here is what to do.

Note: Due to attorney-client privilege, I cannot disclose complete case details or identify the actual parties involved. However, I am sharing the essential facts and legal approach so that if you find yourself in a similar situation, you can understand the available solutions and legal remedies.

TL;DR: If your discom's billing system isn't crediting the units your rooftop solar exported, you don't have to keep paying inflated bills. A written solar net metering complaint to the Consumer Grievance Redressal Forum, and if needed a complaint before the District Consumer Commission, can get the bill corrected and hold off a disconnection threat. Preserve your meter readings, screenshots and payment proofs from the very first month.

Nikhil Kulkarni's rooftop panels in Baner, Pune had been pushing power back into the grid for over a year. Then the March 2025 bill arrived. ₹22,000. His import-export difference for that month came to roughly 150 units. The meter was fine. MSEDCL's billing system simply wasn't picking up the exported units.

So he started going to the section office. Every second or third day, for about six weeks. Same answer each time. "Under process."

The April bill landed too, ₹15,000, with the same missing export credit. Before the last date printed on the March bill he paid ₹11,000, because the alternative sitting in front of him was a disconnection notice. One clerk told him to go to the head office and complain, then went back to his screen. Kulkarni already had meter photographs and screenshots showing both import and export readings. He had shown them. Nothing moved. He approached the Chamber of Advocate Sudhir Rao's chamber. He came in with a plastic folder: the two bills, a printout of the payment, and photographs of the meter from each of the six weeks. He had also kept a small notebook with the date, the name of whoever he met at the section office, and what he was told.

That notebook, as it turned out, was the most useful thing in the folder. Here is what the law gives a person in that position.

What the law says about rooftop solar billing

The framework is a stack, not a single Act.

• The Electricity Act, 2003 — Section 42 sets up the Consumer Grievance Redressal Forum (CGRF) and the Electricity Ombudsman. Every distribution licensee in every state must have these. Section 56 governs disconnection and requires clear written notice before supply is cut.
• The state regulator's net metering regulations — in Maharashtra, MERC. These are the rules that actually create the net metering arrangement: eligibility by sanctioned load, the bi-directional meter, the settlement period, and the principle that you are billed on net import, not gross import.
• The Electricity (Rights of Consumers) Rules, 2020 — central rules on metering, billing, and the manner in which a licensee must handle a disputed bill and a disconnection.
• The Consumer Protection Act, 2019 — electricity supply is a "service". A defective bill is a deficiency in service, and the District Commission can hear it.

The core billing point is simple. Under net metering, the meter keeps two registers — units imported and units exported. What you pay for is the difference. If the discom's billing system reads only the import register, or fails to ingest the export register, you get a bill that is higher than what the meter actually shows. That is a billing defect, not a metering miracle, and it is exactly what the CGRF exists to fix.

Key facts in a case like this

• The meter is working and shows both registers. The failure is in the billing system, or in the reading that was fed into it.
• Complaints made verbally at a section office leave no trace. Date, time, name of the official, and what was said.
• Any payment made under pressure of disconnection should be recorded as paid under protest in writing.
• The limitation period for a consumer complaint is two years from the date the deficiency arose. The CGRF route has its own, usually shorter, windows.
• Forums can order a corrected bill and compensation. They will not order a corrected bill on the strength of your word alone — the meter readings have to back you up.

How do I file a solar net metering complaint?

In sequence. Skipping a step is the most common reason these complaints stall.

Step 1 — A written complaint to the discom

Not a visit. A written complaint, on paper or through the licensee's portal, addressed to the section or sub-division office and marked to the grievance cell. Attach the bill you dispute, the meter photographs showing both registers, and a one-page note of dates on which you already raised it verbally. Ask for a specific thing: re-reading of the meter and revision of the bill on a net basis. Keep the acknowledgement — the portal reference number or the office stamp on your copy.

Most licensees have an internal redressal level above the section office. Ask in writing what that level is. Give them a fixed period, say fifteen days, to respond.

Step 2 — The Consumer Grievance Redressal Forum

If the internal route goes quiet, this is the real forum. The CGRF is constituted under Section 42(5) of the Electricity Act and is free to approach in most states. Your complaint goes to the CGRF of your distribution licensee, in the format the state regulations prescribe. Attach everything from Step 1 and the acknowledgement.

Do not describe the dispute as a general grievance about service. Make it a billing dispute with numbers: these are the units the meter exported, this is what the bill says, this is the difference. The forum's regulations set the outer limit for a decision, and it is usually measured in weeks rather than years. Ask the forum office for the current timeline.

Step 3 — The Ombudsman

If the CGRF decision goes against you, or the CGRF does not decide within its time limit, the next step is the Electricity Ombudsman under Section 42(6). This is an appeal, so the CGRF order and the record go with it.

Step 4 — The District Consumer Commission

Running alongside, or after, the electricity route, there is a complaint under the Consumer Protection Act, 2019. You can ask for revision of the bill, refund of any excess paid, compensation, and litigation cost. The consumer fee for smaller claims is nil or nominal. The limitation is two years.

One honest caveat: some Commissions are reluctant to entertain an electricity billing dispute until the statutory CGRF route has been tried, on the reasoning that the Electricity Act creates a specific forum. Others entertain it directly. Which way your Commission leans is a fact worth knowing before you file, and it differs from state to state.

What about the disconnection threat?

A disconnection is a separate legal event from the bill dispute, and it has its own rules. Section 56 of the Electricity Act, 2003 requires the licensee to give not less than fifteen clear days' written notice before cutting supply, and only for a sum that has been shown continuously as recoverable. A threat delivered verbally by a lineman is not a Section 56 notice.

The Electricity (Rights of Consumers) Rules, 2020 and the state supply codes add protections around disputed bills. How far a pending CGRF complaint freezes a disconnection depends on the exact clause and on your state's regulations. Do not assume it does. Write to the licensee the moment you file, stating that the bill is disputed and pending before the CGRF, and ask them to confirm in writing that supply will not be disconnected during the pendency.

If you do pay to keep the lights on, pay under protest in writing, with the complaint reference in the same letter. That preserves your claim to a refund.

What to preserve, from month one

• Photographs of the meter display showing the import register, the export register, and the meter serial number, taken on the same day each month.
• Screenshots of the licensee's app or portal, with the date visible.
• Every bill as issued, and every payment receipt.
• A running log: date, place, official, what was said.
• Portal complaint reference numbers and acknowledgement slips.
• The net metering agreement and the sanction letter for your system, if you still have them.

This sounds like clerical work. It is the difference between a complaint that moves and one that gets a "under process" reply for six weeks.

What a forum can and cannot do

On a clear billing defect, a forum can direct a fresh meter reading, revision of the bill on a net basis, adjustment of amounts already paid, and in a suitable case, compensation. What it will not do is accept your arithmetic over the licensee's without the meter data behind it. And if the export register itself was never commissioned, or the bi-directional meter was never installed, then the problem is not a billing error — it is a failure of the net metering arrangement itself, which changes both the forum and the relief. That distinction is worth getting right at the start.

We only have one side of any of this. Discoms often have their own record of the readings fed into the system, and sometimes the gap is on the consumer's side — a meter that was replaced without the new serial being mapped, for instance.

Frequently Asked Questions

What to send us

If the export credit is missing from your bill and the section office is not moving, send us the disputed bill, the date it was issued, your net metering or sanction details if you have them, and a two-line note on what you have already complained about and when. That is enough for us to tell you which forum you should be in and what the realistic outcome looks like. On some of these files the honest answer is that there is nothing to argue — the reading was correct. We will say so if that is the case.

Write to /contact-us or book a slot at /book. Advocate Sudhir Rao practises criminal defence, cyber crime and economic offences at the Supreme Court of India; Advocate Jyoti Rao handles family and matrimonial matters.

This article is general information about Indian law and is not legal advice on your own situation. Electricity regulation varies by state and by licensee.

Advocate Sudhir Rao, Supreme Court of India