On February 25, 2026, India's Central Consumer Protection Authority issued an order imposing a penalty of ₹8,00,000 - eight lakh rupees - on Raising Superstars Enterprises Private Limited for disseminating misleading advertisements in connection with its "Prodigy Framework Program." The order, bearing file number CCPA-2/17/2022-CCPA and signed by Chief Commissioner Nidhi Khare and Commissioner Anupam Mishra, concluded a legal process stretching back to 2022 and represents one of the more detailed regulatory rulings on outcome-based marketing directed at parents of infants in India.

The penalty concerns three specific claims that had appeared on the company's website, stating that infants enrolled in the programme would be "crawling at 3 months," "walking at 8 months," and "using 200+ vocabulary by 18 months." According to the CCPA order, the company acknowledged during proceedings that no scientific study, clinical assessment, or empirical research was undertaken to establish a causal relationship between participation in the programme and those developmental milestones. No systematic measurement, tracking mechanism, or outcome evaluation was carried out. No quantified or statistically validated data exists correlating participation in the programme with achievement of the advertised outcomes.

The case originated from a complaint received by the CCPA from the Advertising Standards Council of India (ASCI), which alleged the company had disseminated misleading advertisements in respect of the Prodigy Framework Program, published on the company's own website. Under Section 19 of the Consumer Protection Act, 2019, the CCPA conducted a preliminary inquiry, formed a prima facie view that the claims warranted examination under Sections 2(28), 2(47), and 2(9) of the Act, and issued a Show Cause Notice to the company dated May 17, 2022.

The company and its programmes

Raising Superstars was incorporated on October 5, 2020 under the Companies Act, 2013. According to submissions made by the company during proceedings, it operates as an omni-channel platform for parents of children aged 0-6 years, offering screen-free activities, cohort-based communities, and expert support. The company stated it has acquired more than 1,32,000 customers globally, of whom over 1,15,000 are from India, and that its mobile application had been downloaded over 3,00,000 times, frequently ranking among top applications in the parenting category.

The company disclosed the indicative pricing structure of its various programmes. The Intro to Prodigy Framework was priced at an average of ₹497, an introductory module covering early childhood education and screen-free activities. The Prodigy Challenge carried an average price of approximately ₹7,997, involving screen-free activities, proprietary "Booster Cards," books, access to parent coaches, and a parent community. The Prodigy Baby System was priced at approximately ₹25,000, described as a six-month programme involving planned activities, physical materials, coaching support, and community access. The Prodigy Mastery Program, offered with instalment options, was priced at approximately ₹39,000 as a twelve-month programme. The Prodigy Surge was priced at approximately ₹19,000, a twelve-month reading programme with physical materials and coaching support. A Prodigy Club Membershipsubscription was priced at approximately ₹500 per month for daily screen-free activities.

According to the company's own submissions, approximately 36,000 users had been acquired prior to publication of the claims on its webpage. Approximately 13,000 users were acquired during the period when the impugned claims were live - from June 2021 to September 2021. Approximately 1,20,000 users were acquired after disclaimers had been added until the page was discontinued in December 2023. The total number of parents who have taken the programme is approximately 1,69,000.

What the company argued

The company's legal response was detailed and multipart. It categorically denied the allegations at the outset, stating it had not published any advertisement which was false, misleading, or prejudicial to any consumer. The company asserted that all content and data published on its website were backed by scientific evidence and literature published by reputed institutions, including Harvard University and UNICEF. It further submitted that the content objected to had not formed part of its website since September 15, 2021, and was suitably modified.

The company stated it had appointed Dr. Craig S. Bailey, Ph.D., Assistant Professor at the Child Study Center and Director of Early Childhood at the Yale Center for Emotional Intelligence, Yale School of Medicine, who was associated with the company during its initial phase and involved in vetting the programmes. It also named Ms. Sonal Chawla, an early childhood education professional with over 27 years of experience, who headed curriculum development and app design. The company had appeared on the television programme Shark Tank India, where its business model was publicly disclosed.

On the specific developmental claims, the company submitted that infants can crawl on their bellies from three months, citing articles by medical professionals and books on early childhood physical development. Claims relating to babies walking at eight months and vocabulary development were supported by publications from the Times of India, Mama Natural, Mayo Clinic, and certified speech-language pathologists. The company submitted detailed charts and scientific literature in support.

The company also disclosed website modifications made following ASCI correspondence, including adding a disclaimer stating "While we can't guarantee this (nobody can!), we can prepare you and your child for the best chance at life," qualifying the crawling claim with the phrase "belly crawling, not on all fours," and revising Terms of Use to expressly disclaim warranties and guarantees.

During the hearing on December 11, 2025, the company additionally submitted data showing its earlier domain "prodigyframework.in" was hosted on the platform "Clickfunnels" in 2022, and that upon domain migration in 2023, the earlier domain and its content were deleted.

The authority's findings

The CCPA, after considering written submissions, oral submissions across multiple hearings, and the Investigation Report submitted by the Director General dated November 25, 2025 - received by the CCPA on December 3, 2025 - recorded its findings.

The core finding was that the claims displayed on the website amounted to misleading advertisements and unfair trade practices under the Consumer Protection Act, 2019. The authority observed that the representations directly concerned infant growth, neurological development, and early cognitive milestones, areas intrinsically linked to a child's health, well-being, and long-term development. Advertisements dealing with such subjects are, according to the CCPA, "by their very nature, extremely sensitive and demand the highest standard of accuracy, substantiation, and responsibility."

The CCPA observed that parents and guardians of infants and young children constitute a particularly vulnerable class of consumers. Decisions relating to early childhood development are often taken in a context of anxiety, heightened emotional involvement, limited scientific literacy, and a strong desire to secure the best possible start for one's child. Claims suggesting accelerated or exceptional development have a powerful persuasive impact and are capable of significantly influencing parental decision-making. Any misleading representation in this domain carries a serious potential for harm, including the creation of unrealistic expectations, financial exploitation, diversion from evidence-based practices, and psychological distress if promised outcomes are not achieved.

The authority found it undisputed that the claims - "crawling at 3 months," "walking at 8 months," and "using 200+ vocabulary by 18 months" - were framed as specific, time-bound developmental outcomes and conveyed to consumers as achievements attributable to participation in the programme. These claims did not merely describe isolated experiences but projected precise developmental milestones linked to defined ages, thereby creating an overall representation that such results were achievable through enrolment.

On disclaimers, the authority was unequivocal. According to the order, the subsequent insertion of disclaimers such as "results may vary" and "no guarantee of results" does not cure the misleading nature of the original claims. Where precise, outcome-oriented claims are made regarding early childhood milestones, a general disclaimer is insufficient to neutralise the dominant impression conveyed to parents. The net effect of the advertisements continued to suggest that enrolment in the programme would lead to early crawling, early walking, and advanced vocabulary development.

The CCPA also noted the company's own admission, made expressly during the hearings held on December 11, 2025 and December 19, 2025, that no scientific study had been undertaken to substantiate the claims and that the programme activities had been created by experts based on their experience. Upon further query, the company stated it had not undertaken any systematic measurement or study and did not maintain success or non-success data in respect of the claims made. The company could not, at any stage of the proceedings, furnish the number of parents or children who had actually achieved the stated milestones, despite being afforded multiple opportunities to do so. In its final undertaking dated December 19, 2025, the company expressly stated it does not maintain any quantified success data in respect of the claims made.

The Investigation Report found that the claims were not supported by scientific evidence, were based solely on variable parental feedback, and could mislead consumers regarding the nature and outcomes of the programmes, thereby amounting to a violation despite their later removal. The Report also found that the company initially failed to provide the contact details of its Grievance Officer on its platform, which amounts to a violation of Rule 4 of the Consumer Protection (E-Commerce) Rules, 2020.

The CCPA found violations of three provisions of the Consumer Protection Act, 2019. Under Section 2(9), which recognises the consumer's right to be informed and protected against unfair trade practices, the authority found that consumers were denied accurate, complete, and evidence-based information necessary to make an informed decision. This impairment is particularly serious where the consumer group consists of parents of infants and toddlers, whose purchasing decisions are closely tied to concerns of health, development, and future well-being.

Under Section 2(28), which defines misleading advertisement, the authority found that the representations falsely described the nature, efficacy, and expected results of the service and were likely to mislead consumers, particularly vulnerable parents. Under Section 2(47), the authority found that by projecting unverified and unquantified testimonial-based outcomes as definitive programme results, the company represented that its services possessed characteristics and benefits which they had not been shown to ordinarily possess - squarely within the ambit of unfair trade practice.

The CCPA is empowered under Sections 20 and 21 of the Act to issue directions and, where necessary, impose a penalty which may extend to ten lakh rupees for a first contravention and up to fifty lakh rupees for every subsequent contravention. Having regard to the nature of the violations, the vulnerability of the affected consumer class, and the duration of dissemination, the authority imposed a penalty of ₹8,00,000. The company is required to submit a compliance affidavit and the penalty amount to the CCPA within 15 days from the date of the order.

Why this matters for digital marketing

The ruling carries implications that extend well beyond a single parenting startup. The FTC's August 2024 rule on fake reviews and testimonials established that regulators in the United States have reached similar conclusions about the use of testimonials without adequate substantiation. The CCPA order now demonstrates that India's consumer protection framework, enacted in 2019, applies with equal force to digital platforms using testimonial-driven marketing for sensitive product categories.

The central legal test, as the CCPA articulates it, is not whether the advertiser subjectively intended to guarantee outcomes, but whether the manner in which claims were presented created an objective impression of assured and typical outcomes. A company may genuinely believe its programme is beneficial. But if that belief is communicated to consumers through specific numerical claims tied to defined developmental ages, without any dataset demonstrating typical achievement rates, the communication crosses from honest promotion into misleading advertisement under the statute.

The disclaimers question is particularly instructive. The CCPA's finding that general caveats such as "results may vary" cannot cure a fundamentally misleading dominant message mirrors enforcement positions taken by regulators across multiple jurisdictions. AI-generated advertisements promoting dietary supplements with fabricated scientific demonstrations face the same structural problem: the dominant message is outcome-oriented, and fine-print disclaimers do not neutralise it.

The case also touches on e-commerce compliance. The violation of Rule 4 of the Consumer Protection (E-Commerce) Rules, 2020 - relating to mandatory disclosures and grievance redressal contact details - is a reminder that digital platforms operating in India must comply with specific structural obligations beyond the content of their advertising. Google's own enforcement on misleading ad design reflects a broader platform-level push toward transparency, one that parallels regulatory requirements under national consumer laws.

For marketing professionals managing outcome-based claims across any sector - but particularly health, education, and child development - the CCPA's reasoning establishes a clear analytical sequence. First, are the claims specific enough to create a representation of typical outcomes? Second, is there contemporaneous, quantified, scientific evidence establishing that those outcomes are typically achievable through participation in the product? Third, do disclaimers appear with sufficient prominence to neutralise the dominant message, or do they merely appear in fine print? If the answers point toward unsubstantiated specific claims with inadequate disclosures, the case falls within the legal perimeter this ruling has now drawn.

The ₹8 lakh penalty - roughly equivalent to approximately $9,400 at current exchange rates - is relatively modest given the company's stated customer base of 1,69,000 users and programme pricing reaching ₹39,000 for its most expensive offering. However, the cease-and-desist direction carries more operational weight. The CCPA has directed the company to cease and desist from making any developmental milestone or performance-related claims from immediate effect unless supported by credible, verifiable, and contemporaneous scientific evidence.

Timeline

  • October 5, 2020 - Raising Superstars Enterprises Private Limited incorporated under the Companies Act, 2013.
  • July 2020 - Company states its programme was launched, with the stated objective of promoting early childhood education.
  • June 2021 - September 2021 - The webpage containing the impugned claims relating to crawling at 3 months, walking at 8 months, and 200+ vocabulary by 18 months remains live. Approximately 13,000 users are acquired during this period, according to CCPA enforcement records.
  • September 15, 2021 - According to the company's submissions, the objected-to content is removed from its website.
  • May 17, 2022 - CCPA issues Show Cause Notice to Raising Superstars following a complaint from the Advertising Standards Council of India (ASCI).
  • May 28, 2022 - Company submits its reply to the Show Cause Notice.
  • December 12, 2022 - CCPA affords the company an opportunity of personal hearing. During the hearing, the CCPA also observes prima facie non-compliance with Rule 4 of the Consumer Protection (E-Commerce) Rules, 2020.
  • December 2023 - The earlier domain "prodigyframework.in" is taken down completely following domain migration.
  • March 7, 2024 - CCPA issues communication calling upon the company to furnish the requisite documents and submissions after the company failed to submit them following the December 2022 hearing.
  • April 2, 2024 - Company submits its response to the March 2024 communication, disclosing programme structure, pricing, and customer data.
  • August 5, 2024 - CCPA refers the matter to the Director General for detailed investigation.
  • November 25, 2025 - Director General submits Investigation Report concluding that the claims constitute misleading advertisements under Section 2(28) and that the company's practices amount to a gross violation of consumer rights under Section 2(9) of the Consumer Protection Act, 2019.
  • December 3, 2025 - CCPA receives the Investigation Report.
  • December 5, 2025 - Investigation Report forwarded to the company for comments.
  • December 11, 2025 - Hearing held before CCPA; company directed to furnish total enrolment numbers, outcome data, and a written undertaking confirming removal of the impugned claims. See also FTC's parallel fake review enforcement.
  • December 19, 2025 - Second hearing; company files signed undertaking confirming statements are no longer present on its website or in any advertisement.
  • December 19, 2025 - Company submits its response to the Investigation Report, dated December 11, 2025.
  • February 25, 2026 - CCPA issues final order imposing penalty of ₹8,00,000 on Raising Superstars Enterprises Private Limited, directing cease and desist on unsupported developmental claims and compliance with e-commerce disclosure rules.

Summary

Who: The Central Consumer Protection Authority (CCPA), established under the Consumer Protection Act, 2019, took action against Raising Superstars Enterprises Private Limited, an Indian parenting technology company incorporated in 2020 and operating at raisingsuperstars.com. The proceedings were originally initiated following a complaint from the Advertising Standards Council of India (ASCI).

What: The CCPA imposed a penalty of ₹8,00,000 (eight lakh rupees) and directed the company to cease all developmental milestone or performance-related advertising claims unless supported by credible, verifiable, and contemporaneous scientific evidence. The authority found violations of Sections 2(9), 2(28), and 2(47) of the Consumer Protection Act, 2019 - covering the consumer's right to be informed, the definition of misleading advertisement, and unfair trade practice - as well as Rule 4 of the Consumer Protection (E-Commerce) Rules, 2020.

When: The order is dated February 25, 2026. The underlying complaint from ASCI predates the Show Cause Notice of May 17, 2022. The contested claims appeared on the company's website between approximately June 2021 and September 2021, after which the company removed and modified them.

Where: The case was heard at the Central Consumer Protection Authority, Room No. 545, Krishi Bhawan, New Delhi - 110001. The misleading content was published on the company's website and accessible nationwide across India and internationally.

Why: The CCPA found that specific, time-bound developmental claims - crawling at 3 months, walking at 8 months, 200+ vocabulary words by 18 months - were framed as outcomes achievable through enrolment in a commercial programme, yet were not supported by any scientific study, clinical assessment, empirical research, or outcome tracking data. Parents of infants constitute a particularly vulnerable consumer class whose purchasing decisions are closely tied to concerns about child health and development. The authority found that general disclaimers inserted after the fact cannot cure an originally misleading dominant message, and that the absence of contemporaneous scientific substantiation for specific developmental outcome claims constitutes dissemination of misleading advertisements under Indian consumer law.

Share this article
The link has been copied!