The definition of consumer u/s 2(1)(d) does include the services rendered by Advocate – Madras High Court

Even if the section is declared to be unconstitutional the other sections of the Act will continue to be intact and if the services of the advocate fall within the definition of service u/s 2(o) of the Act, then, it will be certainly open to a client to proceed against, the advocate before the Consumer Redressal Forum.