Antitrust And Competition Newsletter | March 2026

In March 2026, India continued to witness significant developments in competition law enforcement and merger control. On the enforcement front, the Supreme Court declined to interfere with the Delhi High Court's ruling in CCI v. Geep Industries, leaving the question of law open while reaffirming procedural safeguards in respect of penalty enforcement. The Delhi High Court, in a petition filed by AGI Greenpac Limited, directed the Competition Commission of India ("CCI") to consider and decide pending representations within a stipulated timeline. Additionally, the CCI issued several notable enforcement orders, including closing allegations of abuse of dominance against BookMyShow in the online movie ticketing market, Google India in the Android app store ecosystem, and Rapido in bike taxi operations, as well as dismissing claims relating to alleged bid rigging in smart meter procurement and excessive airline ticket cancellation charges. On the merger control front, the CCI approved a broad range of transactions spanning renewable energy, financial services, healthcare, infrastructure, technology and real estate, alongside several deemed approvals under the Green Channel route.

To keep readers informed, this edition provides an overview of private enforcement under the Competition Act, 2002 ("Act") followed by key judicial developments, important enforcement outcomes and orders passed by the CCI, a summary of combinations approved and deemed approved, and highlights of upcoming domestic and international competition law events.

Private Enforcement under the Competition Act, 2002

Under Section 53N of the Act, private claims for compensation in respect of loss or damage arising from anti‑competitive conduct lie before the appellate tribunal, i.e., the National Company Law Appellate Tribunal ("NCLAT"). Such claims may be filed where the loss or damage results from a contravention of: (i) any direction or order passed by the CCI; (ii) any order of the NCLAT; (iii) any order of the Supreme Court passed in appeal against the findings of the NCLAT; or (iv) an order of settlement passed by the CCI. An application for compensation under Section 53N may be filed by any person, enterprise, government, or local authority. Further, where loss or damage has been caused to numerous persons having the same interest, a representative application (class action) may be filed on behalf of all such persons, subject to the prior permission of the NCLAT. However, such an application may be filed only after the CCI, or the NCLAT or the Supreme Court in appeal, has determined that a contravention of the provisions of Sections 3, 4, and 5 & 6 of the Act has occurred, or that there has been a contravention of any order or decision of the CCI or the NCLAT. Upon considering the application, the NCLAT may call for an inquiry and seek recommendations from the CCI before passing an appropriate order under Section 53N of the Act.

Judgments and Orders passed by Supreme Court of India

Supreme Court declines to interfere with Delhi High Court ruling in CCI v. Geep Industries, keeps question of law open

Competition Commission of India vs. Geep Industries (India) Private Limited & Ors. (SLP (C) No. 7026/2026)

The Supreme Court of India, vide Order dated 09.03.2026, declined to interfere with the judgment dated 01.11.2025 passed by the Delhi High Court in LPA No. 727/2024 and accordingly, dismissed the appeal filed by the CCI.

In the said judgement, the Delhi High Court dismissed the letters patent appeal filed by the CCI challenging the Single judge's judgement that set aside CCI's demand for retrospective interest on a reduced penalty amount imposed on Geep Industries in a cartelization case. The Court held that, under the applicable penalty regulations, issuance of a Demand Notice is a mandatory precondition for the levy of interest, and that liability to pay interest does not arise automatically upon expiry of the period specified in the original penalty order, but only upon failure to make payment within the time stipulated in the Demand Notice.

Orders/Judgments passed by High Court of India

Delhi High Court directs CCI to decide pending representations within six weeks, keeps questions of maintainability open

AGI Greenpac Limited v. Competition Commission of India (W.P.(C) No. 1780/2026)

The Delhi High Court, vide Order dated 16.03.2026, disposed of the writ petition filed by AGI Greenpac Limited against the CCI, directing the CCI to consider and decide the Petitioner's pending representations dated 24.11.2025 and 17.12.2025 within a period of six (6) weeks from the date of the said order. In view of the facts and circumstances of the case, the Court opined that since the representations were already under active consideration by the CCI, a limited direction fixing a timeline would suffice. Accordingly, the High Court refrained from examining the merits of the controversy and clarified that the direction shall not be construed as overruling the CCI's objection regarding maintainability, keeping all questions of law open to be agitated in appropriate proceedings.

Orders Passed and Combinations Approved by the Competition Commission of India

CCI closes information alleging abuse of dominance and anti‑competitive conduct in airline ticket cancellation charges

In Re: Kannadiputhur Sundararaman Suresh vs. InterGlobe Aviation Limited & Air India Limited (Case No. 42 of 2025)

The CCI, vide its order dated 11.03.2026, closed the information filed by Mr. Kannadiputhur Sundararaman Suresh ("Informant") alleging contravention of Sections 3 and 4 of the Act against InterGlobe Aviation Limited ("Indigo") and Air India Limited ("Air India") in relation to allegedly excessive and unfair cancellation charges levied on domestic air tickets.

The Informant alleged that Indigo (with approximately 65% market share) and Air India (with approximately 27% market share) together controlled over 90% of the domestic aviation market. Both Indigo and Air India, individually and in concert, imposed arbitrary, unconscionable and discriminatory cancellation fees, amounting to abuse of dominant position and anti competitive conduct. Additionally, the Informant submitted that such cancellation charges were in violation of Section 74 of the Indian Contract Act, 1872, as they far exceeded any "reasonable compensation" for alleged loss, especially where tickets were cancelled within minutes of booking. Relying on his own booking experience, the Informant further highlighted that after cancelling two tickets within minutes of purchase due to a booking error, he received a refund of only INR 3,054/- out of INR 12,488/-, with deductions amounting to over 75% of the fare.

The CCI, in its analysis, noted that the Informant had failed to produce any evidence to show an agreement or concerted action in terms of Section 3 of the Act between Indigo and Air India, and observed that mere similarity in pricing or business practices is insufficient to establish collusion. With respect to allegations pertaining to abuse of dominant position, the CCI dismissed the same as the concept of collective dominance or duopoly dominance is not recognized under the Act. Additionally, the CCI also observed that airlines offer multiple fare categories, including refundable and non refundable options, with cancellation and refund terms disclosed upfront and applied uniformly to all passengers. Therefore, variations in refunds received by the Informant were attributable to factors such as fare type and proximity to the travel date, rather than any unfair or discriminatory conduct. Regarding Informant's grievances relating to contractual fairness or reasonableness of compensation under the Indian Contract Act, the CCI noted that the same fall outside its jurisdiction, and that dissatisfaction with contractual terms does not, by itself, amount to a competition law violation. Accordingly, finding no prima facie case of contravention of Sections 3 or 4, the CCI closed the information under Section 26(2) of the Act.

CCI closes abuse of dominance case against BookMyShow in online movie ticketing market

In Re: Showtyme (through Vijay Gopal) vs. Big Tree Entertainment Pvt. Ltd. (BookMyShow) (Case No. 46 of 2021)

The CCI, vide its Order dated 12.03.2026, closed the information filed by Showtyme against Big Tree Entertainment Pvt. Ltd. ("BookMyShow") under the Act, finding no contravention of the provisions of Section 4 of the Act in relation to alleged abuse of dominant position through exclusive agreements and discriminatory conditions in the online movie ticketing market. The CCI in the said order examined alleged exclusive agreements between BookMyShow and single screen cinemas, theatres and multiplexes, executed for a period of 2-5 years. The CCI analyzed if the same imposes any unfair and discriminatory conditions or results in denial of market access in contravention of provisions of Section 4(2)(a)(i), 4(2)(b)(i) and 4(2)(C) of the Act. An investigation into the allegations was directed by the CCI vide its prima facie Order dated 16.06.2022.

In its analysis, the CCI agreed with the findings of the Director General ("DG") that booking of movie tickets through box-office and online ticket booking through various platforms including website or application is not substitutable and defined the relevant market as "market for online intermediation services for booking of movie tickets in India". In view of BookMyShow's substantial and sustained market share, its scale of operations, network effects, economic strength and presence over time, the CCI concurred with DG's findings that BookMyShow is dominant in the said relevant market. However, with respect to allegations pertaining to agreements with single screen cinemas, the CCI disagreed with the findings of the DG and found reservation of minimum number of inventory / seats for BookMyShow's platform to be justified to prevent overlapping of booking of tickets. Further, with respect to allegations pertaining to discrimination in ownership and exclusivity over customer data by BookMyShow in its agreements with single screen and multiplexes, the CCI held that the provisions of Section 4(2)(a)(i) are not attracted as the alleged discrimination is between the "single screen cinemas" and "multiplexes" which are not similarly situated. The CCI stated that the said provision prohibits unequal treatment only among 'like' entities. As the cinemas, in the present scenario, are not on the same footing, the CCI found no contravention. Similarly, the allegations of discrimination in sharing revenue between single screen cinemas and multiplexes were also rejected by the CCI. Lastly, with respect to allegations pertaining to denial of market access resulting from exclusivity and lock-in period of 2-5 years, the CCI found such lock-in period to be justified for enabling BookMyShow to recoup its financial outlay in view of security deposits extended to the cinemas.

In view of the above observations and findings, the CCI found no contravention of provisions of Section 4 of the Act and accordingly closed the matter.

CCI closes abuse of dominance case against Google India in Android app store market

In Re: M/s Zucol Solutions Private Limited vs. Google India Private Limited (Case No. 17 of 2025)

The CCI, vide its Order dated 24.03.2026, closed the information filed against Google India Private Limited ("Google") under Section 26(2) of the Act, finding no prima facie case of contravention of Section 4 of the Act in relation to alleged arbitrary termination of developer accounts on the Google Play Store. An information was filed by M/s Zucol Solutions Private Limited ("Informant"), a digital distribution platform on Google's Play Store after being aggrieved by the termination of its developer account by Google and alleged non-redressal of its appeal against the same.

In its prima facie analysis, the CCI defined the relevant market as the "market for app stores for Android OS in India" and observed Google's dominance therein. However, the CCI noted material inconsistencies in the Informant's submissions, including contradictory statements regarding the impugned application, failure to furnish complete communication records, and suppression of key facts such as reinstatement of the developer account. The CCI further observed that Google acted in accordance with its published policies, provided an opportunity to appeal, and subsequently reinstated the primary account.

In its analysis, the CCI delineated the relevant market as the "market for app stores for Android OS in India", consistent with its earlier decisional practice. Considering Google Play Store's overwhelming market share, high entry barriers, and the limited substitutability of alternative app distribution channels, the CCI reaffirmed Google's dominance in the said relevant market. However, while examining the alleged abusive conduct, the CCI noted serious inconsistencies, contradictions, and suppression of material facts on the part of the Informant. The CCI observed that Informant had provided conflicting submissions regarding the ownership and development of the impugned application, failed to identify the alleged external contractual developer, selectively disclosed email correspondence, and withheld material facts including reinstatement of its primary developer account by Google in September 2025. The CCI also took adverse note of the Informant's attempts to open multiple related developer accounts despite explicit warnings from Google, leading to their termination under the Relation Ban Policy. The CCI further accepted Google's explanation that termination of the developer accounts was carried out in accordance with publicly disclosed and uniformly applicable Play Store policies, including the Malware Policy, Deceptive Behavior Policy, and Relation Ban Policy, which are aimed at safeguarding platform integrity and user security. Lastly, the CCI noted that the primary relief sought by the Informant i.e., reinstatement of the developer account had already been granted by Google, and that Informant had failed to resubmit its applications thereafter. The CCI found no evidence of denial of market access, discriminatory treatment, or exclusionary conduct resulting in appreciable adverse effect on competition. Therefore, the CCI found no prima facie case of abuse of dominance under Section 4 of the Act and accordingly closed the matter under Section 26(2) of the Act.

CCI closes bid rigging allegations in smart meter procurement by Bangalore Electricity Supply Company

In Re: Mahesh N R vs. Bangalore Electricity Supply Company & Ors. (Case No. 25 of 2025)

The CCI, vide its Order dated 25.03.2026, closed the information filed under Section 26(2) of the Act, holding that no prima facie case of contravention of Section 3 of the Act was made out against Bangalore Electricity Supply Company Limited ("OP-1") and the other opposite parties.

The information was filed by Mr. Mahesh N R ("Informant") against OP-1, M/s Rajashree Electrical Davangere ("OP‑2") and M/s VR Patil Vividh Vidyuth Nirman Pvt. Ltd. ("OP‑3"), alleging bid‑rigging, collusive tendering and exclusionary conduct in relation to OP-1's tender for procurement of smart meters and appointment of an Advanced Metering Infrastructure ("AMI") service provider in Karnataka. The Informant, a consumer of OP-1, contended that the impugned tender was structured in a manner that unduly favoured OP‑2 and OP‑3, resulted in inflated procurement costs, and would ultimately burden consumers through higher charges.

At the prima facie stage, the CCI observed that the Karnataka Transparency in Public Procurement Act, 1999 permits procurement entities to modify tender conditions to suit their requirements, and OP-1's actions fell within this legal framework. In its analysis, the CCI found no material evidence of any agreement, coordination, or concerted conduct between the bidders or with OP-1 to establish bid‑rigging under Section 3(3)(d) of the Act. The CCI also held that allegations of excessive pricing were unsubstantiated, noting variations in tender scope, quantities, and life‑cycle periods across States. Emphasizing that competition law does not act as an appellate forum for procurement decisions in the absence of anti‑competitive conduct, the CCI concluded that no prima facie case was made out and accordingly closed the matter under Section 26(2) of the Act, without granting any interim relief.

CCI closes abuse of dominance allegations against Rapido in bike‑taxi operations

In Re: Vedansh Pandey vs. Roppen Transportation Services Private Limited (Rapido) (Case No. 31 of 2025)

The CCI, vide its Order dated 17.03.2026, closed the information filed by Vedansh Pandey ("Informant") against Roppen Transportation Services Private Limited ("Rapido") under Section 26(2) of the Act. The Informant, a Director of Mantramugdh Communications and Consultancy (OPC) Private Limited, which operates a licensed app based two wheeler taxi aggregation service in Uttarakhand, alleged that Rapido, a technology based intermediary facilitating app based two wheeler passenger transport and parcel delivery services, had engaged in anti competitive conduct in violation of Sections 3 and 4 of the Act.

The allegations arose out of a covert audit conducted by the Informant in Dehradun, Rishikesh and Tapovan between 21.07.2025 and 24.07.2025, which purportedly revealed that Rapido was facilitating bike taxi services using privately registered (white plate) motorcycles, without requisite transport permits, commercial insurance or fitness certifications, and allegedly enabling evasion of regulatory enforcement. It was contended that such practices reduced Rapido's operating costs, enabled below cost pricing, led to diversion of demand from compliant competitors, and resulted in denial of market access, thereby amounting to predatory pricing and exclusionary conduct under Section 4. Additionally, the Informant also alleged the existence of a hub and spoke arrangement and claimed significant business losses due to Rapido's conduct.

At the prima facie stage, the CCI observed that the core grievance related to alleged violations of transport and permit regulations, is governed by the Motor Vehicles Act, 1988 and allied state rules, which fall outside the scope of the Competition Act. The Commission noted that the information was devoid of material evidence demonstrating any anti competitive agreement under Section 3 or abuse of dominance under Section 4 of the Act. Accordingly, the CCI found no prima facie competition concern and closed the matter.

Combinations Approved by CCI

1. CCI approved the proposed subscription to equity share capital of Aditya Birla Renewables Limited by GIP EM Star Pte. Ltd. ¹
2. CCI approved the proposed acquisition of up to 10.71% shareholding in Curefit Healthcare Private Limited by MacRitchie Investments Pte. Ltd. ²
3. CCI approved the proposed acquisition of businesses of four road and highway assets by Cube Highways and Infrastructure V Pte. Ltd. ³
4. CCI approved the proposed acquisition of commercial real estate and related assets (i) Bagmane Developers Private Limited; (ii) Bagmane Rio Private Limited; and (iii) Bagmane Green Power LLP, by Bagmane Prime Office REIT. ⁴
5. CCI approved the proposed acquisition of additional shareholding in Baby Memorial Hospital Limited and subsequent acquisition of stake in Unimed Health Care Private Limited by Bentley Asia Holdings II Pte. Ltd. ⁵
6. CCI approved the proposed acquisition of minority shareholding in Balaji Wafers Private Limited by General Atlantic Singapore BWP Pte. Ltd. ⁶
7. CCI approved the proposed acquisition of additional shareholding in Valuedrive Technologies Private Limited (Spinny) by Setu AIF Trust, Konark Trust and MMPL Trust. ⁷
8. CCI approved the proposed merger of Udemy, Inc. with Chess Merger Sub, Inc. (wholly owned subsidiary of Coursera, Inc.) resulting in acquisition of sole control of Udemy by Coursera, Inc. ⁸
9. CCI approved the proposed acquisition of shareholding in Shriram Finance Limited by MUFG Bank Ltd. ⁹
10. CCI approved the proposed acquisition of additional shareholding in Generali Central Insurance Company Limited and Generali Central Life Insurance Company Limited by Central Bank of India. ¹⁰
11. CCI approved the proposed acquisition of shareholding in Groww Asset Management Limited by State Street Global Advisors, Inc. ¹¹

Deemed Approvals

1. Summit Asia Investments Holdings Pte. Ltd. received deemed approval of the CCI for acquisition of additional equity shares in the Liberty General Insurance Limited by way of a secondary purchase from Diamond Dealtrade Limited. ¹²
2. CA Sardo Investments and Salisbury Investments Private Limited received deemed approval in relation to certain inter-connected steps resulting in the acquisition of certain shareholding of Nido Home Finance Limited. ¹³
3. Panther Asia Holdings II Pte. Ltd. received deemed approval of the CCI for acquisition of certain shareholding in - (i) Allfleet India Private Limited; and (ii) PMI Electro Mobility Solutions Private Limited. ¹⁴

Mark Your Calendar: Upcoming Events!

• The IBA Communications and Competition Law Conference 2026 organised by the International Bar Association, scheduled for April 27-28, 2026 in Singapore. (click here)
• The International Conference on Antitrust and Competition Law (ICACL) 2026 organised by the World Academy of Science, Engineering and Technology, scheduled for April 20-21, 2026 in New York. (click here)

Footnotes

1. C-2026/01/1365

2. C-2026/01/1370

3. C-2026/01/1371

4. C-2026/01/1372

5. C-2026/01/1374

6. C-2026/01/1376

7. C-2026/01/1377

8. C-2026/01/1378

9. C-2026/01/1379

10. C-2026/02/1383

11. C-2026/02/1385

12. C-2026/03/1396

13. C-2026/03/1400

14. C-2026/03/1402

Contributor to the newsletter

Rinki Singh, Senior Associate

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.