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Leading cases on competition law

Competition Law · Unit V · Topic 18 of 18 · 6 min read

The Supreme Court judgments that shape the Competition Act, in date order with the point each decides: Haridas Exports, Brahm Dutt, SAIL, Co-ordination Committee, Excel Crop Care, Thomas Cook, Rajasthan Cylinders, Bharti Airtel, Samir Agrawal, Mizoram, Coal India and Schott Glass, with the Google Android proceedings.

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On this page
  1. 1. Under the MRTP Act
  2. 2. Institutional cases
  3. 3. Anti-competitive agreements
  4. 4. Combinations
  5. 5. Sector regulators and jurisdiction
  6. 6. Abuse of dominance
  7. How this is examined
Cases checked to exist. Read the judgment before quoting a holding.

Every case cited here has been checked to exist — the citation resolves and names the right parties. The propositions attributed to each case have not been verified line by line against the judgment. Case names link through to the full judgment: read it before quoting a holding in an examination answer, and never carry a proposition from notes into court on trust.

How to use this note. The syllabus lists “Case Law” as a Unit V item, and the papers set case notes (Haridas Exports, January 2026). Each entry below gives the facts in a line, the holding, and the topic it belongs to. Learn the holding and the section: a case note that gives facts but not the rule earns half marks. Holdings are stated only to the extent they are settled.

1. Under the MRTP Act

Haridas Exports v. All India Float Glass Manufacturers’ Association, 2002 INSC 306, (2002) 6 SCC 600. Indian float glass makers asked the MRTP Commission to restrain imports of cheap glass by an importer. The Supreme Court held that the MRTP Commission has jurisdiction over a restrictive trade practice that has effects in the Indian market even when the agreement or parties are abroad, but that the import of goods at low prices is not by itself a restrictive trade practice: low prices benefit consumers, and the Commission could not prohibit imports merely because they were cheap. Use: the effects doctrine (now section 32) and the gap on predatory pricing that section 4 of the 2002 Act filled.

2. Institutional cases

Brahm Dutt v. Union of India, decided 20 January 2005, (2005) 2 SCC 431. A writ petition challenged the appointment of a bureaucrat as Chairperson of a Commission exercising adjudicatory functions. On the Union’s statement that it would amend the Act and create an appellate body, the Court disposed of the petition. Use: the reason for the 2007 amendment and COMPAT.

Competition Commission of India v. Steel Authority of India Ltd., 2010 INSC 587, (2010) 10 SCC 744. Jindal Steel complained that SAIL’s exclusive supply arrangement with Indian Railways abused its dominance. Held: (i) a direction to investigate under section 26(1) is administrative, needs no prior hearing and is not appealable; (ii) interim orders under section 33 are to be passed sparingly, in exceptional cases, on recorded reasons showing a contravention and irreparable harm; (iii) the Commission is a necessary or at least proper party in appeals against its orders. Use: CCI procedure, interim orders, appeals.

3. Anti-competitive agreements

CCI v. Co-ordination Committee of Artists and Technicians of W.B. Film and Television, 2017 INSC 211. Associations in the Bengali film and television industry forced a channel to stop telecasting a dubbed serial. The Supreme Court restored the CCI’s finding of a contravention of section 3(3)(b) (limiting supply of services). Use: boycotts by associations.

Excel Crop Care Ltd. v. Competition Commission of India, 2017 INSC 1286, (2017) 8 SCC 47. Suppliers of aluminium phosphide tablets bid identically in FCI tenders and boycotted one. Held: a cartel and bid rigging were proved; the Act applies to conduct continuing after 20 May 2009; the DG may investigate related conduct coming to light; penalty is on relevant turnover. Use: cartels, DG powers, penalty (with the 2023 global turnover amendment).

Rajasthan Cylinders and Containers Ltd. v. Union of India, 2018 INSC 916. LPG cylinder makers bidding in an IOCL tender quoted similar prices. Held: in an oligopsony where a dominant buyer sets conditions and cost-based prices, similar bids from a few suppliers with similar costs can be explained by market structure; collusion was not established. Use: parallel conduct is not enough.

Samir Agrawal v. Competition Commission of India, 2020 INSC 700. Allegation of an algorithm-driven hub-and-spoke cartel among Ola and Uber drivers. Held: any person may give information to the CCI, which acts in the public interest; on the facts, no collusion was shown. Use: locus standi; hub-and-spoke (now the second proviso to section 3(3)).

Competition Commission of India v. State of Mizoram, 2022 INSC 64. Held: the CCI may inquire into alleged bid rigging by bidders for appointment as distributors of State lotteries; the lottery legislation does not oust its jurisdiction over the bidders’ collusion. Use: bid rigging in public procurement.

4. Combinations

Competition Commission of India v. Thomas Cook (India) Ltd., 2018 INSC 352. The parties notified a demerger and amalgamation but not inter-connected share acquisitions. Held: the inter-connected steps formed one composite combination; failure to notify them attracted penalty under section 43A; substance prevails over form. Use: notification and gun-jumping.

5. Sector regulators and jurisdiction

Competition Commission of India v. Bharti Airtel Ltd., 2018 INSC 1154, (2019) 2 SCC 521. Reliance Jio alleged a cartel of incumbent operators denying points of interconnection. Held: the CCI’s jurisdiction is not ousted by TRAI, but questions of licence and interconnection obligations must first be decided by TRAI; until then the CCI’s investigation was premature. Use: overlap with sector regulators; sections 21, 21A, 60, 62.

6. Abuse of dominance

Coal India Ltd. v. Competition Commission of India, 2023 INSC 580. The CCI found Coal India abused its dominance in supplying non-coking coal. Held: the Act applies to Coal India and its subsidiaries, government companies created after nationalisation; their public purpose does not take them outside the Act; section 19(4)(g) shows Parliament contemplated dominance acquired under statute or as a PSU. Use: “enterprise”; public sector dominance.

Competition Commission of India v. Schott Glass India Pvt. Ltd., 2025 INSC 668. The CCI had found abuse by volume discounts and supply terms in neutral borosilicate glass tubing; the Tribunal set this aside. Held: the CCI’s appeal is dismissed; section 4 targets abuse, not dominance; uniform, objective volume discounts are not discriminatory; abuse requires an assessment of effects on competition. Use: the effects-based approach.

Google (Android). The CCI’s order of October 2022 imposed a penalty of Rs. 1,337.76 crore for abuse of dominance in Android-related markets (mandatory pre-installation of Google’s apps as a condition of Play Store access, among others). The NCLAT in March 2023 upheld the findings of abuse and the penalty but set aside some of the directions. Appeals are pending before the Supreme Court; there is no Supreme Court ruling on the merits to cite. Use: section 4(2)(a), (c), (d) and (e) in digital markets.

Pairs that examiners like. Excel Crop Care and Rajasthan Cylinders (when similar bids prove a cartel and when they do not). SAIL and Samir Agrawal (how a case starts and who may start it). Coal India and Schott Glass (who can be dominant, and what makes conduct abusive).

How this is examined

As case notes in any unit (January 2026 set Haridas Exports in Unit III), and as authority inside essays. For a case note: one line of facts, the holding in two or three sentences with the section, and one line on its present relevance. For essays, cite at least one case per issue from the notes on agreements, dominance, combinations, the CCI and penalties.

Now try the real questions: Competition Law past question papers.