THE ICFAI UNIVERSITY, DEHRADUN

COMPETITION LAW IN INDIA, US & UK: A

COMPARATIVE STUDY

SUBMITTED TO SUBMITTED BY
Mr. Saurabh Siddhartha Ritika Shriwastav
Assistant Proff. 17FLICDDN02105
BA. LLB (Hons.)
4thrd year
 ACKNOWLEDGEMENT

At the very outset, I would like to thank all those who were the ‘guiding lights’ behind this
assignment. First of all, I would like to take this opportunity with esteem privilege to express my
heartfelt thanks and gratitude to my course teacher Mr. Saurabh Siddhartha, Faculty of Law of
Investment and Disinvestment, THE ICFAI UNIVERSITY for having faith in me in awarding
me this very significant assignment of such importance. His consistent supervision, constant
inspiration and invaluable guidance have been of immense help in carrying out the assignment
work with success. Next, I would like to thank my colleague’s for lending me a helping hand
during the shaping up of the assignment; subsequently I would like to thank my parents for
availing me the computer and internet facilities without which this assignment would have been
in a distant realm. I extend my heartfelt thanks to my family and friends for their moral support
and encouragement. I also take this opportunity to thank all those people who contribute in their
own small ways but fail to get a mention.
 INDEX

Serial No. Particulars Page No.

1. Index of Abbreviations 1
2. Introduction 2
3. Competition Law in India 2
4. Antitrust Law in the US 6
5. Competition Law in the UK 10
6. Comparison 11
7. Conclusion 13
8. Suggestions 13
9. Bibliography 14
 INDEX OF ABBREVIATIONS
US- United States
UK- United Kingdom
MRTP- Monopolies and Restrictive Trade Practices
DPSPs- Directive Principles of State Policies
MIC- Monopolies Inquiry Commission
LPG- Liberalization, Privatization and Globalization
CCI- Competition Commission of India
FTC- Federal Trade Commission
DoJ- Department of Justice
ALJ- Administrative Law Judge
DG- Director General
OFT- Office of Fair Trading
CMA- Competition and Market Authority

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INTRODUCTION
Competition is “a situation in a market in which firms or sellers independently strive for the
buyers’ patronage in order to achieve a particular business object for example, profits, sales or
market share.”
-World Bank (1999)
Competition law is structured to promote and provide a fair chance for healthy competition
between contending competitors in the market and to protect the consumer’s interest. It deals
with market failures on account of restrictive business practices in the market. The history of
competition law is usually traced back to the enactment of Sherman Act in 1890 in the US. 1
Gradually, competition law came to be recognized as one of the key pillars of a market economy.
This recognition led to enactment of competition law in many countries including in UK as The
Fair-Trading Act, 1973 and in India as MRTP Act, 1969.
Competition in the market means competing for quality, price and resources, leading to a market
oriented towards consumer right, fair trade, and efficient resource allocation, development of
small businesses, incentives for innovation and dispersion of economic power. It is precisely for
the benefits emanating out of competitive markets that they have been perceived to promote
economic development. This project would aim to analyze competition law and its enforcement
in three jurisdictions- India, US and UK giving a comparative breakdown of the competition law
in these countries, along with conclusive suggestions.
COMPETITION LAW IN INDIA
Background of MRTP Act, 1969
The Government of India had been deeply concerned with the control of concentration of wealth
and removal of economic disparities among the people. The MRTP Act, 1969 was brought into
force for realizing the explicit mandate set out in DPSPs, namely, the prevention of concentration
of economic power. The Industrial Policy of 1956 emphasized growth, social justice and self-
reliance. The licensing policy of the government favored big business houses as they were in
better position to raise large amount of capital and had managerial skills to run the industry. With
no proper system of allocating licenses in place, licensing authorities were naturally inclined to
prefer men who prove their ability but success in big business ventures. The system of control in

1 Paul Cook, Competition and its Regulation: Key Issues.

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shape of industrial licensing restricted the freedom of entry into the industry apart from
concentration of economic power in a few individuals or group of business houses.
Background of Raghavan Committee
The Raghavan Committee under the Chairmanship of Mr. S B Raghavan was appointment in
October 1999. The Committee came to the finding that MRTP Act, 1969 to be falling short of
squarely addressing anti-competition practices. The committee desired the focus of the new law
to be on preventing anti-competitive practices that reduce welfare while free markets produced
desired outcomes, they do so only when protected from abuse. Therefore, “the only legitimate
goal of competition law is the maximization of economic welfare.” Based on this analysis, the
Committee found that it is expedient to have a new competition law. The Competition Act was a
part of India’s economic reform and globalization process which necessitated aligning of the
economic laws of the country with the new economic scenario. The factors that gave rise to the
trigger for the transformation from the MRTP Act to the Competition Act are:
i. Recommendation by the expert group;
ii. Recommendation of high-level committee;
iii. The consumer among those who put forward their views and opinions before the
high-level committee for repealing MRTP and substituting it with Competition Act;
iv. Appreciation of the fact that MRTP Act was more concerned with curbing
monopolies rather than promoting competition;
v. MRTP Act was enacted to serve the needs of the command and control economy and
that a new law was needed;
vi. There was an unbridgeable mismatch between MRTP Act and the changing economic
environment brought about by the policies of LPG;
vii. The recommendation of the Standing Committee of the Parliament.

Primarily, there are three main elements which are intended to be controlled by implementation
of the provisions of the Act, which are specifically addressed under Sections 3, 4 and 6 read with
Sections 19 and 26 to 29 of the Act. They are anti-competitive agreements, abuse of dominant
position and regulation of combinations which are likely to have an AAEC.
The objectives of the Act are sought to be achieved through the instrumentality of the CCI which
has been established by the Central Government. Hence the Commission is required to require

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care of such situation in order that there couldn't be created market failure thereby causing harm
to plug. To achieve its objectives, CCI endeavors to do the following:
● Make the markets work for the benefit and welfare of consumers.
● Ensure fair and healthy competition in economic activities in the country for faster and
inclusive growth and development of economy.
● Implement competition policies with an aim to effectuate the most efficient utilization of
economic resources.
● Develop and nurture effective relations and interactions with sectoral regulators to ensure
smooth alignment of sectoral regulatory laws in tandem with the competition law.
● Effectively carry out competition advocacy and spread the information on benefits of
competition among all stakeholders to establish and nurture competition culture in Indian
economy.
Anti-Competitive Agreements
The term anti-competitive agreements as such have not been defined by the Act. However,
Section 3 prescribes certain practices which can be anti-competitive and therefore the Act has
also provided a good definition of agreement under section 2(b). Section 3(1) may be a general
prohibition of an agreement concerning the assembly, supply, distribution, storage, acquisition or
control of products or provision of services by enterprises, which causes or is probably going to
cause an AAEC within India.
Competition law places anti-competitive agreements in two categories namely- horizontal
agreements and vertical agreements. Horizontal agreements are generally viewed more seriously
than the vertical agreement. The former is those among competitors and the latter are those
relating to an actual or potential relationship of purchasing or selling to each other. A particularly
pernicious sort of horizontal agreements is that the cartel. Vertical agreements are pernicious
when they are between firms in a position of dominance.
Abuse of Dominant Position
There are primarily three stages in determining whether an enterprise has abused its dominant
position. The first stage is defining the relevant market. The second is determining whether the
concerned undertaking/enterprise/firm is during a dominant position/ features a substantial
degree of market power/ has monopoly power therein relevant market. The third stage is that the
determination of whether the undertaking during a dominant position/ having substantial market

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power/monopoly power has engaged in conducts specifically prohibited by the statute or
amounting to abuse of dominant position/monopoly or plan to monopolize under the applicable
law.
The Indian Competition Act contains a definition of dominant position that takes under
consideration whether the concerned enterprise is in such an edge of economic strength that it
can operate independently of competitive forces or can affect the relevant market in its favor.
Explanation (a) to Section 4 of the Indian Competition Act defines dominant position as
―dominant position means an edge of strength, enjoyed by an enterprise, within the relevant
market in India, which enables it to-24
i. Operate independently of competitive forces prevailing in the relevant market, or
ii. Affect its competitors or consumers or the relevant market in its favor.
Combinations
One of the most significant provisions of the Competition Act is Section 5 which defines
'combination' by providing threshold limits in terms of assets and turnover but it is yet to be
notified. There is no clarity on when it'll be made effective. At present, any acquisition, merger
or amalgamation falling within the ambit of the thresholds constitutes a mixture.
Regulation of Combinations
Essentially, a transaction must satisfy two conditions before Section 6 is triggered:
i. It must involve total assets or turnover with separate criteria for domestic and international
entities; and
ii. It must have a territorial nexus with India.
Under the originally enacted Competition Act, 2002, the reporting of a mixture was optional.
However, the Act now mandates notification within 30 days of the choice of the parties' boards
of directors or of execution of any agreement or other document for effecting the combination.
Regulation of Combinations
Essentially, a transaction must satisfy two conditions before Section 6 is triggered:
i. It must involve total assets or turnover with separate criteria for domestic and international
entities; and
ii. It must have a territorial nexus with India.
Under the originally enacted Competition Act, 2002, the reporting of a mixture was optional.
However, the Act now mandates notification within 30 days of the choice of the parties' boards

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of directors or of execution of any agreement or other document for effecting the mixture. The
general industry perception is that a memorandum of understanding or a letter of intent will
qualify as an 'agreement'. However, these are generally executed to spell out a basic
understanding among the transacting parties and to enable the acquirer to conduct due diligence,
supported which further negotiations are carried out. Going forward, execution of such a
document shall trigger merger filings. This will increase compliance costs at a premature stage
when it's uncertain whether the transaction will close. It will also add to the bulk of notification
applications submitted to CCI. It remains to be seen whether CCI will have adequate internal
capacity to handle and dispose of such applications efficiently. If it doesn't have the resources,
the delay will potentially have a cascading effect and affect the power of parties to shut on time.
Therefore, it might be prudent to insert a clause altogether future transaction documents stating
that closing is going to be subject to any prior regulatory clearance which will be required from
CCI.
ANTITRUST LAW IN THE US
Antitrust law emerged within the late 19th century within the US as a response to the expansion
of the trusts and their power within the American economy. The first law passed in the US
regarding antitrust was the Sherman Act in 1890. Since the passage of the Sherman Act, antitrust
law has always revolved around the core economic concepts of competition and market power.
The Sherman Act, by prohibiting monopolization, but not monopoly, indicates a consciousness
that the freedom of the individual right to contract is the most efficient means for the prevention
of monopoly.
Competition policy played a starring role in the enactment of the Clayton Act and the FTC Act in
1914. The Clayton Act provided for private enforcement of the antitrust laws and substantively
addressed price discrimination, tying and exclusive dealing, mergers and acquisitions and
interlocking directorates. The FTC Act created a new, independent agency and charged it with
preventing “unfair methods of competition” and with an amendment in 1938, “unfair or
deceptive act or practices”.
THE SHERMAN ACT, 1890
Sherman Act declared illegal all contracts, combination or conspiracies in restraint of trade or
commerce among the states or territories or with foreign nations. The basic requirement is that

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there should be an agreement or mutual commitment to engage in a common course of anti-
competitive conduct.
Monopolize and Conspiracy to Monopolize
Section 2 outlawed (a) Monopolization (b) Attempt to monopolize (c) conspiracies to
monopolize. This section has two basic elements:
i. Possession of monopoly power in relevant market
ii. The willful acquisition or maintenance of the power
A person isn't guilty of monopolization unless he has monopoly power i.e. power to control
prices and exclude competition. Therefore, offence of monopolization requires monopoly power
and intention to monopolize, but there's no monopolization if the defendant’s monopoly power
grows as a consequence of superior product, business acumen or historical accident. Sherman
Act prescribes even attempt to monopolize. The difference between actual monopolization and
plan to monopolization is that in actual monopolization general intent to try to to act is required
but in plan to monopolize specific intent, which can be established by evidence of unfair tactics
on a part of defendant, is required. To establish conspiracy to monopolize three basic items are to
be proved:
i. Proof of conspiracy
ii. Specific intent to monopolize
iii. An overt act in furtherance of conspiracy and there is no need to establish the market power.
Price Fixing
Section 1 mentions that dissemination or exchange of price information does not itself establish a
violation of section 1 rather price information coupled with criminal intent to fix the price
violates section 1 of Sherman Act. However, a mixture or conspiracy within section 1 is
established where an agreement exists between competitors to furnish price information upon
request.
Tying Agreement
The Sherman Act has very well explained tying agreements. It defines “Tying Agreements” as
an agreement by a party to sell one product but only on the condition that the buyer also
purchases a different product or agree that he won't buy that product from another supplier.
Tying agreements are not illegal per se. An illegal tying agreement takes place when a seller

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requires a buyer to get another, less desired or cheaper product, additionally to the specified
product, in order that the competition in the tied product would be lessened.
Group Boycott
Sherman Act features a special category under refusal to deal called as Group Boycott. It has
explained various conditions of group boycott. In case of horizontal restraints, per se rule is
applicable but in case of vertical restraints majority courts view is that per se rule is not
applicable. There are many sorts of group boycott:
i. Group boycott of competitor i.e. joint effort by a firm with dominant market position to
disadvantaged competitors violates section 1 of the Sherman Act.
ii. An agreement among competitors to stop selling to certain customers is illegal.
iii. Boycott by physician, doctors, advocates of a particular customer are unlawful.
iv. Customer boycott of supplier may or may not, on the basis of circumstances, violate Sherman
Act.
Amalgamation
As per the Sherman Act, an amalgamation is unlawful in two ways, firstly, if the amalgamation
eliminates substantial competition and secondly, if it created a monopoly. Basically, there are
two types of amalgamation: horizontal and vertical. In horizontal amalgamation, two companies
are the major competitive factor in a relevant market and a merger or consolidation between
them violates the Sherman Act if such action ends the competition. However, if a corporation is
losing money and has decided to finish up then its horizontal amalgamation isn't illegal. In
vertical amalgamation, it is not illegal unless its illegality turns on the following:
i. The purpose or intent with which it was conceived;
ii. The power it creates in the relevant market
THE CLAYTON ACT, 1914
After the Sherman Act to supplement this Act, there was another Act which was enacted in 1914
named as the Clayton Act.
Mergers
This Act has defined vertical and horizontal mergers. Vertical merger is a merger of buyer and
seller while horizontal merger is a merger which is of direct competitors. A merger which is
neither vertical nor horizontal is conglomerate merger. A per this Act a pure conglomerate
merger is one in which there I no relationship between the acquiring and the acquired firm.

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Amalgamations
This Act has also defined the horizontal and vertical amalgamations, product extension merger
and joint ventures. Amalgamations between firms performing similar functions within the
production or sale of comparable goods and services are referred to as the horizontal
amalgamation. This Act has also mentioned about the burden of proof in horizontal
amalgamation. It points out that by showing that a horizontal acquisition will cause undue
concentration within the marketplace for a specific product during a particular market; the govt
establishes a presumption that the transaction will lessen the competition. The burden of
manufacturing evidence to rebut this presumption then lies with the defendants. This Act does
not outlaw all vertical amalgamations but it forbids those whose effect may be substantially to
lessen competition or tend to create monopoly in any line of commerce in any section of the
country.
Intention
The Clayton Act also talks about the intention of the parties. As per this Act good intention of
parties is no defense to a charge of violating the Act and thus will not validate an otherwise
anticompetitive practice.
THE FTC ACT, 1914
The FTC Act created the FTC and gave it concurrent power to enforce the Sherman Act and the
Clayton Act through use of civil remedies. Only the courts, acting in response to charges brought
by the DoJ, have the power to impose the criminal penalties authorized by the antitrust laws.
Generally, FTC has the same powers as DoJ but it also has three unique powers:
i. The power to enforce a statutory prohibition on unfair methods of competition, and unfair or
deceptive acts or practices;
ii. The power to obtain a court order temporarily enjoining conduct that violates the antitrust
laws by meeting a standard that is less demanding than the standard DoJ must meet to obtain
such an order; and,
iii. The power to conduct hearings to decide whether a firm has violated the antitrust law in-
house before one of the FTC’s ALJ instead of asking a court to make that decision.
The first unique power has rarely been used. FTC uses the second and third powers with great
frequency but both are controversial.

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After decades of controversy and uncertainty, a consensus developed among US enforcement
agencies after federal courts about forty years ago that the antitrust laws should be interrupted
and implemented to maximize social welfare through application of principles of
microeconomics. As a result, they are implemented with the goal of protecting the performance
of competitive markets and not with the goal of protecting competitors. That distinction has
important implications. Thus, for instance, US Antitrust Law recognizes that so-called
“predatory pricing” should not be discouraged because it is almost always a symptom of a
properly performing competitive market, and that price discrimination often ha beneficial effects
on the performance of a market.
COMPETITION LAW IN THE UK
THE FAIR-TRADING ACT, 1973
This Act was passed in England with a view to supply an environment for free of charge
competition. This Act basically focused on the restriction of monopoly. There is monopoly when
a person or group of persons tries to secure the sole exercise of any known trade throughout the
country. However, there are certain monopolies authorized by the status e.g. Post office with
respect to carrying of letters. If there's an agreement which provides control of trade to a private
or group of people then it creates a monopoly calculated to reinforce prices to an unreasonable
extent. It is no monopoly if the control is lawfully obtained by particular persons on particular
places or sorts of articles that a substitute is out there.
THE COMPETITION ACT, 1998
The Competition Act of 1998 repealed the Fair-Trading Act, 1973. This Act was divided into
two parts- firstly, Chapter 1 prohibitions and secondly, Chapter 2 prohibitions.
Chapter 1 prohibitions prohibit the agreements which fix prices, control production, share market
or sources of supply, apply dissimilar conditions to equivalent transactions and make the
conclusion of contracts subject to acceptance by other parties of supplementary obligations
which naturally of economic usage haven't any reference to the topic of such contracts. All such
agreements are unlawful.
Chapter 2 prohibitions: “Any undertaking which amounts to the abuse of dominant position is
prohibited if it consists in:
● Imposing unfair purchase or selling prices
● Limiting production, market or technical development
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● Applying dissimilar conditions to equivalent transactions with other trading parties
● Making the conclusion of contracts subject to acceptance by other parties of supplementary
obligations having no connection with the subject of contracts.”

COMPARISON
Enforcement Structure
As against the Indian framework comprising single legislation and single agency, the US
enforcement framework comprises multiple agencies and legislation. In the US, two federal
agencies bear the major responsibility of enforcing antitrust laws, the Antitrust Division of the
US DoJ and FTC. The former is part of the executive branch of the government and the latter is
an independent administrative agency, similar to the CCI. The Sherman Act is the oldest federal
antitrust statute, enacted in 1890 and deal primarily with anti-competitive agreements and
monopoly exercised by firms. The Clayton Act, 1914 deals with specific business practices
including mergers, price discrimination and tying, exclusive supply, etc. The DoJ and FTC
independently enforce the Sherman Act and therefore the Clayton Act. However, if the violation
entails criminal prosecution, then the DoJ has the exclusive authority to prosecute.
Though India follows the same line of enforcement authorities, still there are few differences
between the enforcement mechanism of competition law between UK and India. They are as
follows:
Indian Competition Act though talks about investigation but unlike UK Competition Act, it does
not talk about the power of the enforcement authority to enter the business premises as talked
about in Section 27 and 28. Non-inclusion of such provision in Indian Competition Act can
affect the investigation process to a very large extent.
The concept of privileged communication as provided under Section 30 is also not included in
the Indian Competition Act. This non-inclusion can affect the rights of undertakings or legal or
natural persons who are undergoing investigation.
Anti-Competitive Agreements

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Section 3(1) of the Indian Competition Act prohibits any agreement with respect to “production,
supply, distribution, storage and acquisition or control of goods or services which causes or is
likely to cause an appreciable adverse effect on competition within India.” The corresponding
provisions are found in Section 1 of the Sherman Act and Section 2 of the Competition Act of
UK.
The term AAEC is not defined in the Act. However, Section 19(3) of the Act specifies certain
factors for determining AAEC. The intent of legislature reflected vide the mandatory language of
Section 19(1) of the Act is that the CCI is required to carry a balanced assessment of anti-
competitive effect as well as pro-competitive justification of the agreement. This balancing
approach under the Act is similar to the rule of reason analysis found in the competition law
jurisprudence of the US and the UK.
The Act doesn't characterize agreement into horizontal or vertical category however, the
language of Section 3(3) and 3(4) makes it abundantly clear that the previous is aimed toward
horizontal agreements and the latter at vertical agreements. Horizontal agreements defined under
Section 3(3) of the Act are presumed to possess AAEC within India a distinguished from all
other agreements which has got to be analyzed in accordance with the rule of reason analysis
under the Act.
Abuse of Dominance
Section 4(1) of the Act prohibits any enterprise from abusing its dominant position. The list of
abusive activities under the Act covers both exploitative abuses also as exclusionary abuses. The
list of abusive practices under the Act is almost a replica to those listed in Section 18 of the
Competition Act of UK. Section 2 of the Sherman Act prohibits monopolization or attempted
monopolization. As distinguished from the Act, the Sherman Act doesn’t lay down the list of
conduct that shall constitute as monopolization or attempted monopolization. The US Supreme
Court lays down that, at its core, Section 2 makes it illegal to accumulate or maintain monopoly
power through improper means. Similar to the UK and US, determination of relevant product
and geographic market is the starting point of investigation under the Act.
Merger Regulation
Section 5 and 6 of the Act are the operative provisions for the regulation of combination. The
CCI has notified the procedure vide Combinations regulations, 2011. The Act alongside the
mixture Regulation provides an exhaustive framework for the merger regulation in India. The

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combination as defined under the Act includes ‘acquisition’, ‘acquiring of control’ and any
‘merger or amalgamation’ of one or more enterprise by one or more persons. The Act sets a
threshold, below which a combination is not regarded as a combination and therefore it is outside
the merger regime of the Act. The threshold is defined in terms of assets or turnover. The
threshold varies counting on whether the mixture involves an enterprise or a gaggle or whether
the enterprise or group has assets or turnover only in India or worldwide. The mergers in the US
are regulated by the Clayton Act, further amended by the Hart-Scott-Rodino Antitrust
Improvements Act of 1976. Section 7 prohibits mergers which are likely to substantially lessen
competition or tend to create a monopoly. The major difference between the US and Indian
system is that CCI being an administrative unit is empowered to approve or prohibit merger
whereas the US system being judicially driven, requires the agencies to approach federal courts
to enjoin a merger.
The merger control in UK is regulated by the CMA, following the merger of the OFT and the
Competition Commission. The CMA has strong powers of investigation and takes a proactive
approach to enforcing UK competition law.
CONCLUSION
Competition Law is a complex mixture of a country's law, economics and administrative action
intended to favor competition in the economy. Since competition is seen as critical to economic
development, competition law seeks to guard this competitiveness within the economy. The
underlying theory behind competition law is that the positive effect of competition in an
economy's market, acting as a safeguard against misuse of economic power. The link between
competition law and economic development emphasized over and once again seems rather
undeniable and therefore the need for competition law looks like the order of the day. The
operation of competition law by prevention of anti-competitive agreements, prohibiting abuse of
dominant position by firms and regulation of combinations which could adversely affect
competition within the economy, thus seems crucial for India as well.
During the past years, the number of jurisdictions with a contest law has exploded from
approximately 25, of which few were seriously enforced, to far more than 100 today. With
economic activity increasingly transcending national borders, and jurisdictions applying
competition laws to firms and conduct outside their borders, achieving a minimum of an

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inexpensive degree of coherence and convergence in the application of competition laws is vital
for both competition agencies and firms.
SUGGESTIONS
A few amendments that could be added to the Competition Act can be as follows:
● Abbreviated rule of reason can be developed especially with regard to cartel cases.
● Outer limit of 210 days is given to the CCI under the Competition Act, 2002. However, CCI
aims at clearing at notices within 180 days. They may lead to unnecessary delays and back logs.
● Threshold limits for trigging Competition Act are very high especially with regard to a country
like India where small industries are prevalent. Hence, it should be taken into consideration that
there might be many mall enterprises entering into mergers which may have AAEC but may not
trigger the combination regulations under Section 5.
● Leniency provisions have been prevalent in India since the beginning of the Act but there has
been no instance of anyone coming to claim them. The penalties under the Act should be hiked
during this case in order that a deterrent effect is made and leniency provisions are made
attractive.

BIBLIOGRAPHY
Articles
● Chatterjee Payal & Gautam Shashank, Competition Law in India vs USA and EU.
● Pierce Richard J, Comparing the Competition Law regimes of the United States and
India, (2017).
● Dhall Vinod, The Indian Competition Act, 2002, Competition Law Today: Concepts,
Issues and Law in Practice, Oxford University Press, (2007), Pg 499-540.
● Fox Eleanor M, World Competition Law- Conflicts, Convergence, Cooperation,
Competition Law Today: Concepts, Issues and Law in Practice, Oxford University Press,
(2007) Pg 224-249.
Webliography
● http://www.oft.gov.uk/
● http://www.cci.gov.in/
● http://ec.europa.eu/comm/competition/index_en.html

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● http://www.internationalcompetitionnetwork.org/
● http://www.wto.org/
● http://www.competition-commission.org.uk/
● http://www.oecd.org/home/

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