Competition Law in India - Lacunae, Complaint and Procedure

Introductioncombination in case of appreciable adverse effect on
In common parlance, competition in the marketcompetitiono May propose suitable modification as
means sellers striving independently for buyers'accepted by parties
patronage to maximize profit (or other businessThe Commission has fixed the threshold limits of such
objectives).A buyer prefers to buy a product at acombinations .In case of combination the threshold
price that maximizes his benefits whereas the sellerlimits are-
prefers to sell the product at a price that maximizesFor acquisition -o Combined assets of the firms more
his profit. Competition makes enterprises morethan Rs 1000 cr or turnover more than Rs 3000 cr
efficient and offers wider choice to consumers at(these limits are US$ 500 millions and 1500 millions in
lower prices. This ensures optimum utilization ofcase one of the firms is situated outside India).o The
available resources. It also enhances consumerlimits are more than Rs 4000 cr or Rs 12000 cr and
welfare since consumers can buy more of betterUS$ 2 billion and 6 billions in case acquirer is a group in
quality products at lower prices.India or outside India respectively.
Fair competition is beneficial for the consumers,For merger/amalgamation -o Assets of the merged
producers / sellers and finally for the whole societyamalgamated entity more than Rs 1000 cr or
since it induces economic growth. Whereas, the unfairturnover more than Rs 3000 cr (these limits are US$
competition means adoption of practices such as500 millions and 1500 millions in case one of the firms
collusive price fixing, deliberate reduction in output inis situated outside India).o The limits are more than
order to increase prices, creation of barriers to entry,Rs 4000 cr or Rs 12000 cr and US$ 2 billion and 6
allocation of markets, tie-up sale , predatory pricingbillions in case merged/amalgamated entity belongs to
and discriminatory pricing.a group in India or outside India respectively
India has been very conscious about the competitionImplementation
in the market place and has been vigilant to frameThe Commission may initiate enquiry into
laws curtailing monopolies and restrictive tradeanti-competitive agreements/abuse of dominance?o
practices The Monopolies & Restrictive TradeOn its own on the basis of information and
Practices Act, 1969 is the first enactment to dealknowledge in its possession, oro On receipt of a
with competition issues and came into effect on 1stcomplaint, oro On receipt of a reference
June 1970.Complaint procedureo Any person, consumer,
With the advent of liberalization in the economicconsumer association or trade association can make a
policy and growth in the market, the Government ofcomplaint against anti-competitive agreements and
India reviewed the implementation of Monopoliesabuse of dominant position. Here a person includes an
& Restrictive Trade Practices Act, 1969 andindividual, Hindu Undivided Family (HUF), company,
finding it lacking in grip and teeth it formulatedfirm, association of persons (AOP), body of individuals
Competition Policy. Competition policy is defined as(BOI), statutory corporation, statutory authority,
those Government measures that affect theartificial juridical person, local authority and body
behavior of enterprises and structure of the industryincorporated outside India. A consumer is also a
with the view to promote efficiency and maximizeperson who buys for personal use or for other
welfare.purposes.o The Central Government or a State
There are two elements of competition policy: First, agovernment or an authority established under any
set of policies, such as liberalized trade policy, relaxedlaw may make a reference for an enquiry.o
FDI policy, de-regulation, etc., that enhanceCommission can initiate enquiry on its own on the
competition in the markets. Second, legislation tobasis of information or knowledge in its possessiono
prevent anti-competitive practices with minimalOn its own, or receipt of complaint/ reference, if the
government interventionCommission is of the opinion that there is a prima
The Government had appointed a committee infacie case, it shall direct the Director General,
October 1999 to examine the existing MRTP Act forappointed under the Act, to investigate the matter
shifting the focus of the law from curbing monopoliesand report his findingso After receipt of the
to promoting competition and to suggest a moderninvestigation report from the Director General, the
competition law. Pursuant to the recommendations ofCommission shall adjudicate the matter after hearing
this committee, the Competition Act, 2002, wasthe parties and pass orders as deemed fit.o During
enacted on 13th January 2003. The objectives of thethe course of enquiry, the Commission can grant
Competition Act are to prevent anti-competitiveinterim relief restraining a party from continuing with
practices, promote and sustain competition, protectanti competitive agreement or abuse of dominant
the interests of the consumers and ensure freedompositiono After the enquiry, the Commission may
of trade. This Act provides for different notificationsdirect a delinquent enterprise to discontinue and not
for making different provisions of the Act effectiveto re-enter anti-competitive agreement or abuse the
including repeal of MRTP Act and dissolution of thedominant positiono To award compensationo To
MRTP Commissionmodify agreemento To recommend to the Central
The objective of the Act is to eliminate the abuse ofGovt. for division of enterprise in case it enjoys
dominance through an anti competitive tradedominant position.o The parties in person or through
agreements. Here dominance refers to a position ofauthorized representative or through a legal
strength which enables a dominant firm to operatepractitioner or a practicing Company Secretary
independently of competitive forces or to affect itsChartered Accountant/Cost and Works Accountant.o
competitors or consumers or the market in its favor.The Commission can also pass orders in case of
Abuse of dominant position impedes fair competitionanti-competitive agreements and abuse of
between firms, exploits consumers and makes itdominance.o During the course of any proceeding
difficult for the other players to compete with thebefore it, a Statutory Authority may make a
dominant undertaking on merit. Abuse of dominantreference for opinion if any party raises an issue that
position includes imposing unfair conditions or price,the decision of the authority is likely to be contrary
predatory pricing, limiting production/market, creatingto the provisions of the Competition Act.
barriers to entry and applying dissimilar conditions toPenaltieso The Commission can impose a penalty of
similar transactions. An agreement includes anynot more than 10% of turn-over of the enterprises
arrangement, understanding or concerted actionand in case of cartel - 3 times of the amount of
entered into between parties. It need not be inprofit made out of cartel or 10% of turnover of all
writing or formal or intended to be enforceable in law.the enterprises whichever is higher
An anti-competitive agreement is an agreementThe Act has so far become operative only partly and
having appreciable adverse effect on competition.the Competition Commission of India has not yet
Anti-competitive agreements include,o agreement tobeen operational fully. The actual impact of the Act
fix priceo bid rigging or collusive biddingo conditionalwill be known only after its substantive provisions viz.
purchase/sale (tie-in arrangement)o exclusive supplysections 3 to 6, come into force. However, the Act
distribution arrangemento agreement to limitstill manifests certain lacunas. An examination of the
production & supplyo agreement to allocatepowers of the CCI would suggest that the
marketso resale price maintenanceo refusal to dealcommission is fully equipped to counter and set right
The objectives of the Act are sought to be achievedthe vagaries of the market place. However, while
through the instrumentality of the Competitionseemingly enjoying carte blanche, there appear to be
Commission of India (CCI) which has been establishedcertain glaring lacunae which would militate against the
by the Central Government with effect from 14thefficacy of the provisions of the Competition Act it
October, 2003.would be remembered that the Commission would
Any arrangement of combination of trading firms isinitiate action upon complaints of anti-competitive
regulated under the Act .A Combination includesagreements abuse of dominant position either suo
acquisition of shares, acquisition of control by themoto, or on the voluntary motion of a person
enterprise over another and amalgamation betweenseeking an opinion of the Commission. Here, two
or amongst enterprises. Further any combination, thataspects may be kept in mind --- the lack of a
exceeds the threshold limits specified in the Act inmandatory provision compelling persons or entities,
terms of assets or turnover, which causes or is likelywhether public or private, to approach the
to cause an appreciable adverse effect onCommission and the corresponding logistical limitations
competition within the relevant market in India, canof the Commission to be able to take cognizance on
be scrutinized by the Commission. A firm proposingits own motion of every malpractice in the economy.
to enter into a combination, may, at its option, notifyIf there is no inbuilt principle that statutory authorities
the Commission in the specified form disclosing theand private persons are required to approach the
details of the proposed combination within 7 days ofCommission to determine whether an
such proposal. If the Commission is of the opinionanti-competitive agreement is in force, or whether
that a combination is likely to cause or has causedthere is an abuse of dominant position or whether a
adverse effect on competition, it shall issue a noticecombination is detrimental to public interest, can we
to show cause the parties as to why investigation inactually rely upon the parties to approach the
respect of such combination should not beCommission of their own accord? The Central
conducted. On receipt of the response, if CommissionGovernment also enjoys unbridled power in the
is of the prima facie opinion that the combination hasmatters of policy framing and issues direction on
or is likely to have appreciable adverse effect onquestions of policy which shall be binding on the CCI .
competition, it may direct publication of details invitingThe government also has the power to supersede
objections of public and hear them, if consideredthe CCI, against which the CCI can make a
appropriate. It may invite any person, likely to berepresentation to the government. Such provisions
affected by the combination, to file his objections.seriously affect the independence and efficacy of
The Commission may also enquire whether thethe CCI. In fact consultation by the Central
disclosure made in the notice is correct andGovernment in evolving competition policy with the
combination is likely to have an adverse effect onCCI should be made mandatory, instead of
competition. The commission can also pass orders indiscretionary, as contemplated in the Act. Moreover,
case of combinations to the following effecto It shallthe Act does not address the abuses of Intellectual
approve the combination if no appreciable adverseProperty Rights, which are monopoly rights for limited
effect on competition is foundo It shall disapprove ofperiod of time.