CCI Dismisses Abuse of Dominance Allegations Against Google in Developer Account Termination Case
Competition Commission of India finds no contravention of Competition Act in Liberty Infospace's claims against Google's Play Store policies.
In a significant ruling, the Competition Commission of India (CCI) has dismissed allegations of abuse of dominance brought by Liberty Infospace Pvt. Ltd. against Google LLC and its parent company, Alphabet Inc. The case revolved around the unilateral termination of Liberty Infospace's developer account on the Google Play Store, which the company claimed was done without specific reasons and constituted an abuse of Google's dominant market position.
The CCI, in its detailed judgment dated October 6, 2025, analyzed the allegations under the framework of the Competition Act, 2002. The key issues examined were the relevant market definition, Google's dominance in that market, and whether Google's conduct constituted an abuse of dominance under Section 4 of the Act.
The CCI determined that the relevant market was the "market for app stores for Android OS in India," a market where Google undeniably holds a dominant position due to the widespread use of its Play Store among Android users and developers.
However, the Commission found that Google's enforcement of its Play Store policies, including the termination of Liberty Infospace's account, did not amount to an abuse of dominance. The CCI noted that Google's policies, such as the "relational ban policy," and its mix of automated and human intervention in appeals processes, were reasonable and non-discriminatory. The Commission also highlighted that Liberty Infospace's claim of no material connection with the alleged violator was factually incorrect, as evidence indicated a significant link.
Furthermore, the CCI observed that standard contracts like the Google Play Developer Distribution Agreement (GPDDA) are common industry practices and do not inherently imply abuse. The Commission also found that Google's redressal process for appeals is uniformly applied across jurisdictions, with the exception of the European Union due to specific local laws.
Given these findings, the CCI concluded that no prima facie case of contravention of Section 4 of the Competition Act was made out against Google. Consequently, the Information was ordered to be closed, and the interim relief sought by Liberty Infospace for provisional reinstatement of its developer account was denied.
In a related order, the CCI granted Google confidentiality over certain documents submitted during the proceedings for a period of three years, subject to the provisions of Section 57 of the Act.
The decision underscores the complexities involved in balancing platform policies with competition law, especially in digital marketplaces where dominant players like Google operate. The dismissal of the case serves as a significant precedent in the application of competition law to digital platforms and their policies.
Bottom Line:
Abuse of Dominant Position - Allegations of unilateral termination of developer account by Google without specific reasons and failure to redress appeals against the same - Competition Commission of India found no contravention of Section 4 of the Competition Act, 2002.
Statutory provision(s): Competition Act, 2002 Sections 4, 26(2), 33, Competition Commission of India (General) Regulations, 2024 Regulation 36, Section 57 of the Act
Liberty Infospace Pvt. Ltd. v. Alphabet Inc, (CCI) : Law Finder Doc Id # 2789689
