CCI’s Google Play Ruling: Key Insights On Competition Law And Digital Platforms

Introduction

The Competition Commission of India (CCI) has recently dismissed allegations of abuse of dominant position against Alphabet Inc., Google LLC, and Google India Private Limited (collectively, Google), filed by Liberty Infospace Pvt. Ltd. The Commission, acting under Section 26(2) of the Competition Act, 2002, which empowers it to close a case at the preliminary stage where no prima facie violations appear, found no prima facie case of contravention and consequently ordered closure of the proceedings.

The matter centered on the termination of the Liberty Infospace’s developer account on the Google Play Store, raising questions on whether Google’s account-suspension policies and enforcement mechanisms amounted to an abuse of its dominant position in the Android app-store ecosystem.

Background of the Case

The informant, Liberty Infospace Pvt. Ltd., a micro enterprise registered under the MSME Ministry, developed the EasyDo Tasks-HRMS Payroll AI App, an integrated HR and productivity management tool. The app was launched on the Google Play Store in 2021 after entering into the standard Google Play Developer Distribution Agreement (GPDDA) with Google LLC.

In June 2024, Liberty Infospace’s developer account was terminated by Google without prior notice. The termination email cited “prior violations of the Developer Program Policies and Developer Distribution Agreement by this or associated previously terminated Google Play Developer Accounts.” Despite multiple appeals and clarifications submitted by the company, Google maintained the termination, referring to internal indications of the account being “related” to previously banned developer accounts.

Liberty Infospace then approached the CCI under Section 19(1)(a) of the Competition Act, 2002, alleging abuse of dominant position by Google and seeking reinstatement of its account. It claimed that Google’s unilateral termination and lack of due process amounted to abuse of dominant position under Section 4. It also sought interim reinstatement of its developer account under Section 33.

Informant’s Allegations

Liberty Infospace alleged multiple abuses, including:

• Unilateral termination of its developer account without specific reason or notice, despite contractual provisions requiring a 30-day notice (Clause 10.3, GPDDA).
• Opaque appeal process and automated enforcement, which deprived developers of a fair opportunity to be heard.
• Arbitrary interpretation of the term “related account” without defined criteria.
• Discriminatory treatment of Indian developers vis-à-vis EU developers, where Google provides additional redressal avenues under the Digital Services Act (DSA).
• Denial of market access to app developers, particularly MSMEs, resulting in economic harm and loss of livelihood.

The informant prayed for initiation of investigation, imposition of penalties, and structural changes to ensure transparent enforcement of Play Store policies.

Google’s Response

Google contended that the issues raised were individual grievances relating to enforcement of Play Store policies, not matters of competition law. It relied heavily on prior CCI decisions, notably the Google Play Case (Case No. 39 of 2018) and Alphabet Case (Cases No. 07/2020, 14/2021, and 35/2021), wherein the Commission had upheld the legitimacy of Play Store’s enforcement mechanisms.

Key submissions included:

• The termination was based on its “Relation Ban Policy,” a security protocol to prevent banned developers from re-entering the platform through linked or associated accounts.
• Internal review revealed strong indications linking the informant’s developer account to a previously terminated “malware seed account” operated by a person named Shri Dakshay Sanghvi, who was publicly identified as Chief Technology Officer of Liberty Infospace.
• Under Clause 10.3 of the GPDDA, Google is authorized to terminate accounts immediately for serious violations without prior notice.
• Automated systems are used alongside human review to detect policy violations, ensuring accuracy and uniformity.
• The appeals process is globally consistent, and developers worldwide (except for EU-specific DSA mechanisms) have the same redressal process.
• There is no incentive for Google to arbitrarily terminate compliant accounts, as more apps on Play Store enhance consumer welfare and Google’s own revenue.

Google emphasized that the enforcement was proportionate, reasoned, and consistent with its global standards.

Commission’s Analysis

The CCI framed three issues for determination:

1. What is the relevant market?
2. Whether Google holds a dominant position in that market?
3. Whether the conduct amounts to abuse under Section 4?

The CCI examined the matter under three key questions:

1. Relevant Market: The Commission reaffirmed the relevant market as the “market for app stores for Android OS in India.” This was based on the non-substitutability of Android app stores with iOS or other ecosystems and the indispensability of the Google Play Store for developers to reach Android users.
2. Dominance of Google: Google was confirmed as dominant in this market, due to its network effects, lack of viable substitutes, and the critical role of Play Store for both developers and consumers. The Commission clarified that dominance alone does not constitute abuse under Section 4 of the Act.
3. Alleged Abuse of Dominance: After examining the evidence and submissions, the Commission found that the termination of Liberty Infospace’s account was consistent with Google’s established policies, including the Relation Ban Policy. The link between the informant’s developer account and a previously terminated account associated with Shri Dakshay Sanghvi (CTO of Liberty Infospace) was substantiated. The GPDDA and GPDPP are standard-form contracts applied uniformly to all developers, reflecting industry-wide practices rather than discriminatory conduct. Google’s appeals and enforcement processes, which combine automated systems with human review, were not arbitrary or unfair, and no evidence was found of discriminatory treatment of Indian developers compared to global practices, including the EU, apart from DSA-specific mechanisms.
4. Conclusion of Analysis: The CCI held that Google’s conduct was proportionate, justified, and consistent with global standards, and did not amount to abuse under Section 4. The Commission emphasized that policy enforcement by a dominant platform is not abusive where applied uniformly, transparently, and in accordance with contractual terms.

• Order and Outcome: Invoking Section 26(2) of the Competition Act, 2002, the Commission concluded that no prima facie case of abuse of dominance was made out against Google and ordered the closure of the information. Consequently, the interim relief application (I.A. No. 64A of 2025) and the urgent hearing application (I.A. No. 195 of 2025) were also disposed of. The CCI additionally granted confidentiality protection to certain information submitted by Google for a period of three years under Regulation 36 of the CCI (General) Regulations, 2024 read with Section 57 of the Act.

Significance of the Decision

1. Clarifies CCI’s Non-Interventionist Approach: The order underscores that contractual or policy enforcement disputes between developers and digital platforms do not automatically raise competition concerns unless they indicate systemic exclusion or market-wide harm.
2. Endorses Platform Self-Regulation: CCI accepted automated policy enforcement and relation-based account termination as legitimate tools for maintaining platform integrity, provided they are applied uniformly and transparently.
3. Reaffirms Google’s Dominance but Not Abuse: While dominance of the Play Store in India was reconfirmed, the CCI drew a sharp distinction between holding dominance and abusing it.
4. Guidance for Digital Developers: Developers must ensure full compliance with the Play Store’s policies and understand that violations or associations with banned entities may justify termination under competition law scrutiny.

Conclusion

The CCI’s order in Liberty Infospace Pvt. Ltd. v. Alphabet Inc. reinforces that competition law will intervene in digital platforms only where market-wide harm, exclusionary conduct, or unfair leveraging is evident. While reaffirming Google’s dominance, the Commission held its policy enforcement to be reasonable, proportionate, and consistent with global standards, signaling a cautious, evidence-based approach to platform governance.

From an analytical perspective, the judgment clarifies that competition law does not substitute for contractual disputes: developers must comply with platform policies and understand that links to banned accounts can justify termination without triggering competition scrutiny. Overall, the decision provides guidance for regulators and digital enterprises on proportional and transparent platform governance.

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