UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

TOPIC- HISTORY AND DEVELOPMENT OF COMPETITION LAW

A Project File submitted to

UNIVERSITY INSTITUTE OF LEGAL STUDIES,

PANJAB UNIVERSITY ; CHANDIGARH

In the Partial Fulfillment of the requirement of the five year intergrated course

B.A. LL.B.(Hons.) Semester-8

SUBJECT : BUSINESS LAWS- II

Under the Supervision of : Submitted By :

Miss Atambir Nishant Choudhary

Roll No.- 67/17

Section- B
Semester- 8th
B.A. LL.B.(Hons.)
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

Acknowledgement
The success and outcome of this project has required a lot of guidance and assistance and I
am extremely privileged to have got all this all along the completion of my project. All that I
have done is only due to such supervision and assistance

I respect and thanks Miss Atambir for providing me with an opportunity to do project wok and
giving all the support and guidance which made me complete this project duly. The project
just not proved to be a part of the syllabus but also taught me about the ground
realities of the execution of law. Being a student of Business law-II, one must be aware about
the concept of Competetion Law. This project has helped me understand the ground realities
about the law with latest case judgments. With the gratitude of my professor I am able to go
through the ground realities and subsequently have learned this topic for the rest of my life.
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

TABLE OF CONTENTS

1. Introduction……………………………………………….……………….…….…..5
2. Evolution……………………………..…………….…..………………………….6-7
3. Evolution of MRTP……………………………………….……………….…..…8-10
4. Competition Act,2002……………………………….……………………………..11
5. Salient features of competitive law…………………………………………..…12-15
6. Powers of commission……………...…………………………….………….…16-17
7. Conclusion…………………………………………….…………………………...18
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

HISTORY AND DEVELOPMENT OF COMPETITION LAW

1. INTRODUCTION
Competition law is a law that promotes or seeks to maintain market competition by regulating
anti-competitive conduct by companies. Competition law is implemented through public and
private enforcement. Competition law is known as antitrust law in the United States for
historical reasons, and as "anti-monopoly law" in China and Russia. In previous years it has
been known as trade practices law in the United Kingdom and Australia. In the European Union,
it is referred to as both anti-trust and competition law. The history of competition law reaches
back to the Roman Empire. The business practices of market traders, guilds and governments
have always been subject to scrutiny, and sometimes severe sanctions. Since the 20th century,
competition law has become global. The two largest and most influential systems of
competition regulation are United States antitrust law and European Union competition law.
National and regional competition authorities across the world have formed international
support and enforcement networks.

Modern competition law has historically evolved on a country level to promote and maintain
fair competition in markets principally within the territorial boundaries of nation-states.
National competition law usually does not cover activity beyond territorial borders unless it has
significant effects at nation-state level. Countries may allow for extraterritorial jurisdiction in
competition cases based on so-called effects doctrine. The protection of international
competition is governed by international competition agreements. In 1945, during the
negotiations preceding the adoption of the General Agreement on Tariffs and Trade (GATT) in
1947, limited international competition obligations were proposed within the Charter for an
International Trade Organisation.

The Competition Act, 2002 was enacted by the Parliament of India and governs Indian
competition law. It replaced the archaic The Monopolies and Restrictive Trade Practices Act,
1969. Under this legislation, the Competition Commission of India was established to prevent
the activities that have an adverse effect on competition in India. This act extends to whole of
India. The competition Act came into existence in January 2003 and the competition
Commission of India was established in October 2003. The Act states that it shall be the duty
of the Commission to eliminate practices having an adverse effect on competition, to promote
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

and protect the interests of consumers and ensure freedom of trade carried on by other
participants, in markets in India.

It is a tool to implement and enforce competition policy and to prevent and punish
anticompetitive business practices by firms and unnecessary Government interference in the
market. Competition laws is equally applicable on written as well as oral agreement,
arrangements between the enterprises or persons.

What is Competition?

Competition means economic rivalry between entities or companies, to draw the highest
number of consumers and earn the most profit. Competition law is also called in some countries
an Antitrust law. Free and fair competition is essential for creating and maintaining an
environment conducive to business and a prosperous country. The objective of all competition
law, around the world is to ensure an environment where all companies compete fairly. The
first act introduced in India for regulation of competition was Monopolies and Restrictive Trade
Practices Act, 1969. When the Act was found to be inadequate, a new act called the Competition
Act, 2002 was introduced.

Evolution of Competition Laws across the Globe

Competition Law is the key tool to promote competition. The scope, application and
implementation of Competition Law vary widely across jurisdictions. Competitive laws have a
long history. Some authors claim the first laws against anti- competitive practices date as far
back as the middle ages, when cartels, the so-called guilds, were formed in most European
cities. The first prohibition of contracts that restrain trade can be traced to English Common
law of the early fifteenth century.1

The first modern body of competition law can be traced back to the enactment of the Sherman
Act of 1890 and the Clayton Act of 1914 in the United States. In the second half of the
nineteenth century, the United States and Canada experienced a turbulent process of economic
change. Railroads and steamships expanded the scope of many markets, and managerial
innovations led to larger corporations and trusts.

1
blog.ipleaders.in/competition-law-india
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

At the same time, agricultural prices fell as a consequence of monetary stringency associated
with the gold standard. Farmers and small business owners discovered that they had to pay high
prices for the inputs charged by the trusts while receiving lower prices for their own outputs.
Further developments in competition law, however, were considerably overshadowed by the
move towards nationalization and industry wide planning in many countries.

Making the economy and industry democratically accountable through direct government
action became a priority. Coal industry, railroads, steel, electricity, water, health care and many
other sectors were targeted for their special qualities of being natural monopolies. In contrast,
Commonwealth countries were slow in enacting statutory competition law provisions.

EVOLUTION AND DEVELOPMENT OF COMPETITION LAW IN

INDIA

India adopted its first competition law way back in 1969 in the form of Monopolies and
Restrictive Trade Practices Act (MRTP). The Monopolies and Restrictive Trade Practices Bill
as introduced in the Parliament in the Joint Select Committee. The MRTP Act, 1969 came into
force, with effect from 1June, 1970. However, with the changing nature of business, market ,
economy on the whole within and outside India, there was felt a necessity to replace the obsolete
law by the new competition law and hence the MRTP Act was replaced with the Competition
Act of 2002.2

The enactment of MRTP Act, 1969 was based on the Socio-economic philosophy enshrined in
the Directive Principles of State Policy contained in the Constitution of India. The MRTP Act,
1969 underwent amendments in 1974, 1980, 1982, 1984, 1986, 1988 and 1991. The
amendments introduced in the year 1982 and 1984 were based on the recommendations of the
Sachar Committee, which was considered by the Govt. of India under the Chairmanship of
Justice Rajinder Sachar in the year 1977.

The Sachar Committee pointed out that advertisements and sales promotions having become
well established modes of modern business techniques, representations through such
advertisments to the consumer should not become deceptive. The Committee also noted that
fictitious bargain was another common form of deception and many devices were used to lure
buyers into believing that they were getting something for nothing or at a nominal value for
their money. The Committee recommended that an obligation is to be cast on the seller to speak

2
en.wikipedia.org/wiki/History_of_competition_law
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

the truth when he advertises and also to avoid half truth, the purpose being preventing false or
misleading advertisements.

However, as the times changed, the need was felt for a new competition law. With introduction
of new economic policy and opening up of the Indian market to the world, there was a need to
shift focus from curbing monopolies to promoting competition in the Indian market.

As pointed out by the then Finance Minister in his budget speech in February, 1999-

“The MRTP Act has become obsolete in certain areas in the light of international economic
developments relating to competition laws. We need to shift our focus from curbing monopolies
to promoting competition. The government has decided to appoint a committee to examine this
range of issues and propose a modern competition law suitable for our conditions.”

In October 1999, the Government of India constituted a High Level Committee under the
Chairmanship of Mr. SVS Raghavan to advise a modern competition law for the country in line
with international developments and to suggest legislative framework, which may entail a new
law or suitable amendments in the MRTP Act, 1969. The Raghavan Committee presented its
report to the Government in May 2000.

The committee inter alia noted: In conditions of effective competition, rivals have equal
opportunities to complete for business on the basis and quality of their outputs, and resource
deployment follows market success in meeting consumers’ demand at the lowest possible cost.

On the basis of the recommendations of the Raghavan Committee, a draft competition law was
prepared and presented in November 2004 0 to the Government and the
Competition Bill was introduced in the Parliament, which referred the Bill to its Standing
Committee. After Considering the recommendations of the Standing Committee, the Parliament
passed December 2002 the Competition Act, 2002. Hence, the Monopolies and Restrictive
Trade Practices Act, 1969 (MRTP) was repealed and was replaced by the Competition Act,
200, with effect from 1September, 2009.
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

Evolution of MRTP as a Competition Law

Even before the Glasnost and globalization which took place in the early 1990s, India took
regulatory measures by means of an antitrust act named Monopolies and Restrictive Trade
Practices (MRTP) Act in1969.3

From 1969 to 2003 Govt. provided the regulation to the monopolistic trade for the first time by
virtue of the enactment of this Monopolies and Restrictive Trade Practices Act (MPTP Act)
which inspired by the mandate of the Directive Principles of State Policy in the Constitution of
India. The Preamble of the MRTP Act preached a socialistic philosophy intended to ensure
that the operation of the economic system did not led to the concentration of economic
power to the common detriment.

The Act advocated for the prohibition of Monopolistic and Restrictive Trade Practices.
However, it was not meant for all sectors of the economic system and did not apply to the public
sector, government undertakings and undertakings by state & central Govt. corporation, banks
, the State Bank of India and insurance companies of India which restricted the scope of the
Act. As a result, the Parliament of India enacted Competition Act, 2002 in 2003. Competition
Act deals with anti-competitive agreements, abuse of a dominant position and a
combination or an acquisition.

Three enquiries conducted by three different committees acted as the loadstar for the enactment
of the MRTP Act . Those are-

The Committee under the chairmanship of Mr. Hazari studied licensing procedure for the
Industrial sector under the Industries (Development and Regulation) Act, 1951. The Committee
found that licensing system led to the disproportionate growth of some big business houses
(Hazari, 1965).

In October 1960 a committee was set up which was chaired by Professor Mahalanobis.
The Committee enquired the distribution and levels of income and came to a conclusion in
February 1964 that the top 10% of Indian population cornered almost
40% of the income and the big business companies were flourishing because of the existence
of country’s ‘planned economy’.

3
https://blog.ipleaders.in
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The Government of India appointed ‘The Monopolies Inquiry Commission (MIC)’ in

April, 1964 which was chaired by Mr. Das Gupta. The Committee researched about the
monopoly practice in the industry and its impact on the Indian economy. The Commission
reported in October 1965 that product wise and industry wise concentration of economic power
existed in the system due to large-scale restrictive and monopolistic trade practices as a few
business houses were operating a large number of companies.

As a consequence of its findings, the Monopolies Inquiry Commission drafted a Bill which was
amended by a Parliamentary Committee and became the ‘Monopolies and Restrictive Trade
Practices Act, 1969 (MRTP Act)’ and was enacted from 1st June, 1970.

The MRTP Act intended to protect consumers as well as to avoid concentration of wealth and
aimed to prevent-
(a) Concentration of economic power
(b) Prohibition of monopolistic, unfair or restrictive trade

Economic Reforms and its Impact on the MRTP Act

The MRTP Act became ineffective for different reasons. For example– the frequently changing
industrial policy of Indian Government. Major amendments to MRTP Act was undertaken in –

(i) 1984 – major addition was relating to Unfair Trade Practices

(ii) 1991 – deletion of chapter relating to Mergers and Acquisitions and Addition relating
to Award of Compensation

The monopoly of the public sector was abolished in 1991. For example- licensing had been
abolished and opened for the private sector in 6 core industrial sectors like steel, heavy electrical
equipment, aircraft, air transport, shipbuilding, telecommunication equipment and electric
power were made open for private sector investments.

Some difficulties arose while practicing and implementing MRTP Act were as follows –

Lack of clarity on various definitions and interpretations – the Act neither define nor even
mention certain trade practices which are restrictive in character. Such as- abuse of dominance,
cartels, collusion and price fixing, bid rigging, boycotts and refusal to deal, predatory pricing
etc.
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

Discrimination between public and private sector – in spite of being a competition law, the
MRTP Act could not be effective in the absence of the element of competition. For example,
the protection and favour offered in pricing and purchase preferences to public sector, hampered
competition where the private companies were also operating in the market without getting any
favour from the Govt.

The major recommendations and suggestions submitted to the government were:

To repeal the MRTP Act and to enact a new Competition Act for the regulation of
Anticompetitive agreements and to prevent the abuse of dominance and combinations including
mergers.

To eliminate reservation of products in a phased manner for the Small Scale Industries and the
Handloom Sector.

To divest the shares and assets of the government in state monopolies and privatize them.

To bring all industries in the private as well public sector within the proposed legislation.

Competition Act,2002

The Competition Act, 2002 was amended by the Competition (Amendment) Act, 2007 and
again by the Competition (Amendment) Act, 2009.4

The Act establishes a Commission which is duty bound to protect the interests of free and fair
competition (including the process of competition), and as a consequence, protect the interests
of consumers. Broadly, the Commission's duty is:-

To prohibit the agreements or practices that have or are likely to have an appreciable adverse
effect on competition in a market in India, (horizontal and vertical agreements / conduct);

To prohibit the abuse of dominance in a market;

To prohibit acquisitions, mergers, amalgamations etc. between enterprises which have or are
likely to have an appreciable adverse effect on competition in markets in India.

4
https://en.m.wikipedia.org
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In addition to this, the Competition Act envisages its enforcement with the aid of mutual
international support and enforcement network across the world.

The Competition Act, 2002 replaced the Monopolies And Restrictive Trade practices Act, 1969,
as the same had become obsolete on account of international economic developments relating
more particularly to competition laws and a need was felt to focus on competition. The Central
Government to serve this need set up a High Level Committee on competition Policy and Law
to study the competition regime in the nation and prepare a report recommending modifications
to the MRTP Act. This ultimately led to the repeal recommending modifications to the MRTP
Act. This ultimately led to the repeal of the Act and a new Act namely, the Competition Act,
2002 was enacted by the Government . one of the essential elements of the New Law was
establishment of the Competition Commission of India (CCI / the Commission).

Object of the Act: The object of the Act was to establish a Commission to:

➢ Prevent practices having adverse effect on competition

➢ Promote and sustain competition in markets
➢ Protect interests of consumers
➢ Ensure freedom of trade carried on by other participants.

The object of this act is to create an environment that promotes competition and safeguard the
independence to do business. The Act states in its Objects and Reasons that because of
globalization, India has opened up its economy to the world, removed restrictions and controls
and liberalized the economy.

SALIENT FEATURES OF COMPETITION ACT, 20025

The Competition Act provides for establishment of a Competition Commission of India which
will be a quasi judicial body bound by priniciples of rule of law in giving decisions and the
doctrine of precedents. The CCI has all the powers of a civil court for gathering evidence.

There are three major elements in the Competition Act:

• Anti-competitive Agreements (Section 3)

• Abuse of Dominant Position (Section 4) Combinations
(Section 5 and 6)
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1. Anti-competitive Agreements

Anti-competitive Agreements are prohibited under the Competition Act. The following
agreements entered into by enterprise, association or persons are considered as anticompetitive:

1. Agreement having appreciable adverse effect on competition(AAEC) – no one shall enter

into any agreement in respect of production, supply, distribution storage, acquisition or
control of goods or provision of services which causes or is likely to cause appreciable
adverse effect on competition within India. Following factors are to be considered by the
Commission to determine whether an agreement has appreciable adverse effect on
competition in India:
• Creation of barriers to new entrants in the market
• Driving existing competitors out of the market
• Foreclosure of competition by hindering entry into the market
• Accrual of benefits to the consumers
• Improvements in production or distribution of goods or provision of services.

2. Any agreement entered into, including cartels engaged in identical or similar trade of goods
or provision of services, which: Determines purchase or sale prices
• Limits or controls production, supply, markets, technical development, investment or
provision of services
• Shares the market of source of production or the provision of services by way of
allocation of geographical area of the market, or type of goods or services, or number
of customers in the market or any other similar way
• Results in bid rigging or collusive bidding having AAEC in India.

3. Agreement at different stages or levels of the production chain in different markets, in

respect of production, supply, distribution, storage, sale or price of, or trade in goods or
provision of services, including:
• Tie-in arrangement
• Exclusive supply agreement
• Exclusive distribution agreement
• Refusal to deal
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

• Resale price maintenance

If the aforesaid agreement causes an AAEC in India, then such agreements will be considered
as anti-competitive agreements and such agreements are prohibited under the Act.

Remedies available against Anti-competitive Agreements

Section 27: Competition Commission of India has the following powers in this regard:

• Passing an interim order during the pendency of inquiry

• Serve a cease and desist notice directing the offending parties to a cartel to discontinue
and not to repeat such agreements in future
• Order the offending parties to modify the agreement
• Impose on each member of the cartel a hefty pecuniary penalty Abuse of Dominant

Position:

The Act defines dominant position (dominance) in terms of a position of strength enjoyed by
an enterprise, in the relevant market in India, which enables it to: a operate independently of
the competitive forces prevailing in the relevant market; or an affect its competitors or
consumers or the relevant market in its favor.

The relevant market (Section 2(r)) means “the market that may be determined by the
Commission with reference to the relevant product market or the relevant geographic market
or with reference to both the markets”.

Factors that Determine Dominant Position

Section 19(4) of the act mentions the factors that help in determining dominant position in the
market.

Dominance has been traditionally defined in terms of market share of the enterprise or group of
enterprises concerned. However, a number of other factors play a role in determining the
influence of an enterprise or a group of enterprises in the market. These include: a market share,
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

a the size and resources of the enterprise; a size and importance of competitors; a economic
power of the enterprise; a vertical integration; a dependence of consumers on the enterprise; a
extent of entry and exit barriers in the market; countervailing buying power; a market structure
and size of the market; source of dominant position. The Commission is also authorized to take
into account any other factor which it may consider relevant for the determination of
dominance.

Abuse of Dominance

Dominance is not considered bad per se but its abuse is. Abuse is stated to occur when an
enterprise or a group of enterprises uses its dominant position in the relevant market in an
exclusionary or/ and an exploitative manner.

➢ directly or indirectly imposing unfair or discriminatory condition in purchase or sale of

goods or service;
➢ directly or indirectly imposing unfair or discriminatory price in purchase or sale
(including predatory price) of goods or service;
➢ limiting or restricting production of goods or provision of services or market;
➢ limiting or restricting technical or scientific development relating to goods or services
to the prejudice of consumers;
➢ denying market access in any manner;

Predatory Pricing

➢ The “predatory price” under the Act means “the sale of goods or provision of services,
at a price which is below the cost, as may be determined by regulations, of production
of goods or provision of services, with a view to reduce competition or eliminate the
competitors” [Explanation (b) of Section 4]

➢ Predation is exclusionary behaviour and can be indulged in only by enterprises(s)

having dominant position in the concerned relevant market.

Powers of the Commission

After inquiry the Commission may pass inter- alia any or all of the following orders
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1. Under section 27 the Commission may direct the parties to discontinue and not to
reenter such agreement; direct the enterprise concerned to modify the agreement. direct
the enterprises concerned to abide by such other orders as the Commission may pass
and comply with the directions, including payment of costs, if any; and pass such other
orders or issue such directions as it may deem fit.
2. The Commission can impose such penalty as it may deem fit. The penalty can be up to
10% of the average turnover for the last three preceding financial years upon each of
such persons or enterprises which are parties to bid-rigging or collusive bidding.
3. Section 28 empowers the Commission to direct division of an enterprise enjoying
dominant position to ensure that such enterprise does not abuse its dominant position.
4. Under section 33 of the Act, during the pendency of an inquiry into abuse of dominant
position, the Commission may temporarily restrain any party from continuance with the
alleged offending act until conclusion of the inquiry or until further orders, without
giving notice to such party, where it deems necessary.

Regulation of Combinations

As per the Competition Act, Combinations include Mergers, Acquisitions, and Amalgamations.
The term combination according to the Act means:

• Section 5(a): Acquisition of control, voting rights or assets;

• Section 5(b): Acquisition of control by a person over an enterprise where such person
has control over another enterprise in similar or identical business; Section 5(c):
Mergers and Acquisitions.

Section 6 provides for regulation of combinations so that they do not have an adverse effect on
competition. As per this section, No enterprise should enter into any combination that is likely
to cause an AAEC. When any enterprise enters into a combinations and if the value of assets or
turnover increases beyond a threshold declared by the government such enterprise shall give
notice to the Commission in the prescribed form by disclosing the details of the proposed
combination and any such combination shall not come into effect until 210 days have passed
from the date on which the notice has been given to the Commission.
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Investigation of Combinations

• The CCI can either by itself or through a Director General conduct an investigation
to determine the proposed combination is likely to cause appreciable adverse effect
on competition within India.
• If the CCI is of the opinion that a combinations is likely to have an AAEC then it
will issue show cause notice to the parties and they have to respond within 30 days
of receipt of the notice.
• After receipt of the reply to show cause notice, the CCI can call for the report from
the Director General.
• Within 7 days of receipt of reply from the parties or of the recpt of the report from
the Director General, the CCI will direct the parties to publish the details of the
combination to the public.
• CCI can invite affected or likely to be affected parties or members of the public to
file written objections to the combinations.
• CCI can call for additional information from the parties to the combination within
15 working days of the expiry of the time for filing objections from the affected
parties or the members of the public.
• Additional document s are to be filed by the parties within further 15 days.
• On receipt of the requested information the CCI must deal with the case within 45
days.

Final decision can be taken by the CCI to accept, reject or modify the combination within an
addition 180 working days. If the CCI does not give its final decision then the combination is
deemed to be approved.

1. CASE LAWS:
In Kingfisher Airline V/s Competition Commission of India,5 the CCI had imposed a
fine of Rs. 1crore on kingfisher Airlines for not providing adequate information during
CCI’s investigation of the airline’s alliance with Jet Airways.

5
WRIT PETITION NO. 1785 OF 2009
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

2. In Hawkins Cookers Limited V/s Murugan Enterprises, the Delhi High Court held that
Hawkins Cookers Limited, a well- known mark on the pretext of being prominent and well
known, could not be allowed to create a monopoly in the incidental market.

Conclusion

India and the world was going through a new phase of globalisation, liberalisation and
privatisation and these changing times were bringing newer challenges and the existing MRTP
Act had become obsolete in the modern era. Hence the new Competition Act came into being
in order to suit the need of the hour. The new act is based on the regulation of conduct or
behaviour of the players in the market and is result oriented rather than being procedure oriented
like the MRTP Act.

Further its main purpose is to protect and promote competition in the market. Competition is
very essential as it benefits: the Consumers as they get wider choice of goods and services,
better quality and improved value for money; it benefits the Businesses as a level playing field
is created and a redressal of anti-competitive practices is available, the inputs are competitive
priced, they tend to have greater productivity and ability to compete in global markets and
finally it also benefits the state as there is optimal realisation from sale of assets and there is
enhanced availability of resources for social sector. Thus, by protecting competition in the
market the competition law helps benefit all the players in the market which in turn is beneficial
for the economy as a whole.
 UNIVERSITY INSTITUTE OF LEGAL STUDIES, PANJAB UNIVERSITY, CHANDIGARH

BIBLIOGRAPHY

1. en.wikipedia.org/wiki/History_of_competition_law
2. blog.ipleaders.in/competition-law-india
3. en.wikipedia.org/wiki/History_of_competition_law
4. blog.ipleaders.in/competition-law-evolution