CCI Declines To Intervene In Dispute Over AI-Altered Re-Release Of ‘Raanjhanaa’, Finds No Competition Law Violation
Pranav B Prem
The Competition Commission of India (CCI) has declined to intervene in allegations of anti-competitive conduct against Eros International Media Ltd. in relation to the AI-altered re-release of the Hindi film Raanjhanaa, holding that no prima facie case of violation of competition law was made out. The Commission found that the issues raised did not fall within the ambit of the Competition Act, 2002, and that any remedy, if available, would lie before an appropriate forum. The decision was rendered by a coram comprising Chairperson Ravneet Kaur and Members Sweta Kakkad and Deepak Anurag in an order dated January 5, 2026, passed under Section 26(2) of the Competition Act, closing Case No. 28 of 2025.
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The matter arose from an information filed by two advocates under Section 19(1)(a) of the Act, alleging that Eros International had unlawfully altered the ending of the feature film Raanjhanaa using artificial intelligence and re-released the modified version in the State of Tamil Nadu in August 2025. The informants contended that the original film, released in 2013, is protected under the Copyright Act, 1957, and that Eros, while holding theatrical and television distribution rights, did not possess the right to alter the content of the film.
It was alleged that the AI-based alteration of the film’s ending, coupled with its theatrical re-release and proposed distribution on OTT platforms, amounted to anti-competitive agreements and abuse of dominant position in violation of Sections 3 and 4 of the Competition Act. According to the informants, such conduct distorted competition in the motion picture industry, adversely affected consumer choice, and exploited the absence of regulatory safeguards governing AI-driven alterations of copyrighted works.
The informants further alleged that Eros had misused exclusive distribution agreements and engaged in collusion with distributors and OTT platforms, leading to price manipulation and potential foreclosure of competition. On this basis, they sought an investigation by the Commission, a permanent restraint on further screening and distribution of the altered version, and interim relief under Section 33 of the Act to stop the exhibition of the AI-modified film.
After examining the information and accompanying materials, the Commission observed that the primary grievance pertained to the alteration of the film’s content and the rights associated with such alteration. It held that the allegations were essentially in the nature of a private or contractual dispute between concerned parties, which by itself did not warrant intervention by the competition regulator.
The Commission noted that although multiple allegations were raised alleging contravention of Sections 3 and 4 of the Act, the informants failed to furnish any material to establish dominance of Eros in the relevant market, the existence of any anti-competitive agreement, or a nexus between the impugned conduct and an appreciable adverse effect on competition in India. It observed that merely raising concerns around the use of new technology or intellectual property exploitation does not automatically attract scrutiny under competition law.
In this context, the Commission observed that “such issues appear to be in the nature of dispute, if any, between concerned/relevant parties which ipso facto does not require intervention of the Commission,” and concluded that no prima facie case of contravention of Sections 3 or 4 of the Act was made out against Eros International Media Ltd.
Accordingly, the Commission ordered closure of the information under Section 26(2) of the Act. Consequent to this finding, the requests for interim relief under Section 33 were also rejected, and the interlocutory applications filed by the informants stood disposed of. The Commission clarified that any remedy available to the informants would lie before an appropriate forum outside the Competition Act framework.
Cause Title: Adv Utkarsh Tiwari, Adv Kunwar Arpit Paliwal and Eros International Media Ltd
Case Number: Case No. 28 of 2025
Coram: Chairperson Ravneet Kaur and Members Sweta Kakkad and Deepak Anurag
