Pranav B Prem

The Competition Commission of India (CCI), has dismissed a complaint filed by Liberty Infospace Pvt. Ltd. against Google, holding that the company did not abuse its dominant position by terminating the Informant’s developer account on the Google Play Store. A four-member Bench comprising Chairperson Ravneet Kaur and Members Anil Agrawal, Sweta Kakkad, and Deepak Anurag, in an order dated October 7, 2025, found no prima facie violation of Section 4 of the Competition Act, 2002, and accordingly closed the case under Section 26(2) without directing an investigation.

Also Read: CCI Dismisses Complaint Against Indiabulls, Says Pre-Payment Penalty Not Anti-Competitive

Background

The Informant, Liberty Infospace Pvt. Ltd., an Indian MSME, operated an HRMS application titled EasyDo Tasks–HRMS Payroll AI, which had over 16,000 downloads on the Google Play Store. On June 26, 2024, Google terminated Liberty’s developer account, citing prior violations linked to previously terminated associated developer accounts. As a result, Liberty’s app was delisted from the Play Store. Liberty claimed that it had no connection with the associated account in question, allegedly belonging to one Mr. Dakshay Sanghvi, who was hired through a third-party contractor. The company contended that Google’s termination lacked transparency, that the appeals process was unfair, and that the undefined term “related account” was arbitrary and enabled discriminatory enforcement.

It also argued that Google’s policies amounted to abuse of dominance and denial of market access under Section 4 of the Act. Further, the Informant cited discrimination, alleging that Google provided developers in the European Union additional redressal mechanisms under the Digital Services Act, which were not extended to Indian developers.

Contentions and Findings

The CCI acknowledged that Google holds a dominant position in the market for licensable mobile operating systems (Android OS) and app stores for Android OS, but held that dominance alone does not imply abuse. Examining the facts, the Commission noted that public sources, including LinkedIn, described Dakshay Sanghvi as Liberty’s Chief Technology Officer (CTO) since March 2024. He was also listed on the company’s official app website and had filed appeals to Google on Liberty’s behalf using his personal email address. Consequently, the CCI found Liberty’s claim of having no association with Sanghvi to be factually incorrect.

The Commission held: “Therefore, in the case of termination of the Informant's developer account and in the disposal of appeals by Google against the same, there appears to be no abusive or discriminatory conduct indulged into by Google.”  The CCI accepted Google’s explanation for not disclosing detailed enforcement mechanisms, observing that complete transparency could enable bad actors to game the system. The Tribunal found Google’s “relational ban policy,” rationale for termination, and lack of incentive to remove legitimate apps to be reasonable. It further observed that combining automated and human review in the appeals process could not be deemed unfair or discriminatory by itself. “Combination of automation and human effort in decision of such appeals cannot be said to be unfair or discriminatory per se,” the order stated.

Terms of Agreement

The Commission also analyzed the Google Play Developer Distribution Agreement (GPDDA), which Liberty had alleged to be one-sided and arbitrary. It found the agreement to be a standard-form contract applied uniformly across all developers. Clause 10.3 of the GPDDA allows immediate termination of developer accounts in cases of serious or policy-related violations, including those linked to associated accounts.

Also Read: PVR Inox's VPF Charge On Filmmakers Prima Facie Violates Competition Act : CCI Orders Probe

Rejecting the Informant’s plea for interim relief under Section 33, the Commission concluded that there was no prima facie evidence of abusive or discriminatory conduct by Google. Accordingly, the matter was dismissed under Section 26(2) of the Competition Act, 2002. The Commission reiterated that mere dissatisfaction with a platform’s enforcement decisions or contractual terms does not constitute an abuse of dominance in the absence of anti-competitive intent or effect. “In view of the facts and circumstances of the present case, the Commission finds that no prima facie case of contravention of the provisions of Section 4 of the Act is made out,” the CCI held.

Cause Title: Liberty Infospace Pvt. Ltd. V. Alphabet Inc & 2 Ors.

Case No: Case No. 07 of 2025

Coram: Ms. Ravneet Kaur (Chairperson), Mr. Anil Agrawal (Member), Ms. Sweta Kakkad (Member), Mr. Deepak Anurag (Member)