Surinder Singh Barmi vs BCCI [Case No. 61/2010]

Case Summary

Forum

Competition Commission of India (CCI), New Delhi^[1]

Acts/Sections Referred^[2]

The Competition Act, 2002:

1. Section 2(h) “enterprise”
2. Section 4 “Abuse of dominant position”
3. Section 19(1)(a) “Inquiry into certain agreements and dominant position of enterprise”
4. Section 26 (1) “Procedure for inquiry under Section 19”
5. Section 27 “Orders by Commission after inquiry into agreements or abuse of dominant position”

Parties^[3]

1. Informant- Sh. Surinder Singh Barmi
2. Opposite Party (OP)- Board for Control on Cricket in India (BCCI)
3. Investigator- Director General (DG), Competition Commission of India (CCI)

Factual Background^[4]

1. This case started from information filed with the Competition Commission of India (hereafter “CCI”) by Sh. Surinder Singh Barmi (Informant), a cricket enthusiast from New Delhi, under Section 19(1)(a) of the Competition Act, 2002. (hereinafter “Act”)^[5] alleging gross violations of Section 4 of the Act, based on which the Commission admitted a prima facie case in the Informant’s favor and subsequent proceedings.
2. The previously dated order issued by CCI under Section 27 of the Act deemed the BCCI’s behavior to be in clear violation of Section 4 of the Act, which bans an “enterprise” from abusing its dominant position in the relevant market.^[6]
3. According to the order, conducting private professional cricket leagues/events in India conclusively proved BCCI’s market dominance. The BCCI’s submission under Article 9.1(c) (i) of its IPL Media Rights agreement entered into with the broadcasters of the Indian Premier League (“IPL”) that “it shall not organize, sanction, recognize, or support another professional domestic Indian T20 competition that is competitive to the league” was found to violate Section 4(2)(c) of the Act, despite having assumed regulatory powers in the commercial agreement.
4. BCCI filed an appeal with the erstwhile Hon’ble Competition Appellate Tribunal after being dissatisfied with the Commission’s earlier verdict (hereafter, “COMPAT”). The COMPAT set aside the Commission’s earlier order dated 8th, directing the Commission to re-start the matter after finding that the earlier order was inconsistent with the very important principles of natural justice, because the said clause was not referred to in the order passed under Section 26(1), nor the Director General (“DG”) recorded any finding regarding its validity, and on this count, the appellant was not allowed to defend the said clause.
5. Following COMPAT’s directions, the Commission redirected the DG to undertake more investigation into the matter.
6. The DG cited the pyramid structure of cricket governing bodies, different types of cricket matches, discrepancies in professional domestic cricket leagues and other formats of cricket, and the similarity of legal issues surrounding the organization of cricket events across India in its report, and concluded that the relevant market for the dominant position is the ‘organization of professional domestic cricket league/events in India.
7. The additional analysis verified BCCI’s dominating position in the relevant market by examining its market share, size, resources and economic power, customer reliance, and significant entry hurdles. Furthermore, the BCCI’s entire dominance in the relevant business was increased by the International Cricket Council (thus, ‘ICC’) and BCCI rules/regulations/bye-laws.
8. The DG contended that the BCCI’s monopolized regulations (Rule 28(b) and (d) of the BCCI Rules) did not permit any other company to organize a professional cricket league in India, constituting a clear breach of Section 4(2)(c) of the Act.
9. The Commission based its decision on the supplementary investigation report and determined that Rule 28 of the BCCI Rules, which states that permission for conducting a cricket match or tournament will be granted only to BCCI members, and Rule 29 of the BCCI Rules, which prohibits any player, official, umpire, or member associated with BCCI from participating in a ‘Disapproved Cricket’ tournament, were both in violation of the spirit and letter of Section 4(2)(c) of the Act. Section 32 of the ICC Bye-Laws defines ‘Disapproved Cricket’ as any cricketing event that has not been awarded a legitimate sanction by the member whose territory it is played.
10. Following that, the Commission ruled that clause 9.1(c)(i) of the IPL Media Rights Agreement breached Section 4(2)(c) of the Act when read in connection with BCCI’s restrictive regulations and ICC bye-laws.^[7]

Issues on which DG Investigated the Matter 

1. Is the Act applicable to the BCCI? Is BCCI a “business” as defined in section 2(h) of the Act?
2. In this scenario, what is the relevant market?
3. Is BCCI a dominating player in the relevant market, as determined?
4. If this is the case, has BCCI misused its dominant position in the relevant market in violation of Section 4 of the Act?^[8]

BCCI’s Contentions^[9]

1. The BCCI maintained that it does not qualify as a “business” under Section 2(h) of the Act, citing the Tamil Nadu Societies Registration Act of 1975, which describes the BCCI as a “not-for-profit” organization committed to the development of cricket in India.^[10]
2. In Secretary, Ministry of Information and Broadcasting, Government of India and Others v. Cricket Association of Bengal and Others [1995 (2) SCC 161], the BCCI cited the Supreme Court’s ruling. By comparing athletic organizations like the BCCI/CAB to other commercial societies that promote sporting events for profit, the Supreme Court decided that Section 4 of the Act is inapplicable in this instance.
3. The DG made a mistake by failing to consider the consumer’s perspective while designing the proper market scenario. BCCI filed an Economist Report in support of this allegation, defining the relevant market as one centered on providing entertainment to its subscribers during prime time for entertainment programming. It went on to say that live telecasts of IPL matches are never carried on sports channels, but rather on entertainment channels and that as a result, the relevant market in terms of professional leagues is far larger.
4. The BCCI also said in their papers that other entertainment programs’ television ratings increased after the IPL, demonstrating that the IPL is not an important market.
5. Based on its market share, size, resources, and economic power, as well as customer reliance and significant entry barriers, the DG decided that BCCI had a dominant position in the relevant market.
6. The BCCI’s economic strength cannot be exploited to establish its dominance because it is a non-profit organization whose funds are used to improve cricket.
7. Based on the reasoning that BCCI prohibits any private entity from staging a cricket match/tournament, the DG’s report mistakenly concluded that BCCI Regulations 28(b) and 28(d) act as anti-competitive restrictions. However, Rule 28(b) specifies that no member, affiliated club, or “any other organization” may organize a cricket match or tournament without the BCCI’s permission.
8. It is vital to note that when the idea of ‘ejusdem generis is applied to it, ‘any other organization’ does not include private organizations, and there is no prohibition upon private organizers launching a professional domestic cricket league or event.

Commission Order^[11]

1. The CCI determined that BCCI’s activities and behavior fit within the scope of regulatory function/role in its detailed conclusion. The BCCI has continued to function as a statutory body with regulatory functions and is thus a de facto regulator of cricket in India by establishing the rules of the game and team selection, associating with the International Cricket Council (“ICC”), and operating Section 32 of the ICC Manual, which authorizes the BCCI to sanction/approve cricket events in India (“Disapproved Cricket”).
2. The Commission also noted that the Legislature intended to draft an Act that focuses mostly on a business’s processes and operations rather than its structural structure. It cited Hemant Sharma & Ors. v. Union of India & Ors. (W.P. (C) 5770 of 2011) to enlarge the idea of a company.^[12] The Chess Federation has deemed a business under Section 2(h) of the Act, while the BCCI was declared an enterprise under Section 2(h) of the Act.
3. The operations of sports organizations fall under the term “business,” and the fact that BCCI is a “not-for-profit” organization does not exclude it from the definition.
4. When defining the relevant market for the dominance of powers, the Commission conducted a thorough examination of market conditions, including the producer on the supply side, the customer on the demand side, and the underlying product or service. It made its determination on the assumption that the Act considers the relevant market to be made up of items and services that may be used interchangeably by consumers and that should be considered from the consumer’s point of view rather than the proponent’s.
5. Furthermore, the Commission determined that, while entertainment is the desired outcome of organizing a Professional Cricket League in India (TRP ratings), the definition of the relevant market, in this case, cannot be replaced by other forms of sporting events and entertainment programs, after taking into account all of the factors that contribute to a systemic portrayal of the success of a Professional Cricket League in India (TRP ratings).
6. After distinguishing between First Class/County Leagues and Private Professional Leagues, which both attract a considerable number of international players, the Commission found that the relevant market is the organization of these Professional Cricket Leagues.
7. The Commission found that the BCCI’s anti-competitive rules (Rule 28(b) and (d) of BCCI Rules) prohibiting any member, official, or umpire affiliated with the BCCI from forming an association with an entity that organizes “Disapproved Cricket” (Section 32.1.1 of ICC Regulations 2011) amounted to clear dominance in the relevant market.
8. The BCCI has a dominant position in the market for organizing private professional league cricket events in India, according to the Commission’s final statement, due to its regulatory role, monopoly status, control over infrastructure, players, ability to control the entry of other leagues, and historical evidence.
9. It also stated that the aforementioned clause (Clause 9.1 (c) I and BCCI Rules 28(b), which allows BCCI to dismiss the functioning of any event that it believes is competitive to the IPL, clearly and unequivocally amounts to a practice resulting in a denial of market access to any potential competitor, and is without a doubt a violation of Section 4(2)(c) of the Act.^[13]

The commission order has been thoroughly reviewed and analyzed in the following part.

Case Analysis

Jurisdiction over Sports Bodies^[14] 

The CCI determined that the BCCI was an “enterprise” under the Competition Act 2002 since its position in India’s regulatory body for cricket, the International Cricket Council (ICC), served as “custodian” of the game and “organizer” of matches. Even though the BCCI was a “non-profit” organization, its operations earned revenue (e.g., it sold media rights as well as tickets). As a result, the CCI concluded that, in terms of their entrepreneurial potential,(i.e., revenue-generating), all sports associations are to be viewed as “enterprises” for the Act and handled “on a par with other commercial entities.” In reaching its conclusion, the CCI relied on known European law cases (e.g., MOTOE v. Elliniko and Meca-Medina)^[15], which found that commercial exploitation of sport constituted an economic activity subject to European competition regulations.

It appears obvious that one of the most influential and commercially successful commercial organizations in Indian sport (the BCCI) should not be immune from competition law, at least insofar as its operations generate income (e.g., the award of broadcast rights, the selling of tickets, and so on). However, as acknowledged in the European examples cited by the CCI, the purely “organizational” actions of the BCCI (i.e., those relating to game laws or exclusively to the sport) should not be captured by the competition rules. As shown, further along, this can be a minor distinction at times.^[16]

Relevant Market

According to the CCI, the relevant market is the “development of private professional cricket leagues/events in India. “The CCI distinguished (1) sports from other forms of television (including movies and general entertainment programs, (2) first-class/international cricket, and (3) first-class/international cricket. (e.g., Test Matches, 1-day Internationals, or Ranji Trophy cricket) from cricket played in “private professional leagues” in reaching this conclusion (such as the IPL). Qualitative and subjective demand variables (for example, “every athletic event is special in its own right”), as well as specific spectator numbers, are used to make the differences.^[17] However, there does not appear to be any application of the SSNIP test, nor does there appear to be any real analysis of how media licenses are given and how TV networks bid/make price choices for programming. That is not to say that the conclusions reached are necessarily incorrect, but it does call into question, for example, whether networks truly believe that media rights for domestic international cricket are not interchangeable with media rights for the IPL (though in that case, it is unclear whether it would make a difference to the BCCI’s position as rights-holder for both domestic international cricket and the IPL).

Dominant Position Defined^[18]

There have been numerous cases in the last decade where industry titans and luminaries have monopolized the functions and operations of the facilities they provide in the relevant market by unleashing their financial wrath on small and financially vulnerable entities, resulting in an obnoxious pro-government atmosphere within the industry. These bulwark enterprises use shady tactics like establishing a ‘dominant position,’ to drive the expansion of such vulnerable organizations so that they may function independently and carve out a distinct image in the industry. Dominant Position is defined in Section 4 of the Competition Act of 2002 as a position held by an entity that permits it to:

• work without regard to the competitive forces that exist in the relevant market;
• and influence its competitors, consumers, or the relevant market in its favor.^[19]

In the case of Fast Track Call Cab Pvt. Ltd. and Meru Travel Solutions Pvt. Ltd. v. ANI Technologies Pvt. Ltd., the settled position on the dominant position was established.^[20]. The CCI stated that Section 4 misuse of dominant position is only applicable where the company under examination has a dominant position in the relevant market. The notion of dominant position was also developed by CCI, which defined it as an enterprise’s position of economic power in the relevant market that allows it to function independently of competitive dynamics or influence its rival, customer, or the relevant market in its favor.

Such a firm will be able to ignore market forces and enforce trade terms, pricing, and other policies unilaterally. Abuse might result in competitive limitations or even the abolition of sustainable competition.

What is abuse of Dominant Position under Section 4 of The Competition Act, 2002?^[21]

An enterprise with a dominant position does one or more of the following things: enforces unfair or discriminatory actions, either directly or indirectly.

• limits or restricts the creation of products or the provision of any kind of service;
•  engages in conduct or acts that result in market access denial contracts subject to third parties’
• acceptance of ancillary duties unrelated to the topic of this kind of contract;
• or exploits its dominant position in one lucrative place to enter or safeguard another relevant market;

A corporation that holds a dominant position has the right to pursue its own goals. However, such an enterprise engages in abusive behavior when it takes advantage of chances deriving from its dominating position to gain trading benefits that it would not have received if there had been regular and suitably effective competition. This premise was articulated in the case of Jupiter Gaming Solutions Pvt. Ltd. v. Government of Goa & Ors.^[22], in which CCI said that abuse occurs when a firm utilizes its dominant position in the relevant market in an exclusionary or exploitative manner. In this case, the government’s lottery tender offer had various restrictions that appeared to limit the size of bidders, such as a minimum gross turnover of the participating company and at least three years of experience. The CCI determined that the Goa government misused its dominant position by denying/restricting market access to other parties in the relevant market by imposing such limitations.

Before debating on the problem of BCCI’s alleged misuse of its dominating position in the relevant market, it is necessary to establish BCCI’s regulatory/custodian status and if it is an entity that may be prosecuted under this act. BCCI has repeatedly violated significant provisions of competition laws in the past, avoiding its penal provisions by claiming that it’s functional/operational structure and financial dynamics (which form part of its transactions) do not qualify as services of an ‘enterprise’ that is covered by this Act. A detailed and complete interpretation of the provision, however, reveals that BCCI’s operation and structure do not exclude it from the definition of ‘business,’ even though it is a non-profit organization.

Limitation of Market Access^[23]

The CCI based its market access analysis on Clause 9.1(c)(i) of the IPL media rights agreement (i.e., the agreement between the BCCI and the networks), which states: “During the Rights period, the BCCI represents and warrants that it shall not organize, sanction, recognize, or support any other professional domestic Indian T20 competition that is competitive to the league.”^[24]

The CCI ruled that the limiting of market access was only conceivable when the BCCI agreed to Clause 9.1(c)(i) using both its commercial and regulatory authorities (i.e., the CCI made a point of emphasizing that this misuse was not only a result of a sporting decision but also involved commercial exploitation). As a consequence, it was decided that the accused activity was subject to competition law rules.^[25]

The CCI investigated Section 4(2)(c) of the Competition Act of 2002, which forbids dominant businesses from “participating in market access denial methods.” The term “market access constraint” isn’t defined clearly, although the Fast Way Transmission case exemplifies it.^[26] is quite useful. Fast Way Transmission, Creative Cable, and Hathway Cable were penalized Rs 8 crore (c. €1.1 million) by the CCI for refusing to provide the complaint to the media firm (Kansan News Pvt). Punjab and Chandigarh have access to the transmission network (decision of on July 3, 2012). The CCI determined that the termination had no objective justification and that there was evidence that Kansan’s channel was growing in popularity (potentially in competition with the downstream channels of the transmission companies). As a consequence, it appears that the concept of limiting market access is similar to the legal concept of refusing to give in Europe (and specifically refusing to grant access to an essential facility or a network). However, it is unclear if this case would fit the European requirements for refusing to provide theory.

On the one hand, there appear to be strong reasons that BCCI “permission” and infrastructure are objectively required/required to operate a competitive private professional league (see the ICL and how the ICC’s pyramid structure prevents the formation of a challenger to the BCCI). It also appears plausible to argue that the IPL is the BCCI’s downstream private professional league (the league is owned and controlled by the BCCI, but the franchises are privately owned), and that, similar to several cases in Europe, a refusal to approve/supply a competing league to benefit an internal downstream operation fits the type of case that typically raises competitive concerns (see paragraph 76 of the Article 102 Guidance Paper).

The chance of such a lawsuit being brought in Europe, on the other hand, appears to be limited by the fact that:

• The decision does not state whether there was an actual or explicit refusal to provide information. Given that it would be activated if a rival private professional league requested approval and the complaint did not seek any sort of clearance/supply from the BCCI, the limitation under the media agreement is hypothetical. The CCI brought up the ICL’s failure/temporary suspension as a solution. However, based on the judgment, the CCI appears to be unable to rely on the refusal to approve/supply the ICL (as it did not have competition powers at that time).
• The customer damage investigation is a formality. It is far from evident that the negative consequences of having only one private professional league would outweigh the consequences of requiring the BCCI to produce and sanction competing leagues over time. It would have to be demonstrated that the BCCI’s monopoly rents for IPL rights resulted in higher consumer costs (e.g., subscriptions), and that these higher subscriptions cost more in total than the costs of the competing league requiring the BCCI’s approval/supply (which may also be subsequently passed on to consumers).
• The BCCI looks to be considering cost-cutting measures (e.g., for the BCCI to continue investing in the sport and producing first-class cricket infrastructure and to maintain interest in the sport, it is necessary to have only one private professional league per season).

Limitation of Franchisees^[27]

The CCI also stated that “the game of cricket and the monetary rewards of playing professional league matches must be distributed rather than concentrated in a few hands, in a few franchises.” In a country with a big youthful population, more private professional leagues provide more opportunities for young people to play cricket, make a living, and find champions where they are least expected.” Simply put, the CCI determined that the BCCI violated Indian competition law by limiting the number of franchisees to a set number. Without more, this premise raises severe legal issues First, it is unclear why the franchise restriction could not be viewed as a strictly sporting choice. Sporting organizations may and do legally select the “correct” number of competitors for a specific tournament/contest, as long as objective and non-discriminatory procedures are followed (For example, by using qualifying events). The CCI’s decision contains a fault in that it does not specify how many franchises would be adequate. As a result, even if the IPL had twice or triple the number of franchisees, the CCI’s interpretation of the legislation would still hold the BCCI in violation.

Penalties imposed by The Commission^[28]

1. BCCI must cease the aforementioned practice, which is regarded to be in breach of the Act’s Section 4(2)(c) and Section 4(1) provisions.
2. The BCCI will not impose blanket restrictions on non-members organizing professional domestic cricket leagues or events.
3. A fine of INR 52.24 crores has been imposed.

Implications/Consequences of The Ruling for BCCI and other National Sports Federations

The judgment aims to change the entrepreneurial behavior of National Sports Federations, who frequently find themselves on the receiving end of granting approvals and sanctions to organize a similar tournament, by putting all sports governing organizations under the umbrella of enterprise based on their economic activity. By articulating the range of laws and commercial transactions that control every athletic event potential and committing every federation to the Act’s mandatory standards, the Hemant Sharma judgment is well-positioned to influence change in the sporting business.

All of the tiny market participants think it is unfair to have been relieved by this ruling. Negotiating a successful agreement with a national/international athlete, broadcasting, media agencies, authorities, and other associated institutions to produce a professional league/event without the heavyweights of the athletic business can be difficult with sporting federations. Minor market participants should take note of the Order of Commission since it contradicts the BCCI’s foundation of one federation, one sport. The Commission thinks that sports federations should not have a monopoly on the rights to create professional leagues and that such leagues should be open to any corporation that wants to form one. The Sporting Federation’s main responsibility will be to devise game rules and to develop disciplinary codes and punitive regulations that are in disagreement with International Sports rules and regulations.

In terms of the power that the BCCI derives from ICC Rule 32, the Commission’s decision to ban the ICL from organizing ‘Disapproved Cricket’ could be overturned under Section 32 of the Act, which empowers the Commission to investigate such transactions if they have a domino effect on competition in India. It is plausible that one of India’s most powerful and financially successful business enterprises should not be exempt from the wrath of competition legislation.

The recent case of Pan India Infra project Pvt. Ltd. v. BCCI^[29] reaffirms the Commission’s stance in the Surinder Singh case, in which the Commission found that the BCCI’s refusal to allow the organizer to participate in the bidding process for IPL market rights amounted to a breach of Section 4(2)(c) of the Act. The BCCI’s expected monopolistic activities of generating considerable revenues through discrete sponsorship and commercial agreements will be equally distributed among players and other businesses, and will not be concentrated in the hands of sports industry behemoths.^[30]

Conclusion

Much of the CCI’s analysis, as can be seen from the preceding, is sound (in particular as regards the application of competition law principles to sporting associations). However, we can see why the third umpire (the Competition Appellate Tribunal of India) would need to conduct a thorough investigation in other aspects of the case.

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References:

[1] 2013 CompLR 297 (CCI) Sh. Surinder Singh Barmi Vs Board for Control of Cricket in India (BCCI). Competition Commision of India

[2] 2013 CompLR 297 (CCI) Sh. Surinder Singh Barmi Vs Board for Control of Cricket in India (BCCI). Competition Commision of India, Case No. 61-2010. Case: Sh. Surinder Singh Barmi Vs Board for Control of Cricket in India (BCCI). Competition Commision of India vLex, https://vlex.in/vid/sh-surinder-singh-barmi-571655722

[3] Id. 3

[4] 2013 CompLR 297 (CCI) Sh. Surinder Singh Barmi Vs Board for Control of Cricket in India (BCCI). Competition Commision of India

[5] The Competition Act, 2002; Act No. 12 of 2003

[6] 2013 (118) SCL 226, Sh. Surinder Singh Barmi Vs Board for Control of Cricket in India (BCCI). Competition Commision of India

[7] SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) Lexology, https://www.lexology.com/library/detail.aspx?g=ce867123-0993-4908-8cf0-1afc943f0ff2 (

[8] COMPETITION COMMISSION OF INDIA, SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) CCI.GOV (2010), https://www.cci.gov.in/sites/default/files/61%20of%202010.pdf

[9] COMPETITION COMMISSION OF INDIA, SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) CCI.GOV (2010), https://www.cci.gov.in/sites/default/files/61%20of%202010.pdf

[10] The Competition Act, 2002; Act No. 12 of 2003

[11] SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) IndianKanoon, https://indiankanoon.org/doc/134186689/

[12] CCI issues order against All India Chess Federation for abuse of dominant position and anti-competitive conduct SCC Blog, https://www.scconline.com/blog/post/2018/07/13/cci-issues-order-against-all-india-chess-federation-for-abuse-of-dominant-position-and-anti-competitive-conduct/

[13] The Board of Control for Cricket in India The Board of Control for Cricket in India,

[14] COMPETITION COMMISSION OF INDIA, SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) CCI.GOV (2010), https://www.cci.gov.in/sites/default/files/61%20of%202010.pdf

[15] Document – Gale Academic OneFile go.gale.com, https://go.gale.com/ps/i.do?id=GALE%7CA249053637&sid=googleScholar&v=2.1&it=r&linkaccess=abs&issn=15677559&p=AONE&sw=w&userGroupName=anon%7Eb5782c54)

[16] Is BCCI an “enterprise”, did it abuse its regulatory powers? | lawstreetindia.com Lawstreetindia.com, http://www.lawstreetindia.com/experts/column?sid=228

[17] Id. 18

[18] COMPETITION COMMISSION OF INDIA, SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) CCI.GOV (2010), https://www.cci.gov.in/sites/default/files/61%20of%202010.pdf

[19] The Competition Act, 2002; Act No. 12 of 2003

[20] Abuse of Dominance, a case of Uber versus Meru LexForti, https://lexforti.com/legal-news/abuse-of-dominance/

[21] The Competition Act, 2002; Act No. 12 of 2003, S.4

[22] Abuse of Dominant Position in a Competitive Market LexForti, https://lexforti.com/legal-news/abuse-of-dominant-position-in-a-competitive-market/

[23] COMPETITION COMMISSION OF INDIA, SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) CCI.GOV (2010), https://www.cci.gov.in/sites/default/files/61%20of%202010.pdf

[24] COMPETITION COMMISSION OF INDIA, SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) CCI.GOV (2010), https://www.cci.gov.in/sites/default/files/61%20of%202010.pdf

[25] Abuse of Dominant Position in a Competitive Market LexForti, https://lexforti.com/legal-news/abuse-of-dominant-position-in-a-competitive-market/

[26] [2018] 147 SCL 198 (SC) Competition Commission of India v. M/s. Fast Way Transmission Pvt. Ltd. & Others

[27] SHRI Surinder Singh Barmi v. Board of Control of Cricket in India (BCCI) (case No. 61/2010) Lexology, https://www.lexology.com/library/detail.aspx?g=ce867123-0993-4908-8cf0-1afc943f0ff2

[28] 2013 CompLR 297 (CCI) Sh. Surinder Singh Barmi Vs Board for Control of Cricket in India (BCCI). Competition Commision of India

[29] Pan India Infra Projects Private Limited Vs. Competition Commission of India on 30 March, 2015 – Legitquest https://www.legitquest.com, https://www.legitquest.com/case/pan-india-infra-projects-private-limited-v-competition-commission-of-india/14F16B

[30] The Competition Act, 2002; Act No. 12 of 2003, S.4