CCI Dismisses Complaint Against Google Play Store; Finds No Abuse in Account Termination Enforcement

On 24 March 2026, the CCI closed allegations of abuse of dominance against Google India Private Limited in relation to the termination of a developer account on the Google Play Store.[1] The informant, a software developer, alleged that Google arbitrarily terminated its developer account due to a third-party application (“Pobreflix – Series, Movies”) and subsequently terminated a newly created account as well. It was contended that such conduct was unjustified, lacked due process, and denied the informant access to the Android app distribution ecosystem, violating Section 4 of the Competition Act.

The CCI delineated the relevant market as the market for app stores for Android OS in India and affirmed Google’s dominance. However, on merits, it found no abuse. A key factor was the informant’s inconsistent and incomplete disclosures. The informant provided contradictory explanations regarding the origin of the impugned application, failed to identify the responsible developer, and did not furnish complete email correspondence despite specific directions. The CCI also noted suppression of material facts, including Google’s reinstatement of the original account and the informant’s creation of additional accounts in violation of Google’s policies.

On the other hand, the CCI found that Google had acted in accordance with its publicly available Play Store policies, including its malware and “relation ban” policies, which restrict developers with prior violations from re-entering the platform through new accounts. The CCI observed that Google had provided reasons for termination, an opportunity to appeal, and ultimately reinstated the original account, asking the informant to resubmit its applications. Notably, the informant failed to do so.

Relying on its earlier decisions, such as Umar Javeed[2] and Liberty Infospace[3], the CCI reiterated that standard-form developer agreements, limited disclosure in enforcement actions, and platform-level safeguards are not per se anti-competitive. Accordingly, the CCI held that the matter reflected an individual grievance arising from policy enforcement rather than a competition law concern, and closed the case under Section 26(2).

Business Takeaway:

The decision casts light on the fact that enforcement of platform policies, including account suspension and restrictions on re-entry, will not amount to abuse where they are transparently framed, consistently applied, and accompanied by review mechanisms. Importantly, complainants who approach the CCI with unclean hands, including through misleading disclosures, risk significantly undermining their competition claims. Businesses should ensure strict compliance with platform policies, as attempts to circumvent enforcement actions may weaken their legal position before the CCI.

[1] CCI: In Re: M/s Zucol Solutions Private Limited and Google India Private Limited, Case No. 17 of 2025, order dated 24 March 2026.

[2] CCI: In Re: Mr. Umar Javeed & Ors. and Google LLC & Anr., Case No. 39 of 2018, order dated 20 October 2022.

[3] CCI: In Re: Liberty Infospace Pvt. Ltd. and Alphabet Inc. & Ors., Case No. 07 of 2025, order dated 6 October 2025.