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Beyond Privacy: Framing Coercive Data Collection As Antitrust Harm In CCI V. Meta Platforms




Rishab Ramakrishna, O.P. Jindal Global University


ABSTRACT


This paper analyses the Competition Commission of India’s (CCI) investigation into Meta Platforms Inc and the subsequent 2025 ruling of the National Company Law Appellate Tribunal (NCLAT) arising from WhatsApp’s 2021 privacy policy update. Meta argued that the CCI lacked jurisdiction, contending that data-sharing conduct falls exclusively within data protection legislation. This paper rejects that argument and contends that the intervention was a defensible and necessary application of competition law, because coercive data collection by a dominant firm constitutes a form of antitrust harm that data protection frameworks are structurally ill- equipped to address. The paper analyses three dimensions of the dispute: the jurisdictional relationship between competition law and data protection as parallel and complementary frameworks; the theory of market foreclosure under Section 4(2)I of the Competition Act 2002 as reformulated by the NCLAT after it set aside the original Section 4(2)I leveraging finding; and the Characterized on of the take-it-or-leave-it consent mechanism as an unfair condition under Section 4(2)(a)(i). The paper argues that the NCLAT’s partial reversal of the CCI’s order, including the setting aside of the five-year data-sharing ban, produces a more doctrinally coherent and durable enforcement framework than the original order, by grounding liability in the group’s aggregate conduct and anchoring relief in a proportionate, consent-based remedy. The paper also considers the subsequent Supreme Court proceedings, in which the Chief Justice characterised WhatsApp’s consent model as a form of theft of private information.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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