Module-wise first checks, evidence and escalation triggers.
| No. | Topic | First action | Evidence | Escalate when |
|---|---|---|---|---|
| 01 | Anti-competitive agreements | Identify whether parties are competitors, suppliers, distributors, platforms or trade associations. | Contracts; Emails and chats; Pricing records | Informal industry coordination |
| 02 | Cartels and bid rigging | Implement competitor-contact protocols. | Tender files; Bid build-up; Communication map | Deleting chats after inquiry notice |
| 03 | Vertical restraints and distribution | Define products, channels and affected geography. | Distribution agreements; Discount policies; Market-share evidence | Minimum advertised price enforced as fixed resale price |
| 04 | Dominant position and abuse | Define relevant market before assessing dominance. | Market study; Customer dependence data; Pricing/cost records | Calling market leadership “dominance” without analysis |
| 05 | Relevant market and competition economics | Identify customer need and switching. | Customer surveys; Switching data; Internal strategy documents | Selecting market to fit desired result |
| 06 | Predatory pricing and discounts | Determine dominance first. | Cost records; Discount approvals; Business plans | Using accounting loss as proof of predation |
| 07 | Combination thresholds and filing screen | Map parties, groups and target business. | Group financials; Transaction documents; Valuation and consideration bridge | Using only target revenue |
| 08 | Deal value threshold | Aggregate direct, indirect, deferred and contingent consideration. | Consideration schedule; Valuation report; India user/revenue data | Excluding earn-outs |
| 09 | Control and material influence | Map affirmative rights and quorum. | SHA/SSA; Articles; Board-rights matrix | Treating all vetoes as protective |
| 10 | Combination filing and standstill | Build filing timetable into transaction plan. | Signing/closing checklist; Clean-team protocol; Interim covenant matrix | Early integration |
| 11 | Green channel and deemed approval | Map horizontal, vertical and complementary overlaps across groups. | Portfolio map; Overlap search; Market descriptions | Narrow portfolio search |
| 12 | Exemptions and ordinary-course acquisitions | Identify transaction category exactly. | Shareholding history; Rights matrix; Investment mandate | No written exemption analysis |
| 13 | Gun jumping and pre-closing conduct | Define prohibited pre-closing actions. | Protocol; Clean-team logs; Decision records | Joint customer meetings |
| 14 | Settlement mechanism | Confirm statutory stage and eligibility. | Investigation record; Remedy design; Financial exposure model | Missing filing window |
| 15 | Commitment mechanism | Act early after prima facie order. | Theory-of-harm map; Commitment proposal; Implementation timeline | Vague commitments |
| 16 | Leniency and leniency plus | Secure evidence and preserve privilege. | Evidence inventory; Chronology; Privilege protocol | Delaying while evidence dissipates |
| 17 | Investigation, dawn raid and digital evidence | Maintain dawn-raid protocol and response team. | Raid protocol; Custodian list; Legal hold | Deleting messages |
| 18 | Penalties, compensation and director liability | Identify relevant turnover/income base. | Turnover data; Role matrix; Compliance evidence | Focusing only on headline penalty |
| 19 | Competition compliance programme | Risk-rank competitor, distributor, procurement and M&A activity. | Policy; Training records; Contract-review log | Generic training only |
This page is an editorial navigation layer. The linked official Act, rule, regulation, notification, circular, portal instruction or judgment remains controlling.