No Abuse of Dominance: CCI Closes Case on Google Play Account Termination

On March 24, 2026, the Competition Commission of India dismissed an information filed against Google India Private Limited under Section 26(2) of the Competition Act, 2002, finding no prima facie case of abuse of dominant position under Section 4 of the Act.

The case arose from an information filed by M/s Zucol Solutions Private Limited, a company engaged in digital software development and mobile application services, alleging violations of Sections 3 and 4 of the Act.

The informant, aggrieved by the termination of its developer account by Google India Private Limited, contended that such termination was arbitrary, lacked transparency, and was undertaken without providing a fair opportunity to appeal. It further alleged that the termination resulted in reputational harm, substantial financial loss, and exclusion from the Android app distribution market.

The informant’s Google Play developer account was terminated in September 2023 on account of an application titled ‘Pobreflix – Series, Movies’, which was found to be in violation of the Developer Program Policies (DPP) and Developer Distribution Agreement (DDA). The informant claimed that the app had been developed by an external contractor. It subsequently created a second account to host an application titled BTHAWK, which was also terminated by Google due to its linkage with the earlier account. The informant alleged that these actions amounted to denial of market access and abuse of dominance.

The Commission delineated the relevant market as the “market for app stores for Android OS in India” and observed that Google holds a dominant position in the said market. However, it noted several material inconsistencies and deficiencies in the informant’s submissions, including contradictory statements regarding ownership of the impugned application, failure to identify the concerned developer, incomplete disclosure of communications, and suppression of material facts such as the reinstatement of the original developer account and the creation of additional accounts.

The Commission further observed that Google had acted in accordance with its stated policies, including the Malware Policy and Relation Ban Policy, had provided an opportunity to appeal, and had eventually reinstated the informant’s account. It also noted that despite such reinstatement, the informant had not re-listed its applications.

Relying on its earlier decisions, the Commission reiterated that Google’s Play Store policies and enforcement mechanisms are standard industry practices and do not, in themselves, indicate anti-competitive conduct. It also found no evidence of appreciable adverse effect on competition or market-wide harm.

Accordingly, the Commission held that the matter pertained to an individual contractual grievance rather than a competition law issue, and closed the case under Section 26(2) of the Act.