CCI drops abuse of dominance probe against Google over Play Store account ban

Background and parties involved

The Competition Commission of India (CCI), acting under Section 26(2) of the Competition Act, 2002, has closed proceedings initiated on the basis of information filed by M/s Zucol Solutions Private Limited against Google India Private Limited in relation to termination of Google Play developer accounts.

The Informant, M/s Zucol Solutions Private Limited, is a private limited company incorporated under the Companies Act, 2013, and is engaged in developing digital software and mobile applications. The allegations concerned the suspension and termination of its Google Play developer accounts and alleged anti-competitive conduct by Google.

The Opposite Party (OP), Google India Private Limited, operates the Google Play Store, a digital app distribution platform for Android OS, through which developers upload and distribute applications to users. Google also provides associated services such as in-app billing, analytics, review management, and various backend services (including Firebase, APIs and ad tools) to support app distribution and monetisation.

The essence of the Informant’s charge was that Google, allegedly enjoying a dominant position in the Android app distribution ecosystem, abused such position by arbitrarily terminating its developer accounts, denying it market access, and thus violating Section 4 of the Competition Act, 2002.

Allegations by the Informant

Creation and termination of the first developer account

  • The Informant created a Google Developer Account (GDA) on Google Play (account ID: 6466909330537599514 – referred to as the First Account) to list its mobile applications.
  • On 20.09.2023, Google terminated the First Account citing breaches of Google’s Developer Program Policies (DPP) and the Developer Distribution Agreement (DDA).
  • According to the Informant, there was no advance notice and no clear reasoning initially offered beyond a generic reference to policy violations.
  • During appeal, Google informed the Informant that the termination was triggered by an application titled “Pobreflix — Series, Movies”, which was identified as non-compliant with DPP and DDA, including alleged malware and deceptive behaviour issues.

The Informant’s stance evolved over time:

  1. In the original information, it claimed that “Pobreflix — Series, Movies” did not belong to it and had been developed and published by an external contractual developer.
  2. It asserted that, upon learning of the alleged violations, it severed all ties with that developer and requested that Google limit enforcement to that specific app, rather than terminating the entire account.
  3. It contended that Google’s insistence on terminating the full account, instead of isolating the alleged offending app, was arbitrary, disproportionate and violative of principles of natural justice.

Alleged external developer involvement

The Informant maintained that:

  • “Pobreflix — Series, Movies” had been created “a while ago” by an external developer, engaged on a one-time contractual basis.
  • The developer was allegedly no longer associated with the Informant at the time of termination.
  • The Informant claimed inability to furnish present contact details of this developer, stating that the engagement had ended.

At the same time, the Informant urged Google to remove or disable the specific “Pobreflix — Series, Movies” app, if found violative, but requested independent review and continuation of its other applications which, according to it, had always complied with all policies.

Subsequent second developer account and its termination

  • On 31.05.2024, after termination of the First Account, the Informant opened a second Google Play developer account (account ID: 7941074486004459573 – referred to as the Second Account).
  • Only one app, named BTHAWK, was published through this Second Account.
  • On 06.07.2024, Google terminated the Second Account, linking it to “past policy violations” associated with the First Account, treating it as a related/connected account.

The Informant argued that:

  • The Second Account was independent, with no connection to the earlier violations alleged against the First Account.
  • Termination of the Second Account without detailed explanation or evidence of linkage was arbitrary and unjust.
  • Google expressly warned against creating new developer accounts and stated that any such account would be terminated, which, according to the Informant, effectively blocked it from re-entering the Android app distribution ecosystem, amounting to denial of market access.
  • The Informant issued legal notices to Google dated 29.03.2025 and 01.05.2025 seeking reconsideration, justification and reinstatement.
  • According to the Informant, no substantive response or fair appeal hearing was provided.
  • It claimed to have suffered substantial financial loss of approximately Rs. 57 Crores, damage to goodwill and reputation, and effective exclusion from the Android app distribution market.

On this basis, the Informant alleged that:

  • Google’s conduct amounted to abuse of dominant position under Section 4 of the Competition Act, 2002.
  • There was also a contravention of Section 3, though the core case focused on alleged unilateral conduct under Section 4.

Reliefs sought

The Informant requested CCI to:

  1. Direct the Director General to investigate under Section 26(1) of the Act.
  2. Declare that Google contravened Sections 3 and 4 of the Act.
  3. Order reinstatement of the Informant’s developer accounts, or allow creation of a new account with transfer of all compliant apps.
  4. Award monetary compensation of INR 57 Crore.
  5. Grant any further relief considered appropriate in the interests of justice.

Proceedings before the Commission

CCI’s initial queries to the Informant

At its meeting on 27.08.2025, CCI examined the information and raised pointed questions to test internal consistency of the Informant’s narrative. CCI noted apparent contradictions between:

  • Email exchanges where the Informant appeared to accept that “Pobreflix — Series, Movies” was under its developer account and that it wanted the app removed, and
  • The statement in paragraph 6 of the information asserting that the app “did not belong to the Informant” and was solely by an external contractor.