Supreme Court has upheld the Delhi High Court's decision to quash the investigations initiated by the CCI under the Competition Act

The Supreme Court has recently refused to entertain a petition filed by the Competition Commission of India (CCI) challenging a Delhi High Court order. The High Court had earlier put an end to the CCI’s probe into Telefonaktiebolaget LM Ericsson and Monsanto Holding Private Limited. A bench of Justices J.B. Pardiwala and Sandeep Mehta dismissed the Special Leave Petition (SLP) but clarified that questions of law could still be raised in another appropriate case.

Delhi High Court’s Key Observations

The Delhi High Court earlier ruled that the CCI investigation quashed by courts was justified because CCI lacked the legal power to continue. The Court noted that once a settlement is reached between the informant and the accused, the foundation of the CCI proceedings collapses. It further stated that CCI had no jurisdiction to conduct such investigations when patent rights are involved.

The High Court emphasized that the inquiry CCI sought to conduct overlapped with the role of the Controller under Chapter XVI of the Patents Act. Therefore, the Patents Act, being a special law, must prevail over the Competition Act. On this basis, the court ordered that the CCI investigation quashed by courts must stand.

Dispute between Competition Act and Patents Act

The central legal issue was whether the CCI could inquire into the conduct of a patentee exercising rights under the Patents Act. Complaints were filed against Ericsson for imposing unfair licensing conditions on its standard essential patents (SEPs) in the telecom sector. Similarly, Monsanto faced complaints of charging excessive royalties for its patented technology, allegedly violating Sections 3 and 4 of the Competition Act.

However, Ericsson and Monsanto argued that a patentee’s rights under the Patents Act cannot be overridden by CCI’s jurisdiction under the Competition Act. The Delhi High Court agreed, ruling that the Patents Act governs such disputes and that the CCI investigation quashed by courts was legally valid.

CCI’s Stand before the Court

CCI contended that it was not seeking exclusive control over patent-related disputes. Instead, it argued that its role was to safeguard competition in markets to ensure fair trade and economic growth. Referring to Section 62 of the Competition Act, CCI claimed that its powers should work alongside, and not be restricted by, the Patents Act. Despite this, the High Court found that allowing such dual jurisdiction would create conflict and uncertainty.

Final Outcome

In conclusion, both the Delhi High Court and the Supreme Court refused to revive the proceedings, marking another instance where a CCI investigation quashed by courts highlights the dominance of the Patents Act over the Competition Act. The ruling reinforces that competition regulators cannot override patent laws when disputes relate directly to the exercise of patent rights.

Case Title: COMPETITION COMMISSION OF INDIA vs. MONSANTO HOLDINGS PRIVATE LIMITED & ORS. Decided on September 2, 2025.