India’s aviation sector witnessed unprecedented disruption in early December 2025 when IndiGo, the country’s largest airline, cancelled and delayed thousands of flights nationwide. With a domestic market share exceeding 60-65%, IndiGo’s operational crisis affected a significant portion of air travellers, prompting not only aviation regulators but also competition authorities to take note. In this context, the Competition Commission of India (‘CCI’) initiated an internal assessment to examine whether the airline’s conduct during the disruptions could raise concerns under the Competition Act, 2002 (‘the Act’), particularly in relation to abuse of dominant position.
Nature of the CCI’s Examination
According to media reports citing senior government and regulatory officials, the CCI has commenced a suo motu examination of the matter, without any formal complaint being filed. The Commission is reportedly analysing whether IndiGo’s dominance in the domestic aviation market, or on certain high-density routes, may have contributed to or exacerbated consumer harm during the crisis. While dominance itself is not prohibited under Indian competition law, Section 4 of the Act restricts enterprises from abusing such dominance through unfair or exclusionary conduct.
Legal Framework: Abuse of Dominant Position
Under Section 4 of the Act, abuse of dominance may take the form of exploitative practices, such as the imposition of unfair conditions or prices, or exclusionary practices that limit market access for competitors. In the present scenario, the CCI is expected to assess whether IndiGo’s operational decisions, capacity management, pricing behaviour, or passenger handling during large-scale cancellations could amount to exploitative conduct, especially in a market where consumers may have had limited alternatives due to IndiGo’s substantial market presence.
Significance for Competition Law Enforcement
The CCI’s scrutiny is significant as it reflects a potentially broader approach to competition law enforcement in India. Traditionally, abuse of dominance cases has focused on pricing strategies, contractual restrictions, or refusal to deal. However, the present case suggests that large-scale service disruptions by a dominant enterprise, if linked to unfair market outcomes or consumer harm, may also fall within the ambit of competition law review. This approach reinforces the consumer welfare objective of the Act and highlights the evolving nature of antitrust enforcement in India.
The Indian aviation industry has undergone significant consolidation in recent years, resulting in a highly concentrated market structure. IndiGo’s dominance has grown alongside the exit or weakening of several competitors, making it a critical player in ensuring market stability and service continuity. The current scrutiny brings into focus the risks associated with such concentration and raises important questions about accountability, resilience, and competitive constraints in essential service sectors.
At this stage, the CCI’s review remains preliminary and informational in nature. No prima facie order or formal investigation has been initiated against IndiGo. The Commission will proceed further only if it finds sufficient material indicating abuse of dominance. If a formal inquiry is launched and a violation is ultimately established, the CCI has the authority to impose penalties, issue cease-and-desist directions, and prescribe behavioural remedies under the Competition Act, 2002.
Conclusion
The CCI’s scrutiny of IndiGo underscores the growing intersection between competition law, consumer welfare, and sectoral regulation in India. As the aviation sector navigates ongoing challenges, this development may set an important precedent for how dominance is assessed and regulated in highly concentrated markets. The outcome of the CCI’s examination will be closely watched by industry participants and legal practitioners alike, as it could shape the future contours of abuse of dominance jurisprudence in India.
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