Reassessing Margin Squeeze Jurisprudence in India after CCI v. Schott Glass

Abstract

Margin squeeze has long been recognised as a potential form of exclusionary conduct under competition law. Traditionally associated with network industries such as telecommunications, the doctrine has generated extensive scholarship concerning its relationship with refusal to deal, predatory pricing and vertical foreclosure. The growing prominence of digital platforms has renewed interest in margin squeeze as these platforms control essential points of access for business users while competing with them in downstream markets. While the doctrine has been extensively analysed in the United States and the European Union, its development in emerging competition-law regimes such as India has received comparatively limited scholarly attention. This paper examines that, in the absence of a free-standing margin-squeeze offence under the Indian Competition Act, such allegations were assessed through unfair conditions, denial of market access and leveraging. It argues that the Supreme Court’s decision in CCI v. Schott Glass India (2025) provides the first coherent doctrinal framework and guiding principles for assessing margin squeeze in India.