Supreme Court Clears CCI Probe into Asian Paints on Grasim Complaint

On October 13, 2025, the Supreme Court dismissed Asian Paints Limited’s petition challenging a Competition Commission of India (CCI) investigation initiated on a complaint by Grasim Industries. 

The complaint alleged that Asian Paints abused its dominant position in the decorative paints market by restricting dealers from selling rival products. The apex court’s decision clears the way for the CCI’s Director General to continue the investigation without obstruction.

Grasim’s Complaint and the CCI Investigation

Grasim Industries, which recently entered the decorative paints segment under the Birla Opus brand, accused Asian Paints of leveraging its market dominance to influence dealers and limit their ability to stock competitors’ products. 

Acting on the complaint, the CCI ordered a Director General investigation under Section 26(1) of the Competition Act. The order was later upheld by the Bombay High Court, which found that the CCI’s prima facie decision was administrative in nature and did not require a pre-hearing for the enterprise concerned.

Legal Background and Court Rulings

Asian Paints had earlier sought to quash the CCI probe through the Bombay High Court, arguing procedural irregularities. The High Court dismissed the plea, affirming that orders under Section 26(1) are preliminary and only direct further investigation. 

Following this, the company appealed to the Supreme Court, which has now rejected the appeal, allowing the competition watchdog to proceed unhindered.

Read More: Asian Paints Moves Supreme Court Against CCI Probe into Grasim Case

Judicial Observations and Key Takeaways

Both the Bombay High Court and the Supreme Court reaffirmed that Section 26(1) investigations do not require a prior hearing. Courts also clarified that Section 26(2-A) does not prevent the CCI from acting on new complaints if they are supported by fresh facts or evidence, even when similar issues have been examined previously. The rulings emphasise that the CCI’s role at this stage is to assess whether a prima facie case exists for deeper investigation.

Conclusion

The Supreme Court’s decision reinforces the CCI’s investigative authority and signals continued judicial backing for India’s competition enforcement framework. The outcome holds significance for the decorative paints industry, where market practices and dominance issues are under close scrutiny amid shifting competitive dynamics.

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