CCI Closes WinZO Antitrust Case Against Google Over Online Gaming Ban Dispute
Termination of Investigation
In view of the subsequent enactment of a law banning online money games, the Competition Commission of India (CCI) terminated its antitrust investigation against Google on the treatment of real money gaming apps.
A CCI release noted that it recalled its November 20 order directing an investigation into Google’s conduct towards real money gaming apps on the Play Store and Google Ads.
The case was filed by WinZO Games Private Limited against Google LLC, Alphabet Inc, and Google’s Indian subsidiaries. Google was accused of abusing its dominant position under Section 4 of the Competition Act, 2002 by discriminating between different categories of real-money gaming apps.
Specifically, WinZO had objected to Google’s pilot programme introduced in 2022 which allowed only Daily Fantasy Sports (DFS) and Rummy apps on the Play Store whereas other RMG apps were prohibited. Google also allowed advertisements on its Google Ads platform for DFS and Rummy apps. Additionally, WinZO raised objections to warnings displayed by Google Pay when users attempt to pay using certain gaming apps.
The antitrust regulator after conducting a preliminary analysis observed in November 2024 that Google is dominant in three markets, namely licensable mobile operating systems, Android app stores and online search advertising services in India.
CCI observed that by selectively allowing DFS and Rummy apps while prohibiting others “Google would create a “two-tier market” based on its own criteria and disadvantage competing RMG developers.” Google invoked the new commitment facility introduced under Section 48B of the Competition Act and proposed to open up Google Play and Google Ads to all legally permissible skill-based RMGs, subject to certain certification requirements.
However, Parliament enacted the Promotion and Regulation of Online Gaming Act, 2025 which prohibits online money games, advertisements for such games and facilitation of payments towards such games. This law came into effect on May 1, 2026. This law does not make any distinction between skill-based games and games of chance.
Though the law is being challenged in the Supreme Court, the CCI order notes that no order staying the operation of the new law has come to the notice of the Commission.
So far as the allegations in the complaint were concerned, CCI observed that since the new law prohibits online money games it had “extinguished any lawful RMG market that may have operated on Google Play/Google Ads Store”.
Further, any order opening up the platform to RMG apps would be in violation of this law.
Accordingly, the relief originally sought by WinZO was no longer tenable and the Commission said the changes in law had rendered continuation of proceedings unnecessary.
“We are thus satisfied that there exists no effective remedy which could be granted to WinZO, should this investigation proceed. Additionally, Google has discontinued its pilot programme and WinZO itself has applied to withdraw the Complaint,” the order added.
Withdrawal of Complaint
The Competition Commission also observed that while competition proceedings are inquisitorial and in rem in nature, and the informant cannot by itself determine whether proceedings should be closed:
Withdrawal of complaint does not automatically lead to termination of proceedings.”
Ultimately the Commission said, WinZO had withdrawn its complaint due to “the combination of the above factors”.
Google closure request rejected
Google separately requested that if the order was being closed it offer a fresh commitment to cease its pilot program and refrain from accepting real money gaming advertisements on Google Ads.
The CCI declined Google’s request noting that since the shutting down of the pilot program and prohibition on accepting RMG ads was now statutorily required, accepting such an offer would effectively mean treating mandatory statutory obligations undertaken by Google as voluntary competition remedies.
“Accepting such an offer may amount to treating mandatory statutory compliance as negotiated competition remedy and may encourage other players to follow a similar route,” the Commission added.
WinZO Games was represented by Advocate Pranav Chadha.
Google was represented by advocates Karan Singh Chandhiok, Rahul Rai (Chandhiok & Mahajan), Tarun Donadi and Uday Bali.
Aditi Gopalakrishnan and Arunima Chatterjee also appeared for Google.
