Stifling Competition: Why CCI's Table Tennis Verdict Is A Game-Changer For Sports Regulation
The Competition Commission of India in a landmark decision has ruled against four table tennis associations for abusing their dominant positions, extending the reach of competition law into the realm of sports governance. It began with a single WhatsApp message, a brief advisory sent by a district-level sports official. But that message, warning players against participating in...
The Competition Commission of India in a landmark decision has ruled against four table tennis associations for abusing their dominant positions, extending the reach of competition law into the realm of sports governance. It began with a single WhatsApp message, a brief advisory sent by a district-level sports official. But that message, warning players against participating in unaffiliated table tennis tournaments, set off a chain reaction that would drag four powerful sporting bodies before the Competition Commission of India.
At the centre of the allegations was the Table Tennis Federation of India (TTFI), along with its affiliated state and district associations. Their alleged crime was using their regulatory authority to restrict player participation, and to enforce affiliation-based gatekeeping, all under the mask of discipline and structure. What followed was a landmark investigation, bringing into light the darker undercurrents of sports governance in India. The CCI's ruling redefined the boundaries of authority in Indian sport. It made it clear that even non-profit, regulatory bodies are not beyond the reach of competition law.
The case, TT Friendly Super League Association v. Table Tennis Authorities (Case No. 19 of 2021), not only changes how sporting bodies function within India's legal framework but also sets a standard for regulatory fairness in non-profit, semi-autonomous domains like sports. This is the story of how a friendly league took on a federation and won.
When a WhatsApp Message Sparked a Legal Battle
The TT Friendly Super League Association (TTFSL), an NGO, registered under Section 8 of the Companies Act, 2013 was established to promote table tennis through friendly, low-stakes tournaments in Maharashtra for its members. It found itself in conflict with the Suburban Table Tennis Association (TSTTA), the district authority responsible for regulating table tennis matches and affiliated to Maharashtra State Table Tennis Association (MSTTA). In October 2020, a WhatsApp advisory issued by TSTTA's General Secretary warned players, clubs, and coaches not to join unaffiliated entities like TTFSL. The threat was explicit and non-compliance could lead to suspension or denial of tournament entries. As a result, players declined TTFSL's membership, and organizers hesitated to associate. What appeared as internal regulatory communication quickly escalated into a nationwide competition law issue when TTFSL filed an information under Section 19(1)(a) of the Competition Act, 2002.
The Allegations: Gatekeeping Through Dominance
The allegations against the Suburban Table Tennis Association (TSTTA), the Maharashtra State Table Tennis Association (MSTTA), the Table Tennis Federation of India (TTFI), and the Gujarat State Table Tennis Association (GSTTA) centred on anti-competitive practices aimed at gatekeeping through dominance. These included restricting players from participating in unaffiliated events, imposing mandatory affiliation requirements on clubs and organizers, and threatening disciplinary action and suspension against those who played in independent leagues or tournaments.
The Commission, considering the hierarchical governance structure—with the TTFI at the national level followed by state and district associations—the Commission found all four entities dominant in their respective jurisdictions. The TTFI, the National Sports Federation recognized by the Ministry of Youth Affairs and Sports and affiliated with the International Table Tennis Federation, was acknowledged as the apex regulator with the highest responsibility.
Abuse of Dominant Position: What the Commission Found
Under Section 4 of the Competition Act, the Commission found that the Suburban Table Tennis Association's (TSTTA) WhatsApp advisory functioned as a de facto entry barrier, discouraging players from associating with the independent TTFSL, thereby violating Section 4(2)(c) of the Act. The CCI also found The Maharashtra State Table Tennis Association's (MSTTA) internal scheme clauses, which imposed blanket bans on participation in unaffiliated tournaments as restrictive. Additionally, The Table Tennis Federation of India's (TTFI) Memorandum of Association contained explicit provisions preventing players and organizers from participating in or conducting non-sanctioned tournaments. Similarly, the Gujarat State Table Tennis Association's (GSTTA), byelaws and circulars barred participation in private tournaments, restricting market access and limiting player mobility. The Commission held that these measures effectively stifled competition, curtailed player freedom, and preserved the monopoly of the traditional governance pyramid.
In addition to abuse of dominance, the CCI also examined these practices through the lens of vertical agreements under Section 3 of the Competition Act. It found that TSTTA's actions violated Section 3(4)(c) and (d) by imposing exclusive dealing arrangements that discouraged players and clubs from joining unaffiliated tournaments. These restrictions were held to cause an appreciable adverse effect on competition(AAEC), further strengthening the anti-competitive impact of the conduct in question.
Key Lessons for Sports Governance in India
1. Regulatory roles do not grant immunity: The CCI consistently treats sports federations as “enterprises” under Section 2(h) of the Competition Act when they engage in economic activities. It adopts a functional rather than a formal approach. This has been affirmed in landmark cases such as Hemant Sharma & Others v. All India Chess Federation, Dhanraj Pillay and Others v. Hockey India, and Surinder Singh Barmi v. Board for Control of Cricket in India. Thus, even non-profit sports bodies are subject to competition law if their activities have an economic dimension.
2. Monopolies must not become gatekeeping tools: Pyramidal governance structures, while designed for orderly regulation, can be misused to stifle innovation, restrict competition, and block fair participation. Such gatekeeping harms the overall ecosystem of the sport.
3. The dual role dilemma demands clear separation: Sports federations that act as a regulator and market participant must clearly separate these functions. Failure to do so risks conflicts of interest, undermines fairness, and invites legal sanctions.
4. Sporting autonomy operates within constitutional limits: The freedom to play, organize, and participate in sports is protected under the broader constitutional vision as reflected in the Preamble and it cannot be used to override principles of fairness, competition, and individual rights.
The TT Friendly Super League case is a landmark decision that upholds the constitutional values of freedom, justice, liberty, and equality by ensuring fair access and competition within sports governance. By stripping down restrictive barriers, the Competition Commission of India established that freedom of enterprise extends even to sporting arenas, thereby protecting players' rights and promoting inclusive participation. This decision establishes a strong precedent that sports federations must regulate without monopolizing, safeguard the spirit of the game without restricting players, and must ensure that fair play is reflected not only on the field but also in governance and policy-making.
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