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April 16, 2026 : The Competition Commission of India has dismissed allegations of anti-competitive conduct in the award of large-scale solar power projects by the Solar Energy Corporation of India, holding that no prima facie case was made out under the Competition Act, 2002.
Passing an order under Section 26(2), a coram comprising Chairperson Ravneet Kaur and Members Anil Agrawal, Sweta Kakkad and Deepak Anurag closed the proceedings initiated on a complaint filed by Ravi Sharma.
The case arose from a 2019 Request for Selection (RfS) issued by SECI for setting up 7 GW of solar power capacity linked with domestic manufacturing facilities. The informant alleged that the tender structure favoured large players such as Adani Enterprises Ltd., Adani Green Energy Limited and Azure Power India Private Limited, while effectively excluding smaller participants.
It was further alleged that provisions such as the “Green Shoe Option,” capacity allocation mechanisms, and subsequent developments including tariff revisions and project reallocations enabled concentration of projects in favour of select entities. The informant also claimed bid manipulation, coordination among parties, and abuse of dominant position.
After examining the material on record, the Commission found no evidence to substantiate the existence of any anti-competitive agreement under Section 3 of the Act. It noted that the allegations of collusion and bid rigging were unsupported by cogent material.
On the issue of tender design, the CCI reiterated that framing of eligibility conditions and bid structures falls within the prerogative of the procurer. It observed that such conditions cannot be termed anti-competitive merely because they may favour certain bidders, particularly when they are aligned with policy objectives and procurement requirements.
The Commission also found that the informant failed to properly delineate the relevant market or establish dominance of any of the opposite parties. It noted that India’s power generation sector includes multiple significant players such as NTPC Limited, Power Grid Corporation of India Ltd., Tata Power, Torrent Power and Reliance Power, as well as renewable energy companies like JSW Energy and Suzlon Energy.
In this context, the CCI held that the Adani Group does not appear to be dominant in the broader power generation market, and no evidence was placed on record to demonstrate abuse through exclusionary conduct, leveraging, or cross-subsidisation.
Addressing clause-specific concerns, the Commission noted that the “Green Shoe Option” was introduced pursuant to directions from the Ministry of New and Renewable Energy and had also been examined by the Central Electricity Regulatory Commission. It found no competition law violation arising from such provisions.
The Commission further observed that standard practices such as prescribing technical and financial eligibility criteria or linking manufacturing capacity with project allocation do not, by themselves, indicate anti-competitive intent. It also rejected allegations relating to project reallocation and tariff revisions, noting the absence of evidence showing any appreciable adverse effect on competition.
Concluding that no prima facie contravention of Sections 3 or 4 of the Act was established, the Commission ordered closure of the case.
Cause Title: In Re: Ravi Sharma v. Adani Enterprises Ltd. & Ors.
Case No.: 36 of 2024