COMPETITION LAW

RESEARCH PAPER ON:

RESALE PRICE MAINTENANCE AND ITS LEGAL

IMPLICATIONS

Submitted By

RITU KUMAR

LL.M (2020-2021)

(CORPORATE AND COMMERCIAL LAWS)

Submitted to

Ms. Priya Vijay

Faculty of Competition Law

National University of Study and Research in Law,

Ranchi

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 DECLARATION

I hereby declare that the project work entitled “Resale Price maintenance and its legal
implications” study as submitted to National University of Study and Research in Law is a
record of an original work done by me under the guidance of Ms. Priya Vijay.

Furthermore, I confirm that: −

- this work has been composed by me without assistance of any;

− I have clearly referenced in accordance with departmental requirements, in both the text
and the bibliography or references, all sources (either from a printed source, internet or any
other source) used in the work;

− all data and findings in the work have not been falsified or embellished;

− this work has not been published.

I confirm that I understand that my work may be electronically checked for plagiarism by the
use of plagiarism detection software and stored on a third party’s server for eventual future
comparison.

I thank all of them !

Ritu Kumar

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 ACKNOWLEDGMENT

My research paper topic is “Resale price maintenance and its legal implications”. I take

this opportunity to express my profound gratitude and deep regards to my guide Ms Priya

Vijay for her exemplary guidance, monitoring and constant encouragement throughout the

course of this project. The blessing, help and guidance given by him time to time shall carry

me a long way in the journey of life on which I am about to embark.

I also take this opportunity to express a deep sense of gratitude to my fellow batchmates,

library staff and my friends for their valuable information and guidance, which helped me in

completing this task through various stages.

I would also thank my Institution and my faculty members without whom this research paper

would have been a distant reality. I also extend my heartfelt thanks to my family and well

wishers.

THANKYOU

RITU KUMAR

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 AIMS AND OBJECTIVES

1. To study and analyse the resale price maintenance in India under the Competition Act,
2002 .
2. To examine its implications or effects in the market.
3. To the study the relevant case law pertaining the same.

RESEARCH METHODOLOGY

The researcher aims to seek doctrinal source including primary and secondary sources such
as books, journals newspaper, websites.

LIST OF STATUE

1. Competition Act, 2002

LIST OF ABBREVIATIONS

RPM - Resale price maintenance

AAEC -appreciable adverse effect on competition
HMIL - Hyundai Motor India Limited
MRP - maximum retail price
CCI - Commission of India

RESEARH QUESTIONS
How is RPM treated under the competition act?
Is it beneficial for the consumers in the market?
How it restricts competition in the market?
What is the CCI views pertaining to the resale price maintenance?

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Page 5 of 17
 TABLE OF CONTENTS

1. DECLARATION ……………………………………………………….2

2. ACKNOWLEDGMENT………………………………………………...3

3. AIMS AND OBJECTIVES……………………………………………...4

4. RESEARCH METHODOLOGY………………………………………..4

5. LIST OF STATUE……………………………………………………….4

6. LIST OF ABBREVIATIONS……………………………………………4

7. INTRODUCTION……………………………………………………….5

8. RESALE PRICE SALE AGREEMENTS………………………………..6

9. PER SE AND RULE OF REASON………………………………………7

10. COMPETITION DISTORTIONS AND IMPLICATIONS……………...9

11. HYUNDAI MOTOR INDIA LIMITED

ON RESALE PRICE MAINTENANCE …………………………………11

12. CONCLUSION…………………………………………………………....14

13. BIBLIOGRAPHY………………………………………………………….16

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 INTRODUCTION

"In the Competition Act, 2002, the principle of Resale Price Maintenance ("RPM") is
described. RPM is a contractual agreement between the manufacturer and the distributor or
wholesaler or any other party to the supply chain which imposes on the manufacturer a resale
price which allows the distributor to sell the product. This allows the manufacturer to keep
end-customers at a uniform price. The definition itself is not unlawful but, under conditions,
is considered a breach of the Act.1

Pursuant to Section 3(4)(e) of the Act 2, resale price maintenance is specified as "any
agreement to sell goods provided that the prices to be charged on resale by the buyer are the
prices stipulated by the seller unless it is clearly stated that prices below those prices may be
charged". Also known as vertical price fixing, RPM refers to arrangements or practices in a
distribution chain between companies at various levels, wherein an organization determines
the resale price at which a distributor must sell a product or service. RPM controls the resale
price of a specific manufacturer's goods or services as a vertical intra-brand restriction. In its
normal form, RPM is the practice of setting a price floor below which, as in the case of
minimum resale price maintenance, sales cannot occur.3 RPM is, in its classic formulation,
the act of directly regulating the retail transaction price for the goods of the producer. RPM
may also, however, be achieved by such schemes in which a manufacturer unilaterally
declares its recommended retail prices and avoids negotiating with retailers that do not obey
its suggestions.

The Constituents of RPM includes resale of the product and the resale price is either set by
the original seller (who may also be the manufacturer) or the resale price is fixed by the
original seller, and is not authorized to be sold by the buyer. Among other practices, RPM is
expressly recommended under the Act, but only if it creates a "appreciable adverse effect on
competition" ('AAEC') in India. Therefore, it is important to understand the circumstances
under which RPM agreements in India can lead to AAEC.

AAEC is measured by measuring the negative and positive impact on competition in the
market that an agreement has or may have. Different considerations need to be considered,
such as the evaluation of market competition, barriers to entry or foreclosure of existing
1
https://libertatem.in/economy/what-is-resale-price-maintenance/
2
Competition act 2002(last visited 27th January, 2020)
3
https://www.mondaq.com/india/antitrust-eu-competition-/633522/the-fixation-with-fixing-resale-prices(last
visited 27th January, 2020)

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competitors, etc. The accrual of benefits to customers and changes in the manufacturing or
distribution chain, etc., which are often evaluated, are some beneficial results of an
agreement.4

RESALE PRICE SALE AGREEMENTS

A resale price management (RPM) arrangement is a deal under which a producer and a dealer
from Downstream agree on a minimum or maximum price to be paid to their customers by
the retailer. Any of the four forms listed -minimum, maximum, recommended, set- can be a
resale price agreement. A price is deemed to be the minimum resale price if the agreement
forbids resale at a price below the price provided for in the agreement between the producer
and the dealer. The aim is generally to prevent market rivalry above a certain price between
retailers.

In the case of agricultural goods, this form of price flooring often happens when governments
set a price floor to ensure minimum revenues for farmers. On the other hand, maximum
resale price maintenance imposes a resale limit at a price above the prescribed price. The
maximum resale price serves as a price limit and is frequently imposed by retailers to protect
the customer from over-pricing. Generally, there is a maximum retail price (MRP) printed on
all consumable goods. 5The retailer is unable to charge above the price. If the supplier is not
bound by the price stipulated by the seller, the price agreement is called the recommended
(suggested) price, since the price is just the recommended price and not a binding price in
general.

The goal is to help standardize prices between locations. However, this may be contrary to
the rules of competition, where collusion or parallelism of some type is deemed to adversely
affect market performance. A "fixed" resale price is the last category. Under this category, the
manufacturer imposes a price at which it is possible to resell the commodity, neither higher
nor lower than that price.In reality, however, even the minimum resale price has the same
impact as the fixed resale price unless the retailers collectively charge a higher price than the
minimum prescribed price. This is because the retailers would not be able to charge a higher
4
https://lakshmisri.com/insights/articles/controlling-price-of-supply-down-the-ladder-an-antitrust-
breakdown/#(last visited 27th January, 2020)
5
Bhawna Gulati, Resale Price Maintenance Agreements, Indian Perspective and International
Practices available at:
https://www.academia.edu/7627001/Resale_Price_Maintenance_Agreements_Indian_Perspective_and_Internati
onal_Practices_Apropos_Bhawna_Gulati_Introduction_Resale_Price (last visited 27th January, 2020)

Page 8 of 17
price in the absence of any such collusion, except at the risk of losing out on customers,
because if others charge the minimum resale price (as if some charge the minimum resale
price Therefore, while retailers are free to assign the minimum RPM, it is not economically
feasible to do so.6

Competition regulators around the world are therefore more narrowly concerned with price
fixing and minimum RPMs, since they are seen to have a more serious impact on the
competition process. First of all, they kill the market rivalry between retailers dealing in a
product, i.e. intra-brand price competition, and secondly, they make the pricing policy very
clear, which could encourage collusion and conscious parallelism. Note that, in general, the
limit and recommended resale prices are not punishable.

Indian competition law also exempts from the application the maximum resale price. Sec 3(4)
(e) notes that 'resale price maintenance' specifically indicates that, under the Indian Act, a
maximum or recommended price is permitted as long as the arrangement between the parties
allows a price to be charged below the price specified. 

PER SE AND RULE OF REASON

A 'per se' infringement needs no further research into the actual impact of the practice on the
market or the intentions of certain people who are participating in the practice. Once the per
se code of conduct is established, the conduct is illegal without any investigation into its
specific competitive or anti-competitive consequences. The 'Rule of reason' method is
juxtaposed to this one. In this strategy, the claimant is also required, along with the obligation
to prove the existence of the alleged actions (agreement), to prove that the anti-competitive
effects of such conduct are greater than their pro-competitive effects. Therefore, the alleged
arrangement can be tolerated under the rule of Reason method if the pro-competitive
advantages resulting from such actions outweigh the anti-competitive consequences. The
detrimental impact of such actions on the free market economy and competition is the very
reason why such activities are made illegal per se.

Unlawful conduct per se is distinguished by the strong likelihood of anti-competitive

consequences and the improbability of adequate reward for competitive virtues. The plaintiff
thus only has to prove the presence of the supposed anti-competitive action in the case of 'per
se' violations.The purpose or goal or the potential consideration of productivity is of no
importance because the action is 'per se' forbidden. Cases which occur that do not suit the
6
Ibid

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generalization, but a per se rule represents the decision that such cases are not sufficiently
common or significant to warrant the time and effort taken to classify them.

Per se is a Latin term that means 'these norms in themselves, while they do not find a place in
the formal statutes (i.e. exact terms do not appear in the statutes), but most jurisdictions use
these techniques to deal with breaches of their respective competition laws.

However, India takes a different strategy. None of India's practices was barred per se. Under
the Indian Competition Act, 2002, even cartels that are barred per se in almost all
jurisdictions are subject to the law of reason. At this juncture, it may be necessary to examine
the methods involved in the Indian Competition Act to deal with various anti-competitive
agreements. Section 37 forbids, as anti-competitive, such arrangements that trigger or are
likely to cause substantial adverse effects on competition.

Consequently, it cannot be said that Indian law, which assesses all agreements falling under
Sec 3 on the grounds referred to in Sec 19(3)8, applies per se in India. The informant must
show two things in the case of vertical agreements [Section 3(4)]: first, that the activity
alluded to in the information occurs and, secondly, that the behavior is likely to have a major
adverse impact on competition. Once created, any conduct falling under Section 3 must be
assessed under Section 19(3), which sets out six factors to decide whether or not the conduct
has a noticeable adverse effect on competition. The first three factors set out in Section 19(3)
are: (a) the formation of obstacles to new entrants in the market; (b) the removal of
established competitors from the market; and (c) the foreclosure of competition by
prohibiting them from entering the market; and (c) the evaluation of the anti-competitive
effect of the alleged operation. And the following three variables, namely (d)the accrual of
consumer benefits; (e) the increase in the production or distribution of goods or the provision
of services; (f) the promotion of technological, scientific and economic growth through the
production or distribution of goods or the provision of services; and (f) the evaluation of the
pro-competitive effects of the alleged activity. Therefore, any supposed activity that may
have anti-competitive consequences within the scope of Section 3 shall be calculated by the
criteria set out in Section 19. (3). The Competition Act would ban only those practices whose
net anti-competitive effects, i.e. anti-competitive effects, outweigh the pro-competitive
effects.9

7
Competition Act, 2002
8
Ibid
9
Supra note 5

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COMPETITION DISTORTIONS AND IMPLICATIONS
"Production efficiency" is one of the economic rationales for antitrust law, ensuring that the
company has the appropriate opportunity to find new and better ways to minimize costs.
Lowest cost and highest output are the two most significant desirable outcomes of a sound
competition policy. Competition may be competitive in price or non-competitive in price.
Price competition focuses mostly on cost control, so that the commodity can be made
available at the lowest possible cost to the final customer. Such low prices not only contribute
to higher profits for the producer, but also to greater customer welfare. On the other hand,
non-price competition can be accomplished by concentrating more on non-price variables,
such as better pre-sale facilities, better marketing programs, better quality goods, improved
post-sales support, etc. Although price rivalry between market participants results in cost
efficiency, better quality is assured by non-price competition. The best solution can therefore
be suggested by an optimal combination of both competitions. However, the importance of
non-pricing competition is often undermined and overshadowed by the objective of
promoting market competition at all levels. 10

The aim of competition law is to safeguard market competition as a means of improving

consumer protection and ensuring that resources are distributed effectively. This obviously
makes it clear that the protection of competition is a way of achieving the "greater end,"
which is the "maximization of consumer welfare." Therefore, it is clear that competition law
aims to protect competition and not just price competition, and there should be space for
variance as long as the defense of competition does not contribute to welfare maximization. 

Competition at the level of the manufacturer can be split into competition between brands and
intra-brand costs. When distributors resell (competing) different brands, they are said to
compete with each other. Nevertheless, when the distributors are selling (competitive) the
same brand, they appear to be competing intra-brand. If they compete on price, the market,
depending on whether they negotiate with indifferent brands or the same brand, becomes
inter-brand price competition and intra-brand price competition.11

10
Ibid
11
Divya Sharma, Resale Price Maintenance As A Vertical Restraint Under The Competition Act, 2002,
Competition Commission Of India New Delhi June 2012 available at:
https://citeseerx.ist.psu.edu/viewdoc/download?Doi=10.1.1.456.9435&rep=rep1&type=pdf pg 11(last visited
27th jan, 2020)

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Intra-brand price competition is supposedly destroyed by resale price maintenance deals
because the retailer sets the minimum price beyond which its goods will not be resold. This
inevitably makes market competition among such retailers impossible because they are
unable to sell below certain prices; otherwise, penalties would be levied (as specified in the
RPM Agreement). Apprehension of the perceived potential of the minimum RPM to
eradicate intra-brand price rivalry has led competition authorities in various jurisdictions to
ban and punish such actions.

It is necessary, however, to recognize that competition law is not an end in itself, but a means
of achieving larger goals. Competition law aims to protect competition and not just price
competition, and there should be room for variance as long as competition protection does
not contribute to welfare maximization. Therefore, if the prohibition of RPM agreements
leads to decreased consumer welfare, enhanced consumer welfare should be permitted.12

There are certains implications to this:

RPM and Free- Rider problem:

A free rider is someone who, without having to pay fees, receives the benefits of someone
else's investment. A high-tech, information-intensive consumer good may be an example of
the free-rider problem, where pre-sale assistance by a knowledgeable salesperson at a retail
establishment is needed to educate and convince a consumer of the merits of the product. The
shopper leaves the store without making a purchase after collecting the necessary details from
the full-service retailer and visits a discount store to buy the product at a lower price. The
discount shop, which can deliver the cheaper price because it does not recruit trained
salespeople, enjoys a free ride from the full-service retailer that incurs the product marketing
expenses.13

For a full-service store, this condition could be unsustainable. It does not continue to recruit
knowledgeable salespersons and yet meet the low price of the discounter. To survive, the full
service retailer must curtail service. The free rider, in the end, prohibits customers from
accessing the retail services they value. Those customers must determine what brand of good
to buy, or whether to buy a good at all, with less than ideal knowledge about their selection of
choices. As a consequence, goods requiring retail service are less affordable.

12
ibid
13
Supra note 8 pg 14

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The effects are bad for customers and bad for the producer. The possibility that free riders
can fully extinguish retail service in a market without RPM requires that permissible vertical
non-price constraints are not up to the task. It also requires that retailers do not distinguish
certain elements of retail operation that generate demand for the product of the manufacturer
from other activities of the retailer and market them on a stand-alone basis to customers or
the manufacturer. Transaction costs tend to prohibit separate service transactions from
removing all free riding in certain cases.14

Beyond the Free- Rider problem:

Even when customers are unlikely to ride freely, limited RPM will alleviate issues between
producers and retailers. For example, retailers recognize their own markup, not the
manufacturer's markup, as they decide on the level and types of services and sales efforts to
provide for a product. Suppose Levi Strauss & Co, a famous manufacturer of denim wear, has
a $50 wholesale markup on a women's jeans brand, while its distributor has a $10 retail
markup. The retailer would not spend $15 on promotional displays or increased advertising
activities to purchase an additional customer; however, the income of Levi would increase, so
it is in the interest of Levi to allow the retailer to invest and compete for incremental sales.

This example shows just how easily it is possible to misalign the private interests of retailers
and manufacturers, especially when markups differ greatly. In stark contrast to price-fixing
deals, investment in the promotional brand image or sales-effort is competitive and based on
incremental sales. Minimum RPM agreements will provide retailers with greater discount-
restricted markups to fix the incentive problem; express the types of facilities, effort, and
brand image needed to track retail prices, and terminate distributors who do not comply.15

HYUNDAI MOTOR INDIA LIMITED ON RESALE PRICE

MAINTENANCE
On June 14, 2017, after nearly a decade of aggressive compliance, the Competition
Commission of India (CCI) released its first ever decision to find a company to engage in
resale price maintenance (RPM).  RPM's allegations were made against Hyundai Motor India
Limited (HMIL). HMIL is the Indian subsidiary of Hyundai Motor Corporation, a South

14
Supra note 5
15
Supra note 8

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Korean multinational automotive manufacturer.16. The following explains the specifics of the
allegations made against HMIL:

 Dealership Exclusive Arrangements:17

HMIL was alleged to have entered into exclusive dealership agreements with its
distributors to the degree that distributors were bound to purchase spare parts,
accessories and all other specifications, either directly from HMIL or through HMIL-
approved distributors; and distributors were forced to obtain HMIL's prior approval
before taking over another brand's distributorships.

 Discount Control Mechanism:18

"It was alleged that a "Discount control mechanism" was enforced by HMIL that
controlled the maximum allowable discount levels that a dealer could offer for the
sale of HMIL manufactured passenger cars. The dealers were not allowed to offer
discounts above the range prescribed.

 Hub and Spoke Arrangements:19

HMIL allegedly perpetuated, by way of being a common supplier, bilateral vertical

agreements between the supplier and the dealers and horizontal agreements between
the dealers themselves. It was alleged that HMIL was liable for price collusion among
competitors through a series of "hub-and-spoke" arrangements by acting as a hub
(common supplier) between spokes (dealers).

 Tie-in Arrangement:20

Finally, HMIL was claimed to have leverage over the supply sources and thus tied the
purchasing of desired cars to the selling to its dealers of high-priced and unwanted
cars. HMIL also allegedly identified supply sources for supplementary products for
dealers, resulting in a "tie-in" agreement. In this situation, the complementary
products were lubricants, CNG kits and car insurance.
16
Anshuman Sakle, Resale Price Maintenance : Has CCI Upped the Ante?, November 22, 2017 available at:
https://competition.cyrilamarchandblogs.com/2017/11/resale-price-maintenance-cci-upped-ante/
17
ibid
18
ibid
19
ibid
20
ibid

Page 14 of 17
The Commission found that HMIL's Discount Control Scheme was in violation of the RPM
provision under the Indian Competition Act, after a review of the submissions made by both
parties. The Discount control management preserved the resale price of Hyundai vehicles,
which did not offer any advantages to the customer. The Commission concluded that 'it
inevitably contributes to lower intra-brand competition and overall higher prices for products
once RPM is implemented.'

The Commission did not find, however, that HMIL was in violation of the claim of an
exclusive dealership contract or refusal to trade. The Commission did not comment on the
plans for the hub and spoke arrangements. With regard to the tie-in arrangements, the
Commission agreed with the claims of HMIL that there is an empirical rationale and valid
commercial interest in the revocation of the warranty on the use of non-CEV 2) CNG kits and
non-recommended oils/lubricants, as the cost of the warranty will be borne by HMIL. In the
case of car insurance services, the Commission found that, because the option of car
insurance services from the list of insurance services offered by HMIL was not obligatory for
customers, there was no tie-in agreement.

In view of the above, the CCI levied on HMIL a penalty amounting to INR 87 crore
(approximately USD 13.5 million). In the previous case, the Commission 3) has also
penalized HMIL for anti-competitive activity and misuse of its dominant role in the
aftermarket automotive market (automobile case). A lot has changed between then and now.

A ruling was released by the Supreme Court of India to set the volume of the penalty
proportionately based on the related turnover instead of the company's total turnover found to
be in violation of the Competition Act.21

Following the orders of the Apex Court, in the case of HMIL, the CCI was given the
opportunity, for the first time since the Supreme Court gave its judgment, to determine the
penalty based on the related turnover. Considering that, in the automotive case, the CCI had
already levied a penalty of 2% on the average turnover of HMIL for the last three financial
years, in this case the penalty level was set at 0.3% of the applicable turnover.

21
Shilpi Bhattacharya,Aditi Kheman Hyundai and the Law of Resale Price Maintenance in India, Economic and
Polictical weekly, Vol. 55, Issue No. 50, 19 Dec, 2020 Updated on 19 December 2020 available at;
https://www.epw.in/journal/2020/50/special-articles/hyundai-and-law-resale-price-maintenance-india.html (last
visited 30th Jan,2020)

Page 15 of 17
The CCI took cognizance of the fact that, in the automotive situation, HMIL was previously
penalized, although the Commission's order does not explicitly state whether that was taken
as an aggravating factor in order to arrive at a proportionate penalty. Proportionality, no
supra-normal income and the introduction of a competition law enforcement programme
were the mitigating factors properly considered by the Tribunal.22

The CCI has taken a pragmatic approach to its path of ensuring enforcement by not only
acknowledging a working program in compliance with competition law as a mitigating
factor, but also by taking into account the general practices prevailing in all sectors while
being circumspect of the legitimate interests and business justifications connected with them.

CONCLUSION
Recognizing that vertical agreements, especially resale price maintenance (RPM) agreements,
do pose serious concerns, anxieties and experiences on both sides, unlike horizontal
agreements, that is to say, favorable to fostering competitiveness and sometimes causing
impediments or negative impacts on competitiveness. Discussion of benefits and losses has
created a substantial chunk of this review, so the real challenge is how to strike a balance
between conflicting claims; benefits versus loss. A different twist has been given to Wisdom
practiced for about 100 years in one of the most evolved and capitalized structures, America,
if not entirely reversed. The law attaching illegality per se to RPM has now been converted
into a rule of reason test by the US SC in the Leegin case.

No doubt, if not illegal per se after the Leegin RPM agreements, they are also not legal per
se. Therefore, a large area has been left empty, or in other words, a space filled by flexibility,
vagueness and ambiguity in which the courts and law enforcement agencies are subjected to a
vast lack of empirical evidence and related economic analysis to more inventive and
circumspect and innovative RPM agreements. But at the same time, the status of legality
should not be granted, nor should such agreements destroy the market, trigger market failure,
promote a culture of cartelisation and build obstacles for new entrants. The need to find a
balance that is not, per se, neutral.

The CCI is of the opinion that any agreement which has the direct or indirect objective of
setting a fixed or minimum resale price level can, if it has an AAEC on the market, preclude
competition. In the Hyundai Event, RPM has been extended to include any behavior that

22
ibid

Page 16 of 17
fixes the distribution margin, fixes the maximum discount level, offers rebates, transfers the
promotional costs based on adherence to a given price level, links resale price to competitors'
resale prices, or uses threats, coercion, warnings, fines, delay or suspension of deliveries as a
means of fixing the price.

BIBLIOGRAPHY

1. Shilpi Bhattacharya,Aditi Kheman Hyundai and the Law of Resale Price Maintenance
in India, Economic and Polictical weekly, Vol. 55, Issue No. 50, 19 Dec, 2020
Updated on 19 December 2020 available at;
https://www.epw.in/journal/2020/50/special-articles/hyundai-and-law-resale-price-
maintenance-india.html
2. Anshuman Sakle, Resale Price Maintenance : Has CCI Upped the Ante?, November
22, 2017 available at: https://competition.cyrilamarchandblogs.com/2017/11/resale-
price-maintenance-cci-upped-ante/
3. Divya Sharma, Resale Price Maintenance As A Vertical Restraint Under The
Competition Act, 2002, Competition Commission Of India New Delhi June 2012
available at: https://citeseerx.ist.psu.edu/viewdoc/download?
Doi=10.1.1.456.9435&rep=rep1&type=pdf
4. Bhawna Gulati, Resale Price Maintenance Agreements, Indian Perspective and
International Practices available at:
https://www.academia.edu/7627001/Resale_Price_Maintenance_Agreements_Indian_
Perspective_and_International_Practices_Apropos_Bhawna_Gulati_Introduction_Res
ale_Price
5. https://lakshmisri.com/insights/articles/controlling-price-of-supply-down-the-ladder-
an-antitrust-breakdown/#
6. https://www.mondaq.com/india/antitrust-eu-competition-/633522/the-fixation-with-
fixing-resale-prices
7. https://libertatem.in/economy/what-is-resale-price-maintenance/

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