CASE NAME: Showtyme v. Big Tree Entertainment
CASE NO.: Competition Law – 46 of 2021
COURT: Competition Commission of India
DATE: 12-03-2026
QUORUM: Justice Ravneet Kaur (Chairperson), Justice Anil Agrawal (member), Justice Sweta Kakkad (Member), Justice Deepak Anurag (Member)
FACTS:
The information of the present case is being filed by Vijay Gopal, who is a social activist and the founder of an online movie ticket booking platform called as Showtyme which was launched on 9th March 2026, under the proprietorship firm Vanila Entertainments. This platform was launched as an alternative platform for online ticket booking. It was first opened in Hyderabad and later across India, its services were provided. It was an alternative online platform for the cinema goers to book their tickets online without any hassle.
In this case, the complaint was filed before the Competition Commission of India under Section 19(1)(a) of the Competition Act against the Big Tree Entertainment PVT L.T.D., which Also operates as an online ticket booking platform named BookMyShow. In this case initially many cinema chains and authorities were a part of BookMyShow, but later the Commission retained only Bookmyshow as the opposite party. According to the informant, Vijay Gopal, it was stated that a BookMyShow holds a dominant position in the cinema and entertainment market and hence is misusing its dominance on the other platforms where tickets are booked online. It was stated by him that this platform holds a dominant position in the online movie ticket booking industry in India with a market of share of around 90%.
Certain allegations were also made by the informant, such as the BookMyShow platform charges approximately around Rs.25extra on every ticket as a convenience fee from the customers for booking tickets online and using its platform. From the extra convenience fee from the customers, it shares about Rs. 12 to Rs. 14 per ticket with the multiplexes and Rs. 6-8 with single screen theatres and earns profit. It was stated that the platform Showtyme, it charges Rs.11 per ticket as a convenience fee, which is cheaper than BookMyShow and offers cinemas a Commission of up to Rs. 5 per ticket. But despite offering a better Commission structure, many cinemas refuse to associate with Showtyme. There were certain benefits provided by the platform BookMyShow, which created financial dependence of the entertainment industry, such as interest free monetary deposits or cash loans to several cinemas.
It was also claimed by the informant that the platform BookMyShow has entered various. exclusive agreements with the cinemas for periods ranging from two to five years, which requires them to sell movie tickets only through that platform, disabling the other platforms providing such services. This agreement allegedly disrupted other cinemas from partnering with other online ticket booking platforms.
According to the informant, these practices restricted market access for new platforms and reduced competition in the online ticket booking market, and therefore he approached the Commission alleging that BookMyShow had abused its dominant position and violated the Competition Act.
ISSUE:
- What is the relevant market for the purpose of competition analysis?
- Whether BookMyShow holds the dominant position in the relevant market.
- If BookMyShow is dominant, whether it has abused its dominant position by- Reserving seats during agreements with cinemas, imposing exclusive clauses relating to customer data ownership, adopting discriminatory revenue sharing practices, and entering into exclusive agreements that deny market access to the competitors.
LEGAL PROVISIONS:
Section 4(1) – Prohibits abuse of dominant position.
Section 4(2)(a) – Unfair or discriminatory conditions.
Section 4(2)(b) – Limiting production or technical development
Section 4(2)(c) – Denial of market access to competitors.
Section 19(4) – Factors for determining the dominance.
ARGUMENTS:
APPELLANT:
It was being argued by the appellant in this case that the BookMyShow platform had established a dominant position in the market for online movie ticket booking and was misusing its position to eliminate the competition, claiming it has violated the competition act 2002. It was being stated that since BookMyShow is a platform which holds dominance across all over India, it is controlling a large share of the market because of its strong network of cinemas and brand recognition, most movie theatres prefer to partner with Bookmyshow rather than any other alternative platform. This makes it difficult for the new platforms to enter the market.
The appellant in this case also stated certain facts claiming the dominancy of the platform BookMyShow in the market. The appellant further states that BookMyShow, it charges a high convenience fees of Rs.25 per ticket. From customers for online booking or for using its platform. It is being reflected that the convenience fee is excessive in nature and it increases the overall cost of the movie tickets for the consumers and in contrast the appellant’s platform Showtyme, it only offers a convenience fee of Rs.11 per ticket on the consumers which is significantly lower and more consumer friendly. The appellants further argues that BookMyShow, it shares a portion of the convenience fee with the cinema owners and provide them with the financial incentives to remain associated exclusively with its platform. And multiplexes allegedly receive a higher share compared to single screen theatres, which keeps the dominancy of Bookmyshow running in the market.
It was said that the platform BookMyShow entered into exclusive agreements with several cinema owners and multiplex chains for the periods ranging from two to five years. These agreements allegedly require cinemas to sell tickets online only through BookMyShow and restrict any other platform for booking the tickets online or collaborating with them. The BookMyShow provides interest free monetary deposits and financial advances to the cinema operators and according to the appellant, these deposits create a financial independency between the cinema owners and the BookMyShow, discouraging them from associating with competing platforms such as Showtyme in the entertainment market.
The appellant in this case has personally approached more than 30 theatres and multiplexes in Hyderabad to partner with Showtime. However, most of them refused because they had already entered into agreements with BookMyShow, which created a discrimination in the entertainment market industry.
In the online ticket booking process, it provides reserved seats and customer data ownership which establishes unfair contractual conditions in the market and strengthens its control over the ticket booking ecosystem and limits the opportunities available for the competitors. It was stated that these practices collectively restricted the competition and denied the market access to new entrants, thereby violating section 4 of the Competition Act which prohibits abuse of dominant position.
RESPONDENT:
The BookMyShow denied all the allegations and argue that it does not hold a dominant position in the relevant market. It stated that the relevant market should include all forms of ticket sales, including offline box office bookings, as consumers could choose to purchase tickets directly from the cinemas, creating an option. It was argued that consumers have multiple options to purchase movie tickets, including buying tickets directly from the cinema box offices and therefore the respondent claim that the online ticket booking services face competition from offline ticket sales as well and not create and reject the claims made on the dominance in the market.
The cinema operators are free to negotiate contractual terms and choose whether to associate with the platform BookMyShow. It is not imposed that all operators must form an agreement with the platform, but rather its being negotiated and then an agreement was formed. The agreements with cinemas are voluntary commercial arrangements. The theatres willingly enter into these agreements after negotiating terms that are mutually beneficial. The respondent stated that such agreements are common in business and are necessary to ensure smooth operation of ticket booking services.
They responded in this case submitted that any exclusivity clauses or lock-in periods were introduced only to protect the financial investments made by Bookmyshow, such as advance deposits and the Technical Support provided to the cinemas. These arrangements help the company recover its investments and ensure stability in business relationships and denied the services being provided by them to stay in the agreement with the operators. Here the respondent also addressed the allegation made regarding the seat reservation clauses. It’s stated to avoid the problem of double booking in the theatres where real time integration with booking systems was not available, the seats are reserved.
Further on, it is stated that revenue sharing arrangements differ from theatre to theatre because the cinemas vary in terms of infrastructure, location, number of screens and ticket sales volume. Therefore, different Commission structures cannot be considered discriminatory or unfair. It is made to suit the different structures available. Regarding the convenience fee, it is clearly disclosed and represented to the customers. The convenience fee is added for providing the online services. Based on these arguments, the respondent requested the Commission to dismiss the complaint, stating that its business practices were legitimate commercial strategies and did not violate the provisions of the Competition Act, 2002.
ANALYSIS:
The court in this case determined the relevant market and held that the online movie ticket booking platforms provide services such as online payment, seat selection and convenience, which are different from traditional box office ticket sales and therefore the relevant market was defined as the ‘market for online intermediation services from movie tickets in India’.
The court also analysed whether the dominance was abused. It was found that the seat reservation criteria given in the booking platform Is operationally necessary to avoid the problem of double bookings and the revenue sharing arrangements with different cinemas were also considered reasonable because theatres also vary in size, infrastructure and ticket sales. Therefore, it was held that the provisions provided by the BookMyShow platform is not violating any competition act, any provisions of competition in 2002. Also, regarding the. Exclusive agreements. The Commission noted that such agreements allowed the platform to recover its financial investments in theatres and did not completely prevent other platforms for mentoring the market.
JUDGMENT:
The Competition Commission of India in this case held that although Big Tree Entertainment PVT L.T.D. enjoys a strong position in the market for the online movie ticket booking services, there was no sufficient evidence to prove the abuse of dominant position under the Competition Act 2002 and therefore, there was no contravention of the Sections 4(2)(a), 4(2)(c), of the Act was established and the case was ordered to be closed.
CONCLUSION:
This case highlights the role of the Competition Commission of India in examining allegations of abuse of dominance in the digital markets. Although Big Tree Entertainment Private Limited was found to have a strong market presence, the Commission concluded that its practices did not violate the competition Act 2002 and therefore the allegations made by the informant were dismissed and the case was closed.
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WRITTEN BY: MEENAKSHI DANGI.
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