UNMASKING CARTELS: A COMPARATIVE ANALYSIS OF ANTITRUST LENIENCY AND LESSER PENALTY SCHEMES IN THE USA, UK, EU, AND INDIA

AUTHOR – ARJUN SAJISH, STUDENT AT CHRIST UNIVERSITY, PUNE LAVASA

BEST CITATION – ARJUN SAJISH, UNMASKING CARTELS: A COMPARATIVE ANALYSIS OF ANTITRUST LENIENCY AND LESSER PENALTY SCHEMES IN THE USA, UK, EU, AND INDIA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (7) OF 2026, PG. 751-760, APIS – 3920 – 0001 & ISSN – 2583-2344. DOI – https://doi.org/10.65393/IJLRV6I782

Abstract

This paper provides a comparative analysis of antitrust leniency and lesser penalty programs in four significant jurisdictions: the US, UK, EU, and India. In this context, through the study of the statutory and procedural framework, it evaluates the criteria for leniency, reduction percentages, confidentiality clauses, and withdrawal procedures. This paper also examines the recent development, namely in India where the Lesser Penalty Regulations, 2024 introduce the “Lesser Penalty Plus” program. The research findings are based on the examination of the substantive law and case law principles, illustrating the way in which competition authorities use tiered rewards in order to undermine anticompetitive arrangements as well as encourage voluntary compliance

Keywords: Withdrawal, lesser Penalty Regulations, Substantive Law, Anticompetitive Arrangements