A Cross-Jurisdictional Analysis of Competition Law Perspectives from The Eu, Us, And India.

Competition law governs markets by forestalling monopolistic behavior, encouraging fair competition, and safeguarding consumer interests. With growing digital markets, there has been increased concern regarding Big Tech dominance, data monopolies, and anti-competitive takeovers. This paper contrasts competition law regimes in the EU, US, and India based on their legal systems, enforcement mechanisms, and methods for regulating digital platforms. Major legislative frameworks are the Sherman Act (1890), Clayton Act (1914), and FTC Act (1914) in the US; Articles 101 and 102 of the TFEU in the EU; and India's Competition Act (2002). The EU adopts a strict interventionist approach, the US is market efficiency-oriented, and India combines both but has enforcement issues in the digital economy. The research also delves into India's draft Digital Competition Act (DCA), bringing measures to prevent anti-competitive behaviours proactively. Highlighting international cooperation, more challenging merger control, AI-based enforcement, and global regulatory cooperation, the paper urges a competitive and equitable digital economy.