COMPARATIVE GOVERNANCE OF DIGITAL PLATFORMS AND AI-DRIVEN CARTELISATION: TOWARDS COMPETITION POLICY FRAMEWORK FOR VIKSIT BHARAT

Digital platforms have become the principal infrastructure through which contemporary commerce, communication, and information flow. Their intermediary position, combined with data accumulation and network effects, generates durable market power that traditional ex-post competition law struggles to discipline within meaningful time frames. The rise of algorithmic pricing compounds this difficulty by enabling forms of coordination that do not require explicit human agreement, thereby straining the doctrinal foundations of both Section 3 of the Competition Act, 2002 and Article 101 of the Treaty on the Functioning of the European Union. This article undertakes a comparative analysis of the governance frameworks adopted in India, the European Union, the United States, and the United Kingdom, and examines the distinct typologies of algorithmic collusion identified in the economic and legal literature. It concludes by proposing institutional and doctrinal reforms suited to India's Viksit Bharat @2047 objectives, arguing for a calibrated hybrid model that combines ex-ante gatekeeper regulation with strengthened ex-post enforcement and algorithmic accountability mechanisms.