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PHARMACEUTICAL SECTOR AND COMPETITION COMMISSION OF INDIA: AN ANALYSIS OF JUDICIAL PRONOUNCEMENTS OF COMPETITION COMMISSION OF INDIA
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Article Details
PHARMACEUTICAL SECTOR AND
COMPETITION COMMISSION OF INDIA: AN ANALYSIS OF JUDICIAL PRONOUNCEMENTS OF
COMPETITION COMMISSION OF INDIA
AUTHROED BY - MS. PRIYANKA CHOUDHARY
*
Abstract
Indian
Pharmaceutical Industry is one of the major contributors in the nation’s GDP leading
to the prosperous growth of the economy. The practices followed in the pharma
industry have a major impact both from the consumer and the market perspective.
It is also very important to understand that pharmaceutical industry is an
industry which works towards human welfare as the main purpose that is carried
out in the industry is to manufacture lifesaving drugs and ensure the supply of
those drugs in the form of medicines across the markets. In the present paper
the researchers have focused upon the causes and possible reasons of
monopolistic trade practices in the medical and pharmaceutical sector and the
Role of CCI to overcome the same and have suggested methods by which the said
practices can be eliminated to maintain a healthy competitive market
environment.
Keywords: Anti-competitive,
Regulations, Drug Control, Transparency, Health Care, Competition, Monopoly.
1.
INTRODUCTION
Life is the very subject matter of
all debates in relating to policy implementations and public health - whether
in terms of access to medicines, sovereignty over living and genetic material,
privacy and integrity in the individual body[1].
Healthcare is one of the most basic needs and an inviolable right of every
human being. Health and human development are interdepended and both contribute
towards each other to build the other strong. Various International as well as
national forums have recognized the right to access highest standards of health
including India[2]. Right
to access to quality and affordable medicines is an important component of
right to health. However, at times, this right to access to medicines gets
violated in the midst of many anticompetitive practices.[3]
Until 2002, India did not have a
competition law regime. The earlier regime consisted of the Monopolies and
Restrictive Trade Practices Act, 1969. MRTP was later on substituted by the
Competition Act in 2002 and amended in 2007.[4] The
Competition legislation of India came into full force after notification of major
provisions i.e. the provisions relating to anti-competitive practice and abuse
of dominance were brought into force in May 2009 during the second phase of
implementations and provisions relating to combination to be brought into force
in during third phase of implementations in June 2011.
The Competition law is essentially a
legal framework to ensure curbing of monopolistic measures in commerce and
industry. It is an instrument to intervene in markets in the situations of
market dominance, monopoly and correct market failures. It is concerned with
the promotion and maintenance of competition for the benefit of society.[5] It is founded on the elementary
postulates that market forces and their contracts need to be structured in a
competitive fashion. Such laws primarily seek to encourage competitors to
compete against each other and thereby create an economically efficient free
market system. Thus, competition law and authorities intercede whenever
commercial contracts are found to be obstructive in nature.
Since its inception, CCI has dealt with around sixty cases related to
pharmaceutical and the healthcare sector. While dealing with the cases CCI perceived that the pharmaceutical sector is
induced information asymmetry (uneven or disproportionate) and demands
influenced by the suppliers that ultimately influences the choice of the
consumers. As a result in such a scenario various kinds of practices occur
which limits the markets from working effectively and efficiently. Moreover, CCI has also depicted its concern regarding the
need of regulation in the sector. Also identification of regulatory gaps and
overreach and the need of requisite reforms are other critical factors which
need to be assessed for determining affordable and quality healthcare through
proper functioning of the markets.
2.
OBJECTIVE OF RESEARCH
In the famous case of East Line
Projects Pvt. Ltd. v. Dr. B. Borooah Cancer Institute Guwahati[6]one
of the conditions in a tender to establish a pharmacy was challenged. The
challenge was on the ground that “the stockiest enjoy a dominant position and
if he is allowed to compete with the distributor or the retailer, it will
amount to abuse of dominant position which will be in violation of the
provisions of Section 4 of the Competition Act, 2002”. However, the Court found
that “considering the avowed object for which the pharmacy is going to be
established, the Competition Act, 2002 does not apply in the matter.” Therefore,
through this study, the researcher aims to make an analysis of such kind of
cases relating too the pharma industry, and wants to determine the causes as a
result of which anti-competitive and monopolistic trade practices are existing
in the pharmaceutical sector.
3.
ANALYSIS OF COMPETITION
COMMISSION OF INDIA’S INTROSPECTION IN PHARMACEUTICAL AND HEALTHCARE SECTOR
Since its commencement, the
Competition Commission of India has received approximately Sixty cases
pertaining to the pharmaceutical and healthcare sector. While adjudicating the
matters, the Commission has observed that the pharmaceutical sector is
characterised by information asymmetry and supplier-induced demand that
significantly circumscribes consumer choice, a condition necessary for
well-functioning markets[7]. The
Commission has also expressed the need for optimal regulation in the
pharmaceutical sector. The Commission is of the opinion that identification of
the regulatory gaps/overreach and necessary regulatory reforms is another area
of critical importance in the quest of ensuring affordable and quality
healthcare through well-functioning markets.
In order to meet the requirements of
quality healthcare services and to find out solution, The Commission undertook
a series of initiatives focused on the Pharmaceutical and healthcare sector.
The Commission collaborated with IIM, Ahmedabad and carried out Competition
Assessment of Drug Price Control Order, 2013. It also conducted an internal
review of the regulatory architecture governing the Pharmaceutical sector in
India; and conducted a Technical Workshop on “Competition Issues in the
Healthcare and Pharmaceutical Sector”. The present study discusses the key
issues and recommendations for policy/regulatory reform suggested by CCI in Pharma
Industry in India.
1). Role of Intermediaries in Determining Drug Prices
India produces drugs of worth US $ 33
billion amongst which forty percent of the drugs are exported to other
countries. Interestingly even after such a massive production about 50-65%
people in India does not have a consistent access to the crucial and essential
medicines as a result of which most of the expenses out of pocket expenses are
spent on medicines or for healthcare aspects. Further, high trade margins is one of the
major reasons as a result of which the drug prices in India are considerably
high, The same is evident from the huge disparity in the drug prices existing
and varying from state to state. For instance there is a high disparity in the
market prices and the prices at which the same drugs are purchased by the
states like Rajasthan and Tamil Nadu are under the public procurement and
distribution systems.
Moreover, high margins influences
that which drug is to be sold or distributed by the traders and are used as a
bonus/incentive by the drug companies to market their products. Also the self-regulation
by various trade associations to control the entire mechanism of drug
distribution are responsible for such high prices of drugs and in the in a way completely
disables the competition in the country.
Suggestions
1. The essential drugs can be availed by
the consumers at a standard price by introducing the system of public
procurement widely, which can also help in curbing the problems of high pricing
due to long distribution chain.
2. Supplying the medicines through
online medium by various platforms with certain regulations will not only be
transparent but also will end the monopoly and will build a healthy competition
among various retailers as it is seen in other kind of products.
In view of the same the Ministry of
Health and Family Welfare, Government of India had released draft rules on
Drugs (Sale and Distribution) Rules 2017 which aimed at removing ambiguity
regarding the regulations on sale of drugs through online platforms.
2). Perceptions of the buyers about the quality of Branded
Generics
Throughout the world, low cost
generic drugs are seen as a tough competition against the branded drugs with
expired patent which are marketed at monopolistic prices but on the contrary in
India the pharmaceutical market is captured by the branded generics.
Interestingly the competition between these branded generic version of drugs
are largely based on brand and not on prices. Though the difference in quality
b/w the branded and unbranded generics is not much provided same regulations
are applied on both the categories but still the branded generics are marketed
more as the people have a perception that the branded ones are more effective
and have more therapeutic value as a result the doctors as well as the
pharmacists prescribe the same in order to earn maximum profits. This in turn
helps the companies to earn maximum revenue even though there is no difference
at all between both the varieties.
Suggestions
The regulatory authorities while
granting license to any brand for launching a drug should do a thorough study
about the drug its composition and should see that the clinical trial of the
said drug is done properly or not. Also adding to it the regulatory authorities
should confirm that the qualities of the said drug are actually the same which
the manufacturer claims it to be before granting the license and the permission
to launch the drug.
3). Lack of Transparency and Alternate Arrangements in
Healthcare Services
The lack of availability of
information in the public domain about where the consumers can get the best
treatment or proper healthcare services does not permit the consumers to make
informed choices about the various services. As a result it can be seen that at
many instances the various healthcare providers in the private sectors cheat
the consumers by charging hefty sum of money from them for medicines and
various other services which are otherwise available in the market at
reasonable prices. These private health care services force the people to
obtain the services and purchase of medicines from their intra service
providers by making it compulsory.
Suggestions
Strict Regulations and framework
should be there for ensuring that transparency is there in determining the
prices for various services and medicines provided by the in house pharmacy and
the hospitals.
4). Competition Commission and Regulation of Pharmaceutical
Sector
As it is a well-known fact that
regulations are important to ensure safety, smooth and effective functioning,
quality control etc. In a sector like healthcare regulations are really
necessary on manufacturing, import and purchase and sell of drugs.
But while imposing regulations it
should be kept in mind that the regulations imposed are neither too strict nor
too simple as both have their own implications. As to maintain the spirit of
competitiveness in the market no strict regulations can be imposed on entry and
distribution of the drugs. On the other hand to ensure that the drugs which are
produced and are supplied in the market are not of inferior quality the
regulations imposed can be too simple. As a result there should be a correct
balance between the two and the regulations imposed should be clear transparent
and not arbitrary.
In India the Drugs and Cosmetics
Act, 1940 (DCA) and the Drugs and Cosmetics Rules 1945 are enacted for
maintaining the quality, safety and efficacy of the drugs manufactured,
supplied or imported to India. Moreover, drug controlling authorities like
CDSCO are also responsible for approving and licensing the production, imports
and clinical testing of the new drugs. Also the officials at the state level
are responsible for providing licenses for producing, supplying and selling of
drugs and for monitoring these activities.
But however due to the presence of
two different regulatory authorities at the State as well as the National Level
there arises the following problems:-
i.
Lack of uniformity:- As there
are two different regulators at state and National level this creates a problem
in applying the Drugs and Cosmetics Rules uniformly and effectively throughout
the country as at various instances it has been seen that the Central and the
State Authority fails to have a smooth coordination amongst themselves and as a
result of which currently stringent and even multiple regulations are
prevailing on the production, sale and import of drugs which varies from state
to state and this in turn are creating a lot of trouble for the drug companies
to carry out their operations and businesses resulting in unequal playing field
for the companies into this business.
ii.
Inconsistency in approval and testing:- There is no
definite process or rules for obtaining the approval for new drugs. There is a
lot of disparity for granting approval to a new drug mostly depending upon who
has applied for the approval. Moreover even for the clinical testing there are
no prescribed rules and may vary in each case and depends on the contentment of
the licensing authority pertaining to its safety and efficiency. As a result
all this leads to unnecessary delay in launching of the new drugs causing a lot
of loss to the manufacturers as well as a threat to the public health.[8]
iii.
Difficulty in access to the
biological drugs: - In the past
ten years the drug manufacturers in India have made steady progress in the
manufacturing of generic drugs and registering the biological medicines by
increasing the competition and thus in turn to reduce the cost of expensive
treatments in the world. [9]
But access to these biological drugs is difficult due to the stringent
regulation process as a result of which the national regulators asks most of
the manufacturers to not only conduct the Phase-1 & Phase-2 Trials but also
to do a comparative trial before receiving the final approval. As a result of
conducting multiple trials for each biological medicine leads to exhausting a
lot of time and money as there a very few companies who would enter into a
competition with the large pharmaceutical companies thus in turn it leads to
monopoly and killing the competition.[10]
Suggestions/Recommendations
1. A framework should be designed under
the supervision of CDSCO that ensures coherence for basis adhered by the state
licensing authorities and a centralized mechanism for the training of
inspectors to ensure uniformity in the interpretation and implementation.
2. There should be a centralized data
base where all the data related to issuance and cancellation of licenses, list
of sub-standard drugs, prosecutions etc should be made and the same should be
linked to all the state authorities to maintain a better coordination between
the CDSCO and the State Drug Authorities.
3. The Drug Approval Process should be
more transparent and should be completed within a limited time period. In order
to do the same there should be definite set of rules determining the time
period within which the same should be completed. Other than that there should
be strict rules for each step involved in the approval of new drug inclusive of
the time required for clinical trials, deliberation by the experts etc.
4. There should be a common database
available in the public domain containing information related to the number of
new applications for new drug, number of
drugs for which clinical trials were required/waived, number of
approvals/rejections, time taken for approval/rejection etc. This will make the
process more clear and accountable.
5). Anti-Competitive Practices and the Role of CCI:-
In order to prevent monopolistic
trade practices and allow fair playing field for various companies and
manufacturers in the pharmaceutical sector Competition Commission of India will
have to carry on applying anti-trust laws in the pharmaceutical sector. Also
CCI through a variety of judgements has also helped to address the various
underlying reasons responsible for non-competitive market conditions. The major
areas which will be focused upon will include acts of the trade associations in
the pharmaceutical distribution chain to limit competition and also the
malpractices involved in the development of generic medicines.
i.
Malpractices by Trade Associations in distribution
of drugs:-
To establish a equal level playing
field and avoid anti-competitive trade practices it is important to ensure that
at each level of the supply chain whether it is manufacturing, wholesale or
retail is working smoothly and there are no monopolistic trade practices
involved. But however by looking at the existing high trade margins in India it
is clear that there is a monopoly involved in the distribution of drugs.
By looking at the previous judgments
passed by the commission such as the BCDA case, Arora Medical Hall Case or the
JDMDA case it is clear that the entire supply-chain management in the drug
distribution sector is regulated by the trade associations themselves.
The malpractices into which the trade
associations are involved are as follows: -
1. Collecting Product
Information Service (PIS) Charges from the manufacturers: -
It has been found in a variety of
cases that the trade associations in various districts are involved in
collecting money illegally from the manufacturers in the name of PIS charges.
The same has been noted by the commission and as a result heavy penalties were
imposed on such associations and the President and Secretary of such trade
associations are also made liable for the same.
In the instant case of Nadi Jauhri v. Jalgaon District
Medicine Dealers Association (JDMDA)[11]
the said trade association in the name of Product Information Service
Charges was collecting a hefty sum of money from the product manufacturers. The
said act of the association was reported by the informant to the commission
wherein it was found that on the pretext of publishing the details of the new
drug launched in the market the association used to charge a fee of INR 500/-
from each manufacturer. But when an enquiry was conducted by the Director
General in respect of the same it was found that the said charges though were
not compulsory to be paid but if any manufacturer refuses to pay the said
charges then the product launched by their company will be boycotted and no
retailer of that district will sell that products.
Here the JDMDA has violated S.3(3)(b)
r/w S.3(1) of the Competition Act 2002 as the said act by the
association has imposed a limitation on the free flow of supply of new products
by various pharmaceutical companies in the market. Moreover the said act of the
association has made it clear that the companies which will not pay the said
fee will have no chance to market their products in the district and on the
other hand the people who will pay the said charges will have a monopoly over
the market.
The opposite party had tried to
oppose the above said allegations leveled against them by the informant and the
investigation report of the DG by saying that the commission is not empowered
to take cognizance in the said matter as vide the order dated 2.12.2015 the
Delhi High Court by which the commission and the DG were directed not to take
any coercive steps and hence it was expected from the commission to wait for
further orders of the superior court before enabling any kind of proceedings.
Also the OP had denied the allegations leveled by the informant that the
payment of PIS charges are voluntary and not compulsory to which they had
relied on the statements of Mankind Pharma Limited, Koye Pharmaceutical Private
Limited, Unichem Laboratories Limited to prove that the payment of PIS charges
was not mandatory. Also the opposite party had refused to accept that they were
failing to advertise about the concerned products on time even after receiving
the PIS charges which was not correct though.
After hearing to the contentions of
both the parties and the witnesses the CCI had held that the collections of PIS
charges were neither for the purpose of advertisement nor for the compliance
with DPCO. Accordingly the CCI had imposed fine with interest for three
financial years. Further, penalties were imposed on both the President and
Secretary of the JDMDA. Hence, this case is a clear example of the CCI’s
concerns for the pharmaceutical sectors and against the unfair practices.
2. Paying of charges for
obtaining NOC is compulsory: -
Another kind of malpractices into
which the trade associations are involved into is the collection of the No
Objection Certificate Letter and Letter of Credit by paying the fees as
ascertained by the association. The said had declared that the said acts are
violative of the provisions of the Competition Act 2000 and held the same in
the following case.
In the instant case of M/s Arora Medical Hall, Ferozpur v.
Chemists and Druggists Association Ferozpur, (CDAF)[12] the association had violated
S.19(1)(a) of the Competition Act, 2002. The informant alleged that the
said association was imposing a sum of Rs.2100/- for obtaining a NOC
certificate and a letter of credit on all the chemists/druggists who wanted the
distributorship for medicines in Ferozpur. The informant/petitioner disagreed
to pay the said charges and as a result the association not only boycotted the
informant but also defamed them and passed a resolution in the general body
meeting to boycott the petitioner from the pharmaceutical business.
After the investigation of the DG it
was found that the above said allegations leveled against the association are
true and as a result the said act have violated the freedom of trade of the
plaintiff and was an attempt to limit and control the supply of drugs in the
market.
The association in its submissions
stated that all the allegations leveled against them by the informant is false
and malicious and it has not committed any of the said acts and alleged that
the general body meeting was called on receiving a lot of complaints from
various retailers against the informant and said that the investigation of DG
had missed out on the fact that the informant being the sole stockiest in the
city to some of the drug manufacturing companies was misusing its power and the
same was brought to the notice of the said companies by the association through
a letter. Moreover the association also contended that FIR’s were registered
against the informant by various retailers u/s 420 of IPC and u/s 66(1) of the IT
Act 2000 alleging that the informant had generated computerized bills to
some retailers without excluding the amount of the expired drugs.
After hearing both the parties the
CCI contended that the opposite party or the association CDAF is liable for
indulging into anti-competitive practices under Section 3 and 4 of the
Competition Act 2002 and were involved
in collecting fees from the distributors in the name of NOC Certificates and
Consent Letters, fixing trade margins at different levels, issuing instructions
to chemists/druggists/manufacturers to sell the drugs at a certain rate by
fixing the rate of discount they can give and the issuance of boycott notice
against the informants.
The CCI issued directions to
associations by listing out the anti-competitive practices and if at all these
activities are still carried out then they will be violating the provisions of
the Competition Act, 2000. The CCI found the defendants liable for the alleged
charges and imposed penalties on them regarding the same.
3.
Associations are involved in price fixing, limiting
supply and fixing the selling price of
the drugs: -
The various trade association
involved in supplying of drugs are involved into acts such as fixing, limiting
supply and fixing the selling price of the drugs to earn more profits and setup
a monopoly in the pharmaceutical sector.
In the case of Re: Bengal Chemists and Druggist Association and Others [13]the
CCI had received information via e-mail that BCDA was involved in the acts like
price fixing, limiting supply and fixing the selling price of the drugs. CCI
took suo-motto cognizance and an investigation was by the Director General (DG)
was ordered in the said matter.
After the investigation was concluded
by the DG it was found that the BCDA had instructed the retailers to not to
offer any discount and have also have also directed them to sell the drugs at
the MRP determined by them thus this act of the association had caused an
adverse effect on the competition and will lead to limiting the supply of the
medicine and will be in violation of Section-3 of the Competition Act 2000.
Therefore BCDA submitted that BCDA is
a non-profit association as per the Companies Act and therefore cannot be
treated as an enterprise. It further added that the association had voluntarily
complied with S.27 of the Competition Act 2000 hence it is not liable to pay
the penalty. Lastly BCDA had concluded that their office bearers cannot be held
liable as their liability is limited to the MOA as the same is a non-profit
entity.
CCI observed that firstly the BCDA
will be covered under the category of ‘entities’ and the decisions taken by the
association of behalf of its member will fall under the ambit of section 3 of
the Act. In the said case CCI penalized BCDA for practicing anti-competitive
practices and also held 78 of the senior office bearers personally liable for
endorsing anti-competitive conduct and further went on imposing a penalty of
Rs. 18.38 Crores (fine imposed on BCDA was only Rs. 13.24 Lakh).
4. Manufacturing Companies
involved in restrictive trade practices: -
Apart from associations it has been
seen that the manufacturing companies by colluding with other organizations are
involved in anti-competitive practices thus creating trouble for the retailers
and in such a case associations comes as a survivor for such retailers.
In the instant case of Re: Belgaum District Chemists and
Druggists Association (BCDA) v. Abbott India Ltd. & Ors. [14]filed
a complaint before the Director General of Investigation and Registration
(DGIR) against Abbott India Ltd. and Geno Pharmaceuticals as the said companies
had stooped stopped the supply of the essential medicines to some of its
members on the ground that they did not fulfill the pre-requisite of obtaining
the “No Objection Certificate” from All India Organisation of Chemists
and Druggists (OP-4) and Karnataka Chemists and Druggists Association (OP-2).
The DGIR transferred the complaint to the Commission under Section 66(6) of the
Competition Act, 2002 with an observation that the alleged practice opted by
the Original Petitioner-1 and OP-3 appeared to be a restrictive trade practice
of refusal to deal. The Commission further passed an order on 29th June,
2010 under Section 26(1) and directed the Director General to organize/conduct
an investigation/examination in the present matter.
The Director General in his
investigation observed that Original Petitioner-2 and Original Petitioner-4
have indulged into anti-competitive practices by contravening the provisions
under Section 3 (3) (a) & Section 3 (3) (b) of the Act.
The Competition Commission has stated
that in the absence of any evidence to show that Original Petitioner-4 cannot
be found guilty of contravention of the said provision. The Competition
Commission has held that the Original Petitioner-2 has acted in contravention
to the provisions of the Act. The Commission directed Original Petitioner-2 to
cease the requisite of the mandating NOC and have also advised not to indulge
in such practice in future. The Commission has held that the appointment of the
stockiest and the fixing of trade margins for retailers and wholesalers are
considered to be anti-competitive under the provisions of Section 3 (1) read
with Section 3 (3) of the Act. The Commission has stated that as a penalty of
Rs. 860321 has been imposed upon OP-2 in similar matter of mandating the NOC
for the appointment of stockiest, therefore the Commission refrained from
imposing any monetary penalty.
Conclusion
The Indian pharmaceutical industry is
one of the major pharmaceutical industries in the world, both in terms of
volume of consumption and value of production. Further, given its critical
importance, this industry has attracted significant policy attention. Given the
ever changing policy environment, it is only appropriate to assume that the
firms also adapt their strategies as per the policy environment, thereby
altering the industry dynamics itself. In
short, the competition law of India has a crucial role to play in the
pharmaceutical sector. In India the consumers suffer direct and immediate
harms, as they frequently are not able to afford the drugs prescribed to them.[15]
Anti-competitive behavior often is not justified based on innovation or patents
and the complexity of the conduct does not diminish and in fact necessitates
careful competition law scrutiny of the pharmaceutical industry. The CCI had
played a vital role in maintaining anti-competitive environment and has
established a equal playing arena for all the manufacturers in the
pharmaceutical industry/sector. Also the CCI had played a vital role in keeping
the various trade associations under a strict check and thus ensuring that the
freedom of trade prevails and delimiting the control on manufacturing and
supply of drugs by the various companies. In the end, we can conclude that the
CCI has ensured that the customers are protected against duplicate products and
have made efforts to ensure that the prices of essential drugs remain
reasonable.
[1] Johanna
Gibson, Intellectual Property, Medicine and Health: Current Debates, 7 (1st
ed. Routledge 2009).
[2]
India has recognized Right to health as a part of right to Life in N D Jayal v. Union of India 2004 (9) SCC 362.
[3]
Centre for Trade and Development (Centad), Competition Law and Indian
Pharmaceutical Industry.
[4] The provisions of the Competition Act have
been notified by the Government in a phased manner and the whole Act is
expected to come into force in the near future. Services were also included
under the new regime.
[5] K.D.
Raju, The Intellectual Property Rights
& Competition Law: A Comparative Analysis, 27 (Eastern Law
House, 2015).
[6] AIR 2005 Gau 5
[7] Annual Report on Competition Policy Developments in India, Organisation
for Economic Co-operation and Development,
DAF/COMP/AR(2019)45.
[8] Prajapati Vishal et al, A Review
on Drug Approval Process for US, Europe and India, International Journal of
Drug Regulatory Affairs, 2014
[9] Leena Menghaney, Competition is
the key to making drugs affordable, Hindu Business Line, May 12, 2017
[10] Ibid
[11]
2019 SCC OnLine CCI 12
[12] 2014 SCC OnLine CCI 18 : [2014]
CCI 38
[13] 2014 SCC OnLine CCI 38
[14] 2017 SCC OnLine CCI 20
[15] C. S. Hemphill and B. N. Sampat, “When
Do Generics Challenge Drug Patents?” Journal of Empirical Legal Studies, 8
(4): (2011) 613 – 649.
Article Information
PHARMACEUTICAL SECTOR AND COMPETITION COMMISSION OF INDIA: AN ANALYSIS OF JUDICIAL PRONOUNCEMENTS OF COMPETITION COMMISSION OF INDIA
Authors: MS. PRIYANKA CHOUDHARY
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/01/01
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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