In India, since 30 November 2023 every e-commerce app, OTT platform, food-delivery app, travel booking site and online seller is bound by a regulator-issued rulebook against 13 named deceptive design patterns called “dark patterns”. You are no longer asking the company nicely. You are enforcing law.
🟢 Quick answer for citizens. If an app fakes urgency, sneaks items into your basket, shames you for declining, traps a subscription, hides the real price or auto-renews silently, file a complaint at NCH 1915 (call or https://consumerhelpline.gov.in), file online at https://edaakhil.nic.in for a money claim, and write to the Central Consumer Protection Authority at https://consumeraffairs.gov.in. Screenshot the screen, the URL and the timestamp before you tap anything. Compensation can include refund plus mental agony plus costs under §39 of the Consumer Protection Act 2019.
If you are short on time, jump to the five-route complaint section below. Everything else in this article supports that one decision: where to send your screenshots.
The Central Consumer Protection Authority (CCPA), the statutory regulator under the Consumer Protection Act 2019, issued the Guidelines for Prevention and Regulation of Dark Patterns, 2023 in exercise of its powers under §18 of the Consumer Protection Act 2019. The notification was published in the Official Gazette of India on 30 November 2023 under F. No. J-24/34/2023-CPU (Reg), Department of Consumer Affairs, Ministry of Consumer Affairs, Food and Public Distribution. The official text is hosted at https://doca.gov.in/ccpa/files/The%20Guidelines%20for%20Prevention%20and%20Regulation%20of%20Dark%20Patterns,%202023_1732707717.pdf.
The guidelines define a “dark pattern” as any practice or deceptive design pattern using user interface (UI) or user experience (UX) interactions on any platform, that is designed to mislead or trick users into doing something they originally did not want to do. The guidelines say such conduct amounts to a misleading advertisement, an unfair trade practice, or a violation of consumer rights.
The guidelines apply to all online platforms that systematically offer goods or services in India, all advertisers, and all sellers. Foreign-incorporated platforms that serve Indian consumers are also covered, removing the old “we are a US LLC” defence.
Annexure I of the guidelines lists 13 named dark patterns in plain illustrative language. The list is not exhaustive. CCPA can add more by future notification.
Three reasons.
Trust signal. In Indian Medical Association v. V.P. Shantha (1995) 6 SCC 651 the Supreme Court held that any service for consideration is a “service” under consumer law. The principle has been applied to digital intermediaries by the National Consumer Disputes Redressal Commission (NCDRC) repeatedly since 2019.
Each pattern below has the official name, the plain-English definition, a typical Indian-app illustration, and a one-line “what to capture” cue.
Creating an artificial sense of scarcity or time pressure to push you into a quick decision. Common examples: “Only 2 seats left at this price”, “Offer ends in 03:42 minutes” on a counter that resets when you refresh, “5 people are viewing this hotel” on travel apps.
What to capture: screenshot the page, then refresh and screenshot again. If the counter restarts or the seat count is identical, you have evidence.
Adding items, donations, insurance, priority delivery or “tip” amounts to your cart without your explicit consent. Common examples: cab apps adding a tip slab on the payment screen, ticket platforms auto-adding a small charity contribution per ticket, e-commerce apps auto-adding “buyer protection” or “VIP membership” trials.
What to capture: screenshot the cart subtotal, then screenshot the final payment screen. The delta is your case.
Using guilt-inducing language to discourage you from declining. Common examples: “No, I don't want to save money”, “No thanks, I prefer paying full price”, a sad emoji next to the decline button.
What to capture: screenshot the pop-up showing the two button labels side by side.
Forcing you to take an action you did not intend, in order to use the basic feature you came for. Common examples: requiring app installation to read an article, demanding marketing-email consent before checkout, locking content behind a social-media follow.
What to capture: screenshot the modal blocking your path. Note the timestamp.
Making subscription sign-up easy but cancellation hard or hidden. Common examples: OTT platforms that need you to call a number to cancel, e-commerce membership programmes where the cancel button is buried under five menus, free trial that auto-converts without a clear notice.
What to capture: search the app's settings for “cancel”. Screenshot every dead end. Email a written cancellation request to the platform's grievance officer the same day.
Designing a screen so the option the platform wants you to pick is visually obvious, and the option you want is dim, small or hidden. Common examples: pre-checked add-on boxes, “Recommended” payment method that is more profitable for the platform, a giant “Continue with offer” button beside a tiny “Skip” link in grey.
What to capture: screenshot the full screen. Highlight both buttons with annotation later.
Advertising one offer, product, or price and delivering another after you have committed. Common examples: a hotel listed at ₹1,499 that on checkout shows ₹2,899 with “taxes and fees”, a phone advertised in stock that is “currently unavailable” only after you log in to buy.
What to capture: screenshot the listing page and the product page and the checkout page. Timestamps must match the same session.
Hiding parts of the price till the last screen, so the final amount is much higher than the advertised amount. Common examples: airline tickets where convenience fee, seat fee, baggage fee, meal fee appear only at payment, food-delivery apps where packaging, surge, platform fee and small-order fee are added on the last step.
What to capture: screenshot every page where the price changes. Save the URL.
Showing paid content styled as organic content or editorial reviews. Common examples: “sponsored” listings on travel and review apps that are not clearly labelled, video ads that look like product demos, “you might also like” widgets that are paid placements.
What to capture: screenshot the listing with the “sponsored” or “ad” label, or its absence.
Repeated unwanted prompts, notifications or pop-ups to make you give in. Common examples: an OTT app that asks every session “Upgrade to premium?”, a notification permission prompt that returns despite “Don't allow”, a “Rate the app” pop-up after every order.
What to capture: screenshot the third or fourth occurrence with timestamps. A pattern of repeated nagging matters more than a single instance.
Phrasing buttons or copy in a way that misleads you about what happens next. Common examples: “Save” and “Cancel” reversed in colour, “Continue without protection” presented as the risky choice, double negatives in checkboxes (“I do not wish to not receive offers”).
What to capture: screenshot the screen, transcribe the exact words next to it.
Auto-converting a free trial into paid subscription without a clear consent prompt, silent recurring deductions, auto-renewals without a one-week prior notice, or charging for features you do not use. The guideline expressly covers exploiting recurring billing on cards or UPI mandates without renewed consent.
What to capture: download the bank or UPI mandate page screenshot, the original sign-up screen, and any monthly debit SMS.
Deceptive download buttons, fake “Your device is infected” pop-ups, or buttons that resemble system warnings to trick you into downloading paid software or scam apps. This is the most aggressive pattern and overlaps with the Information Technology Act 2000 §43 and §66 (computer fraud).
What to capture: screenshot the pop-up. Do not click it. Note the host URL. Report it to https://www.cybercrime.gov.in in parallel.
🟡 Citizen tip. The 13 patterns above can occur in combination. A single OTT signup can show false urgency (“Limited offer: ₹49 today only”), confirm shaming (“No, I do not value my time”), drip pricing (taxes added at payment), interface interference (auto-checked add-on), and SaaS billing (silent renewal next month). Each one is separately complainable.
The narrative below is a composite based on patterns commonly described in NCH 1915 dockets and consumer-forum filings. It is presented as an illustrative example, not as a finding against any company.
Mrs N, a Pune resident, opens a popular travel app on a Friday evening to book a Mumbai–Bengaluru flight for the following Monday. The home screen shows the route at ₹3,499 with a banner “Only 4 seats at this fare!”. She taps. The detail page now reads ₹3,899, with “1 seat left at this fare!” and a 4-minute countdown timer. She proceeds. A seat-selection screen prompts ₹350 for a window seat, with “Recommended” highlighted in green. A meal screen offers a ₹250 vegetarian meal, with a pre-ticked “Skip meal” box she does not notice. The checkout screen shows convenience fee ₹199, port-charges ₹130, and a “Trip Assurance” insurance ₹89 already added. The decline button is a small grey link saying “I'd rather travel unprotected, no thanks”. The total is now ₹4,617.
Mrs N reads the breakup, untickes the insurance, removes the meal, and skips the seat. The total drops to ₹4,028. She refreshes the page out of habit. The same “1 seat left” message displays with a fresh 4-minute timer.
In this single 12-minute session, Mrs N has experienced at least six dark patterns: false urgency (fake scarcity counter and timer), drip pricing (convenience fee and port charges shown only at the end), basket sneaking (auto-added insurance and meal), interface interference (pre-ticked add-ons and “recommended” highlight), confirm shaming (“I'd rather travel unprotected”), and trick wording (the “skip meal” checkbox actually keeping the meal).
Mrs N pays ₹4,028, takes screenshots of every step, and the next morning files a single combined complaint at NCH 1915 plus a written email to the platform's grievance officer plus an e-Daakhil money complaint claiming refund of the inflated convenience fee, the booking-stage misrepresentation, ₹10,000 mental agony, and ₹2,500 costs. Total claim ₹13,727.
Two weeks later the platform refunds the convenience fee and credits ₹2,000 as goodwill. The DCDRC complaint proceeds for the residual claim.
🟢 Most citizens miss this. A goodwill credit in the app is not a settlement of legal liability. It is a customer-service gesture. Accept it in writing with reservation of rights (“I accept ₹X without prejudice to my claim under the Consumer Protection Act 2019”). Otherwise the platform will plead settlement in the consumer forum.
The single biggest reason dark-pattern complaints fail is the absence of clean, timestamped evidence. Build the kit before you tap “Pay”.
Create a folder named ``[Platform]-[Date]-[OrderID]``. Inside, save:
When you file at e-Daakhil, upload this folder zipped. The bench reads in this order.
===== How to complain — the five-route stack ===== {#how-to-complain-step-by-step}
Indian law gives you five overlapping channels for a dark-pattern complaint. Use them in parallel, not sequentially. Each one targets a different objective.
Under IT Rules 2021 Rule 3(2) every intermediary publishes the name, email and address of a grievance officer who must acknowledge in 24 hours and resolve in 15 days. Write a single dated email setting out the dark pattern, the screenshots, the order ID, the claim, and a 7-day deadline.
Call 1915 or file online at https://consumerhelpline.gov.in. NCH is run by the Department of Consumer Affairs. It does not decide cases but mediates with the platform and forwards repeat-offender cases to CCPA.
File at https://edaakhil.nic.in. This is the formal District Consumer Disputes Redressal Commission (DCDRC) route. Claims up to ₹50 lakh are District, ₹50 lakh–₹2 crore are State, above ₹2 crore are NCDRC.
For systemic patterns affecting many consumers, write to the Central Consumer Protection Authority at https://consumeraffairs.gov.in with subject “Complaint under §18 CPA 2019 — Dark Patterns Guidelines 2023”. CCPA is the only authority that can issue platform-wide directions under §21 and impose penalties up to ₹10 lakh first offence and ₹50 lakh repeat offence for misleading advertisements.
If the dark pattern caused a credit-card or UPI mandate debit you did not intend, raise a chargeback with your bank within 120 days under Visa/Mastercard reason codes (13.3 “Not as described” or 13.5 “Misrepresentation”). For UPI mandate debits, raise a complaint at NPCI via the UPI app's dispute section within 30 days. Banking dark patterns can be escalated to the RBI Ombudsman under the Integrated Ombudsman Scheme 2021.
🟢 Do this immediately. After capturing the screenshots, fire off three emails in 30 minutes. (a) Platform grievance officer. (b) The CCPA at https://consumeraffairs.gov.in. © Your bank or card issuer if a debit occurred. Then file NCH 1915 online. Then within 15 days, if unresolved, file e-Daakhil. This stack puts five different timers on the platform's lawyers simultaneously.
To: grievance.officer@[platform].com Cc: [email protected]; [email protected] Subject: Complaint under §18 Consumer Protection Act 2019 — Dark Patterns Guidelines 2023 — Order ID [XXXX] dated [DD-MM-2026] Sir / Madam, I am a consumer of your platform. On [DD-MM-2026] at [HH:MM IST] I used your application/website (version [X.Y]) on a [device, OS] to [task]. During this transaction I experienced the following dark patterns as listed in Annexure I of the CCPA Guidelines for Prevention and Regulation of Dark Patterns, 2023 (notified 30 November 2023 under §18 CPA 2019): 1. False urgency: [describe screen and counter] 2. Drip pricing: advertised ₹[X], final price ₹[Y] 3. Basket sneaking: auto-added [item] of ₹[Z] 4. [Others] Screenshots attached: 01 to 08. Under §2(47) CPA 2019 these are unfair trade practices. Under §39 of the Act I claim: (a) Refund of ₹[A] (the differential between advertised and final price plus auto-added items). (b) Compensation for mental agony ₹[B]. (c) Costs ₹[C]. Please acknowledge within 24 hours under IT Rules 2021 Rule 3(2) and resolve within 15 days, failing which I shall approach NCH 1915, the Central Consumer Protection Authority under §21 CPA 2019, and the District Consumer Disputes Redressal Commission via e-Daakhil (https://edaakhil.nic.in). This email is also a record under §63 of the Bharatiya Sakshya Adhiniyam 2023. Yours faithfully, [Name, address, phone, email, date, registered account ID]
Citizens often want to know how many other complaints exist against a platform, what CCPA has done about it, and which guidelines amendments are pending. The Right to Information Act 2005 is the tool.
To, The Central Public Information Officer Department of Consumer Affairs Krishi Bhawan, New Delhi 110001 Subject: Application under §6(1) of the Right to Information Act 2005 Sir, Under §6(1) of the RTI Act 2005, I seek the following information for the period 01 January 2024 to date: 1. Number of complaints received by NCH 1915 alleging violation of the Guidelines for Prevention and Regulation of Dark Patterns, 2023 against [platform name], pattern-wise. 2. Number of show-cause notices issued by CCPA under §21 CPA 2019 in respect of dark patterns, with copy of each notice (subject to §8(1)(j) redactions). 3. Penalties imposed under §21(2) CPA 2019 in respect of dark patterns. 4. Status of any proposed amendment to Annexure I of the 2023 Guidelines. 5. Action taken on the CCPA Advisory dated 5 June 2025 directing e-commerce platforms to self-audit within three months. RTI fee of ₹10 enclosed by IPO No. [XXXX] / UPI reference [XXXX]. Reply within 30 days under §7(1) RTI Act 2005. If part of the information is held by another public authority, transfer it under §6(3) within 5 days. Yours faithfully, [Name, Address, Phone, Email, Date]
Use the free AI RTI Drafter to auto-prefill the boilerplate and check fee category. Then run it through the PIO Reply Checker when the reply arrives.
Under §2(5)(v) of the Consumer Protection Act 2019, a complaint may be filed by “one or more consumers, where there are numerous consumers having the same interest, with the permission of the District Commission, on behalf of, or for the benefit of, all consumers so interested”. This is the Indian class-action mechanism.
For dark patterns this matters because the same UI screen affects every user of the platform. If 50 citizens file a joint petition through one consumer activist, with the District Commission's permission, the relief can extend to all similarly affected consumers, not only the 50 signatories. The CCPA itself can take suo motu class action under §21.
Process in brief:
Trust signal. In Ambrish Kumar Shukla v. Ferrous Infrastructure (NCDRC, 2017) the National Commission laid down the procedure for representative consumer complaints under the (then) CPA 1986. The same framework continues under the 2019 Act. CCPA has used the same logic in its 2024 advisory to e-commerce platforms.
Under §39 of the Consumer Protection Act 2019 the District Commission can pass any of the following orders against a platform found to have used a dark pattern. You should claim all heads in your complaint; the bench will award what it considers proportionate.
In a dark-pattern case the mental-agony head is often the largest practical claim, because the actual money loss may be small (₹89 insurance, ₹250 meal) but the cumulative annoyance and trust harm is real and recognised by NCDRC orders.
CCPA action since the 2023 Guidelines includes (verifiable to public press releases and law-firm advisories):
The advisory is not by itself a binding rule, but non-compliance is treated as an aggravating factor in any subsequent enforcement order under §21 CPA 2019. Penalty ceilings are ₹10 lakh first offence and ₹50 lakh repeat offence, plus potential criminal liability for officials in egregious cases under §89.
🟡 Important caveat. Some commentators have noted that the 2023 Guidelines themselves describe the Annexure I patterns and illustrations as “for guidance” and not “a binding opinion”. The binding legal hook is §2(47) CPA 2019 (unfair trade practice) read with §18 (CCPA's powers). The Guidelines amplify what counts as unfair, but the enforcement rests on the parent Act.
The Guidelines are issued under §18 CPA 2019, a statutory power. They are binding on platforms in the sense that violations are treated as unfair trade practices under §2(47), which is itself a statutory ground for action and penalty under §21. Some commentators argue the illustrative examples in Annexure I are “guidance” only. The safer reading is that the patterns identify what counts as unfair trade practice; enforcement is under the parent Act.
No. Industry practice is not a defence under CPA 2019. The Supreme Court in LIC v. Consumer Education and Research Centre (1995) 5 SCC 482 held that unfair contractual terms in standard-form consumer contracts are actionable regardless of how common they are. If every airline drips its prices, every airline can be made to stop, not the other way around.
The Guidelines apply to consumers in India. If the transaction was made while you were in India, on an Indian platform, you can complain to NCH 1915 and the consumer forum. For a foreign-incorporated platform serving India, jurisdiction lies wherever the consumer resides or the transaction took place (§34(2)(d) CPA 2019).
Yes, and you can also claim the differential and mental agony. The pattern is drip pricing. Cancel within the platform's grace window, screenshot the listing page and the final-price page, and file a complaint with the platform grievance officer plus e-Daakhil. Many travel platforms refund silently to avoid a CCPA enquiry.
The pattern is SaaS billing under Annexure I item 12. (a) Cancel the subscription immediately. (b) Email the grievance officer demanding refund of the auto-converted amount and citing the dark patterns guidelines. © If denied, raise a credit-card or UPI mandate chargeback within 120 days. (d) File at e-Daakhil for ₹100 if the amount and mental agony together justify it.
Yes. The pattern is basket sneaking. Even ₹2 is unauthorised debit and an unfair trade practice. NCH 1915 takes such complaints in bulk and CCPA has acted on similar add-ons in 2024. Your screenshot adds to the body of evidence. The platform's cost of fighting 10,000 such complaints exceeds the cost of fixing the UI.
Yes, under §39(1)(g) of CPA 2019 the District Commission can order discontinuance of the unfair trade practice and direct it not to be repeated. For platform-wide design relief, CCPA under §21 is the more effective forum because its orders bind the platform as a whole, not only your transaction.
No. Such jurisdictional ouster clauses against the consumer in standard-form contracts are routinely struck down as unfair. The Supreme Court in Modi Entertainment Network v. WSG Cricket (2003) 4 SCC 341 and the NCDRC in many subsequent orders have held the consumer's home forum cannot be excluded by a click-wrap term.
For dark-pattern complaints in 2026 the District Commission typically issues notice within 6 weeks of admission, holds 2–4 hearings (hybrid), and decides within 6 to 9 months. Many platforms settle by the second hearing. Appeal to the State Commission takes another 6 to 12 months. Most dark-pattern citizens get their relief at first-instance or pre-hearing settlement.
Only if there is criminal intent to cheat — for example, rogue malware patterns or fake “your device is infected” pop-ups that lead to financial loss. For those, file an FIR under §318 of the Bharatiya Nyaya Sanhita 2023 (cheating), report at https://www.cybercrime.gov.in, and pursue the consumer remedy in parallel. Pure UI tricks without intent to defraud usually stay on the civil consumer-law track.
The 2023 Dark Patterns Guidelines are the most concrete tool an Indian consumer has had against deceptive app design. The patterns have not gone away, but the legal weight of every screenshot is now much higher than in 2022. Tap less, screenshot more, send three emails in 30 minutes, and use the five-route complaint stack. The next time a “1 seat left” timer flashes, you are looking at evidence, not pressure.
If you are stuck mid-case, post your scenario on the Citizen Crisis Response Network. A fellow citizen will walk you through the exact escalation. The 2023 Guidelines are the floor, not the ceiling. Push.