CCI Cement Cartel Litigation in India — 8 Listed Entities, 3 Streams, FY 2024-25 Status

CCI cement cartel litigation in India — at a glance (FY 2024-25 status)

8 of 14 audited Indian listed cement majors carry CCI cartel exposure documented in the BRSR Cement Sector Benchmark FY 2024-25. Quantified exposure across the 5 entities with explicit penalty amounts in their financial statements totals approximately ₹2,088 crore. The matters run through three structurally distinct CCI litigation streams. Only 3 of the 8 exposed entities disclose the matter under BRSR Principle 7 Q2 (anti-competitive corrective action); 5 report ‘NA’ on P7 Q2 despite carrying the exposure in their financial statements.

Entity	Penalty / exposure	Source FY 2024-25	Forum status
UltraTech Cement	₹1,685.13 crore	Standalone FS Note 34(b); Auditor EoM page 295	Supreme Court (stayed 5 October 2018; ₹161.68 cr 10% deposit on balance sheet)
Ramco Cements	₹258.63 crore	BRSR P7 Q2 + Principle 1 Q2 fines table	Supreme Court (Ramco appeal admitted; NCLAT dismissed 25 July 2018; ₹25.86 cr 10% deposit)
JK Cement	₹137.82 crore (₹128.54 + ₹9.28)	Director’s Report §14	Supreme Court (₹128.54 cr matter); NCLAT stay continues
JK Lakshmi Cement	₹6.55 crore	BRSR P1 Q2 + P1 Q3 + P7 Q2 + SASB EM-CM-520a.1	NCLAT (post-COMPAT-merger; Transfer Appeal No. 39 of 2017)
Star Cement	₹5 lakhs	BRSR P7 Q2	QUASHED by Guwahati HC 30 August 2024; CCI Division Bench appeals pending
ACC	Not quantified in BRSR	Auditor Emphasis of Matter Note 43(A) page 337	Same vintage as UltraTech; Supreme-Court-stayed
Nuvoco Vistas	Not quantified in BRSR	Auditor KAM #1 Note 48(c)	COMPAT lineage; Supreme-Court-stayed cohort
India Cements	Not quantified in BRSR	Not disclosed under P7 Q2 or P1 Q2; historical 2017 cohort exposure	Inherits UltraTech-parent disclosure posture post-Dec 2024 acquisition

The remaining 3 of 14 audited entities — Birla Corporation, Orient Cement and Sagar Cements — carry no CCI cement-cartel exposure documented in either their BRSR Principle 7 Q2 disclosure or their financial-statement notes. Birla Corp and Orient additionally have clean P7 Q2 records; Sagar Cement’s SASB EM-CM-520a.1 (Pricing Integrity & Transparency) reports zero monetary losses from cartel/price-fixing/antitrust proceedings — corroborating the BRSR-disclosed clean record.

The three CCI cement-cartel litigation streams

Stream 1 — 2012 Builders’ Association of India v. Cement Manufacturers’ Association

CCI order dated 20 June 2012 in the Builders’ Association of India (BAI) v. Cement Manufacturers’ Association (CMA) reference. The CCI found violations of Section 3(1) read with Section 3(3)(a) and 3(3)(b) of the Competition Act 2002 (anti-competitive agreements and bid-rigging). The Competition Appellate Tribunal (COMPAT) remanded the matter on procedural grounds; the CCI re-adjudicated and on 31 August 2016 reiterated the original penalty quantums on remand.

Ramco Cements is the lead identified entity in this stream from the BRSR Cement Sector Benchmark v1.0 audit: CCI re-imposed the ₹258.63 crore penalty on 31 August 2016. Ramco made the 10% deposit of ₹25.86 crore on 30 November 2016 (classified under “Bank Balances other than Cash and Cash Equivalents” in Ramco’s standalone financial statements). NCLAT dismissed Ramco’s appeal on 25 July 2018; the Supreme Court admitted Ramco’s appeal with the interim-order continuation. As at FY 2024-25 BRSR reporting date, the matter is pending before the Supreme Court.

Ramco discloses this matter in four BRSR / SASB venues — Principle 1 Q2 fines, Principle 1 Q3 appeal details, Principle 7 Q2 anti-competitive corrective action, and the SASB EM-CM-520a.1 Pricing Integrity & Transparency line. This is among the most-transparent BRSR CCI disclosures in the audited sample.

Stream 2 — 2016 cement-cartel orders (Century / Binani consolidation cohort)

CCI orders dated 31 August 2016 captured the major cement producers under a related but distinct factual matrix. UltraTech’s standalone financial statements Note 34(b) discloses ₹1,616.83 crore under the 31 August 2016 order — this incorporates exposures absorbed via the acquisitions of Century Cement (effective FY 2018-19) and Binani Cement (effective FY 2019-20) where the predecessor entities carried CCI cartel allegations from this vintage.

UltraTech filed appeals before NCLAT (disallowed) and subsequently before the Supreme Court of India, which granted a stay on 5 October 2018. UltraTech has deposited ₹161.68 crore (10% of the larger penalty under the cumulative ₹1,685.13 cr exposure — see Stream 3 below for the second order) as an asset on its balance sheet pursuant to the SC order. The matter remains pending before the Supreme Court as at FY 2024-25.

ACC carries CCI cartel litigation from the same 2016 vintage as a contingent liability (Independent Auditor’s Report Emphasis of Matter Note 43(A) page 337 of the FY 2024-25 Integrated AR). The Adani-group acquisition of Holcim’s stakes in Ambuja + ACC in 2022 carried this contingent liability forward; the Supreme-Court-stay status applies to ACC’s matter on the same docket.

Nuvoco Vistas is the fourth entity confirmed in this cohort per the BRSR cement audit — Independent Auditor’s Report (M S K A & Associates) Key Audit Matter #1 references COMPAT matters under Note 48(c) of standalone financial statements; same Supreme-Court-stay docket.

Stream 3 — 19 January 2017 Government-of-Haryana reference

A separate CCI proceeding initiated on a reference from the Government of Haryana resulted in orders dated 19 January 2017, with aggregate cement-sector penalties of approximately ₹205.73 crore (per JK Lakshmi’s BRSR disclosure of the aggregate). The Haryana reference covered a distinct factual matrix from the 2016 orders and ran on its own procedural track.

Entities captured in this stream from the BRSR cement audit:

• UltraTech — ₹68.30 crore (component of the cumulative ₹1,685.13 cr standalone-FS contingent liability)
• JK Cement — ₹9.28 crore (Director’s Report §14 page 180 of the FY 2024-25 Integrated AR)
• JK Lakshmi Cement — ₹6.55 crore (BRSR P1 Q2 fines table)

JK Lakshmi was the first of the seven cement companies in the Haryana reference to file the COMPAT appeal — Transfer Appeal No. 39 of 2017. Post the COMPAT-NCLAT merger (Companies Act 2016 amendment dissolving COMPAT into NCLAT), the matter sits before NCLAT.

Stream 4 (procedural-side) — Star Cement Guwahati HC challenge

A fourth procedural-side stream is documented for Star Cement in the BRSR cement audit and warrants separate treatment because the legal outcome is unique. The DG-CCI issued a notice on alleged cement cartelization seeking information; Star filed an application for CCI recall/review of the order registering the case and investigation. When the information was not received within reasonable time, CCI imposed a ₹5 lakhs penalty (orders dated 06.12.2016 and 08.08.2018). Star filed Writ Petitions before the Guwahati High Court challenging both the penalty and the underlying registration + investigation orders.

By common judgment dated 30 August 2024, the Guwahati High Court allowed Star’s Writ Petitions and quashed the CCI’s ₹5 lakhs penalty plus the underlying orders dated 06.12.2016 and 08.08.2018. CCI has filed Writ Appeals before the Division Bench of the Guwahati HC; the appeals are pending hearing.

This is the only successful High Court challenge to a CCI cement-cartel matter documented in the BRSR Cement Sector Benchmark FY 2024-25 audited sample. The ₹5 lakhs penalty is also the smallest CCI exposure in the audited sample. Methodologically the Star matter is distinct from the substantive cartel-allegation litigation in Streams 1-3 — it concerns the procedural information-gathering phase rather than a CCI finding of cartelization on the merits.

BRSR Principle 7 Q2 disclosure transparency — sector-wide gap

BRSR Principle 7 Q2 asks for details of corrective action taken or underway on issues related to anti-competitive conduct by the entity, based on adverse orders from regulatory authorities. The benchmark documents the transparency pattern across the 8 cartel-exposed entities:

Entity	Discloses CCI matter under BRSR P7 Q2?	Where disclosed in FY 2024-25 AR
UltraTech Cement	❌ Reports ‘NA’ under P7 Q2	Standalone FS Note 34(b) + Auditor EoM page 295
ACC	❌ Reports ‘NA’ under P7 Q2	Auditor Emphasis of Matter Note 43(A) page 337
JK Cement	❌ Reports ‘NA’ under P7 Q2	Director’s Report §14 page 180 (quantified ₹137.82 cr)
Nuvoco Vistas	❌ Reports ‘NA’ under P7 Q2	Auditor KAM #1 Note 48(c)
India Cements	❌ Reports ‘NA’ under P7 Q2 + P1 Q2	Not separately disclosed
JK Lakshmi Cement	✅ Disclosed	BRSR P1 Q2 + P1 Q3 + P7 Q2 + SASB EM-CM-520a.1
Ramco Cements	✅ Disclosed	BRSR P1 Q2 + P1 Q3 + P7 Q2
Star Cement	✅ Disclosed	BRSR P7 Q2 (with chronology + HC quash outcome)

Five of eight exposed entities (62.5%) report ‘NA’ under BRSR P7 Q2 despite carrying the matter as a financial-statement contingent liability or Auditor Emphasis of Matter / Key Audit Matter. This is a sector-wide BRSR disclosure-quality gap — the BRSR alone is inadequate for an investor, ESG rater, journalist or assurance reader screening cement-sector cartel-litigation exposure. Cross-referencing the Auditor’s Report (Emphasis of Matter + Key Audit Matters), the Director’s Report and the standalone financial statements’ contingent liability schedule is required.

The 3-of-8 disclosure transparency rate may improve in the FY 2025-26 reporting cycle as SEBI’s Industry Standards Forum guidance + ICAI’s BRSR-Core reasonable assurance practice notes mature, but as at FY 2024-25 the gap is structural.

What this means for benchmark users

For ESG raters and BRSR analysts: the BRSR Principle 7 Q2 dataset alone undercounts cement-sector cartel exposure by approximately 62.5% (5 of 8 exposed entities missing). For directional integrity of an Indian cement-sector governance score, add a cross-reference layer on Auditor’s Report Emphasis of Matter + Key Audit Matters + Director’s Report contingent-liability schedule.

For journalists: the Star Cement Guwahati HC quash (30 August 2024) is the most newsworthy single CCI cement-cartel datapoint of FY 2024-25 — only successful HC challenge in the sector, distinct procedural-side litigation, smallest exposure in the audited sample. The cumulative ₹2,088 crore quantified exposure across the 5 explicitly-quantified entities is also a meaningful sector-aggregate number.

For FY 2025-26 BRSR Core assurance practitioners: the Principle 7 Q2 disclosure transparency gap is likely an FY 2025-26 audit observation candidate. ICAI’s reasonable-assurance practice notes flag BRSR Principle 7 disclosures as a higher-judgement area; the gap documented here is one of the more concrete examples of P7 Q2 underreporting.

For listed cement-sector M&A diligence teams: the contingent liabilities on UltraTech (₹1,685 cr), JK Cement (₹137.82 cr) and Ramco (₹258.63 cr) materially affect enterprise-value bridging. The Supreme Court has been actively reserving judgment on the cement-cartel matters since 2018; absent a final SC ruling, treat the contingent liability as the realistic exposure floor.

Cross-references and further reading

The complete entity-level BRSR Principle 7 disclosure analysis (including the broader trade-association affiliation comparison and the SASB Construction Materials EM-CM-520a.1 mapping) is in Section 7.3 (entity-specific safety + governance signals) and Section 10.2 (methodology bullets) of the BRSR Cement Sector Benchmark FY 2024-25 anchor article. The 14-entity JSON dataset at src/data/research/brsr-cement-fy2425/ carries per-entity cci_exposure_disclosed_in_brsr_p7 and related fields for machine-readable analysis.

Related methodology references:

• NGRBC Principle 7 — Public Policy methodology — covers the BRSR P7 framework including the Q2 anti-competitive corrective action disclosure obligation
• NGRBC Principle 1 — Ethics methodology — covers the BRSR P1 fines + disciplinary action disclosure under which some entities disclose the CCI matter
• NGRBC to BRSR Metric Mapping reference — full cross-walk between NGRBC Principles and BRSR-format disclosures
• Document Evidence Requirements — covers assurance-evidence patterns including contingent-liability cross-references

Methodology note

Every entity exposure documented in this spoke is sourced from the primary-source audit underlying the BRSR Cement Sector Benchmark FY 2024-25 — specifically the entity-level qc_metadata.notes_audit_2026_05_27 blocks in the 14-entity JSON dataset, each of which captures verbatim FY 2024-25 BRSR PDF page references and Auditor’s Report citations. No CCI matter is included here that was not independently verified during the May 2026 manual audit pass. Cumulative ₹2,088 crore figure = ₹1,685.13 cr (UltraTech) + ₹258.63 cr (Ramco) + ₹137.82 cr (JK Cement) + ₹6.55 cr (JK Lakshmi) + ₹0.05 cr (Star Cement, since-quashed). ACC, Nuvoco Vistas and India Cements are excluded from the cumulative figure because their FY 2024-25 financial statements do not separately quantify the cement-cartel-specific contingent-liability amount — their exposures are real but not separately disclosed.