Central Consumer Protection Authority (CCPA): While considering a suo motu matter concerning Misleading advertisement and unfair trade practice by Rapido (Roppen Transportation Services Pvt Ltd), the Bench of Nidhi Khare, Chief Commissioner and Anupam Mishra, Commissioner, in order to safeguard the interests of consumers, directed Rapido to discontinue the display of misleading advertisement and imposed a penalty of Rs 10,00,000 (ten lakhs) for publishing misleading advertisement and unfair trade practices.
The CCPA held that Rapido had engaged in a practice calculated to mislead consumers by both commission and omission overstating its actual service capability while concealing qualifying conditions for the purpose of promoting its business. Such conduct not only distorted consumer decision-making but also eroded fair competition in the marketplace, thereby violating Sections 2(28) and 2(47) of the Consumer Protection Act, 2019, as well as the provisions of the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 (2022 Guidelines).
Background- Misleading Advertisement & Action by CCPA:
The suo motu cognizance revolved around impugned advertisement featuring prominently on Rapido’s official platforms including YouTube channel, giving the following guarantees:
i. Guaranteed Auto
ii. AUTO IN 5 MIN OR GET ₹ 50
In its preliminary inquiry to ascertain the genuineness of Rapido’s claims, the CCPA noted that such a strong claim, lacking hard to miss disclaimer was capable of creating a strong visual impression and a definite expectation regarding the speed and reliability of the service. This guarantee also appeared to be acted as a direct inducement to consumers as class, while concealing material conditions or limitations, if any, thereby appeared to be infringing the consumers’ right to be informed under Section 2(9) of the Consumer Protection Act, 2019 (CP Act).
It was further pointed out that during April 2023 and May 2024, around 575 consumer complaints were registered against Rapido on the National Consumer Helpline (NCH), relating to deficiency in services, non-refund of paid amounts, overcharging, failure to provide promised services, and non-return of money.
The CCPA further observed that, 5 out of 575 complaints, were related to the impugned advertisements/claims. The consumers specifically alleged that the guarantee of “AUTO IN 5 MIN OR GET ₹ 50” was not honoured. Instead of receiving the promised Rs 50, consumers were credited with only Rs 5 in the form of Rapido coins and thus misled consumers into believing that a flat amount of Rs 50 would be credited in case of failure to provide the guaranteed service. Consumers also pointed out that such misleading advertisements caused inconvenience and wasted considerable time of the consumers.
Therefore, in view of Sections 2(28), 2(47) and 21 of the CP Act, which prohibit misleading advertisements and unfair trade practices, the CCPA took cognizance of the violations. Besides taking note of CP Act provisions which bars misleading advertisements, the CCPA also took note of Guidelines 4 and 12 of the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 (2022 Guidelines), which mandate that advertisements must make only truthful and honest claims, avoid misleading consumers with unsubstantiated assertions, and ensure that any claim based on objectively verifiable facts can be substantiated when required by the Central Authority, without exaggerating the accuracy, performance, or service of the product. Therefore, the CCPA opined that the impugned guarantee-based claim appeared to be in contravention of the statutory provisions and the 2022 Guidelines.
CCPA issued a notice dated 12-06-2024 to Rapido pointing out the provisions that were violated and the 575 consumer complaints before NCH. On 27-06-2024, the CCPA received response from Rapido vis-a-vis the allegations.
CCPA’s Assessments and Findings:
The CCPA emphasised that principles of natural justice have been followed vis-a-vis giving Rapido full particulars of the allegations and adequate opportunity to respond before any adverse order is passed. Rapido had been served with a detailed notice dated 12-06-2024, the investigation report dated 02-07-2025 was shared for obtaining their response, opportunities to file responses and participate in hearings dated 17-07-2025 and 05-08-2025.
Upon perusing Rapido’s reply, submissions etc., the CCPA pointed out that the term “up to” was not used anywhere in the impugned advertisement or claims, thereby indicating that Rapido failed to disclose material information which was essential for consumers to make an informed decision.
The CCPA further noted that “T&C apply*” was hardly readable and was written in extremely small font. Further, perusing the Terms and Conditions submitted by Rapido, the CCPA noted that “₹50” benefit was not provided in actual currency but only in the form of “Rapido coins” credited to the consumer’s wallet, redeemable exclusively against bike rides on the Rapido platform and subject to a validity period of merely 7 days from the date of credit. The CCPA explained that such restrictions materially altered the nature of the promised benefit and substantially limited its utility to the consumers. “The scheme appears to be effectively coercing consumers into availing another service from the same platform within an unreasonably short period. Such a condition, which was neither disclosed in the advertisement nor reasonably expected by the average consumer, not only materially alters the nature of the promised benefit but also creates an undue compulsion to re-engage with the service of the opposite party”. Therefore, this format/design had the effect of locking consumers into repeat transactions under restrictive terms, which appeared to be unfair and contrary to the provisions of the CP Act. Mere presence of term ‘T&C’s Apply’, especially if it is in extremely fine print or not prominently displayed, does not fulfil the requirement for transparency and company cannot escape its liability from using the term ‘T&C’s Apply’.
CCPA further explained that while the advertisement prominently conveyed a categorical guarantee, the Terms and Conditions simultaneously stated that the guarantee was provided by individual captains listed on Rapido’s platform and should not be construed as a guarantee provided by Rapido itself. This contradictory position therefore was an attempt to evade liability for the very claim and appeared to be constituting both an unfair trade practice under Section 2(47) and a misleading advertisement under Section 2(28) of the CP Act read with 2022 Guidelines. The concealment of such material information from consumers, while making an absolute and unqualified claim in the advertisement, was in violation of the CP Act and the 2022 Guidelines
CCPA pointed out that Rapido failed to address the 575 consumer complaints concerning deficiencies in services, non-refund of payments, overcharging, and non-fulfilment of promised services.
CCPA also pointed out that Rapido is still running the impugned advertisement on its official platforms including YouTube, Facebook channels and also running it as ads in between normal videos on YouTube. Furthermore, the impugned ads were running in regional languages to influence consumers across India. Therefore, CCPA noted that there existed prima facie case of misleading advertisement and unfair trade practices under the CP Act.
Taking note of Rapido’s contention that impugned advertisement was merely promotional claim intended to run for a limited duration, the CCPA found the assertion as untenable and devoid of merit. It was pointed out that evidence on record conclusively established that the said advertisement was disseminated continuously for an extended period of at least 548 days (1.5 years) and propagated in multiple regional languages across the country. Such extensive and prolonged circulation, coupled with its pan-India reach, demonstrated a clear intent to influence consumers on a nationwide scale, thereby negating any assertion of its limited or transitory nature.
CCPA pointed out that the claims “Guaranteed Auto” and “AUTO IN 5 MIN OR GET ₹50” created an unqualified impression that the consumer would invariably receive ₹50 if the auto was not provided within 5 minutes. However, the material limitation that the benefit was restricted up to ₹50 was omitted from the main claim and, if at all disclosed elsewhere, the same was not presented with prominence, placement or clarity as required under the Guidelines. This omission contravened Guideline 11(a) and 11(b) of the 2022 Guidelines.
The claim of “Guaranteed Auto” and “AUTO IN 5 MIN OR GET ₹50” projected an assurance of a very high degree of service reliability. “Such representations create a clear and definite expectation in the mind of an average consumer that, irrespective of location or circumstances, an auto will be made available within a maximum waiting time of five minutes. By making such absolute promises, Rapido had given the impression that the availability of autos within the stated timeframe is an assured and standard feature of its service”.
Furthermore, “₹50” benefit was not provided in actual currency but in the form of “Rapido coins” and the entire patter of crediting the Rapido coins and restrictions on its use etc., effectively coerced consumers into availing another service from the same platform within an unreasonably short period. This condition, undisclosed in the advertisement, not only diminished the true worth of the promised “₹50” but also created undue compulsion for repeat engagement under restrictive terms, contrary to the principles of the CP Act.
“If, in reality, Rapido cannot reasonably ensure the availability of autos within five minutes for a substantial number of consumers in the advertised areas, such claims are factually inaccurate and amount to inducing consumers on the basis of false or misleading representations”.
The CCPA pointed out that Rapido’s conduct left no doubt regarding their apathetic attitude of towards consumer rights and consumer interest. Therefore, it was held that Rapido had engaged in unfair trade practice, false or misleading advertisement as envisaged under the CP Act and therefore it is necessary to impose a penalty in consumer interest in addition to the other consequences.
The CCPA thus imposed a penalty of Rs 10 Lakhs on Rapido after taking into consideration their transgressions, that Rapido ran its services in 120 cities and impugned misleading ad ran for 548 days. The CCPA further directed Rapido to reimburse the consumers who did not receive the promised Rs 50 as per the misleading “AUTO IN 5 MIN OR GET ₹50” ad.
[In the matter of: Misleading advertisement and unfair trade practice by Rapido (Roppen Transportation Services Pvt Ltd), Case No: CCPA-2/35/2024-CCPA, decided on 20-8-2025]
Advocates who appeared in this case:
For Rapido (Roppen Transportation Services Pvt Ltd): Mr. Kaustav Som, Advocate; Mr. Sagar Ramangondi, Advocate
