Central Consumer Protection Authority (CCPA): While taking cognizance of a representation against Rapido (Roppen Transportation Services Pvt. Ltd.) concerning pre-ride tipping prompts displayed on its ride-hailing platform, the CCPA comprising Nidhi Khare, Chief Commissioner, and Anupam Mishra, Commissioner, examined whether such prompts amounted to misleading advertisements, unfair trade practices, unfair contracts and prohibited dark patterns under the Consumer Protection Act, 2019. The CCPA held that the impugned prompts created a misleading impression in the minds of consumers that paying an amount over and above the quoted fare would improve the likelihood and speed of ride confirmation, thereby violating Sections 2(28), 2(46) and 2(47) of the Consumer Protection Act, 2019 and the Dark Patterns Guidelines, 2023. Accordingly, to safeguard the interest of the consumers, the authority directed Rapido to discontinue the impugned prompts including the interface designs and imposed a penalty of ₹10 lakh.
Background and the Factual Matrix
The present proceedings were initiated by the Central Consumer Protection Authority (CCPA) against Roppen Transportation Services Private Limited, operating under the brand name Rapido, regarding alleged misleading advertisements, unfair trade practices, unfair contractual terms, and use of dark patterns on its ride-hailing platform.
The CCPA took cognizance of the representation dated 16.05.2025 and in exercise of its powers under Sections 18 and 19 of the Consumer Protection Act, 2019, examined the concerns raised therein. In its Preliminary Inquiry Report, the CCPA issued a Show Cause Notice to the opposite party (Rapido) requiring it to furnish a response in relation to the following alleged practices:
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The app charged consumers an upfront fare for booking a ride, comprising base fare, distance and time charges, peak pricing, applicable fees, tolls and taxes.
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Consumers were sometimes shown a longer waiting period, which could result from factors such as rider unavailability or traffic congestion.
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To address the waiting time, the app displayed prompts such as “Captains aren’t accepting at ₹60. Try adding more +10, +20, +30” and “Higher the price, higher the chance of getting a ride.” which created an expectation that paying an additional tip would result in a faster ride.
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The CCPA also noted that Rapido had promoted the claim “Guaranteed Auto in 5 mins or get ₹50” through social media platforms.
The issue relating to the “Guaranteed Auto in 5 mins or get ₹50” claim, had already been examined and decided by the CCPA in a separate proceeding, and is not dealt with in the present order.
Rapido, on the other hand, denied violating the provisions of Consumer Protection Act, 2019, the Dark Patterns Guidelines,2023, and the Misleading Advertisement Guidelines,2022. It contended that the fare displayed on the platform was merely a suggested fare and that consumers were free to offer a different, including lower, fare, while Captains retained the discretion to accept or reject ride requests. Rapido further submitted that the prompts “Higher the price, higher the chance of getting a ride” and “Captains aren’t accepting at ₹[X]. Try adding…” formed part of a real-time fare negotiation mechanism and were neither mandatory nor coercive, as the matching algorithm continued searching for Captains even where consumers chose not to increase the fare. It denied creating any misleading expectation of faster ride confirmation and relied on its Terms and Conditions, which described the displayed fare as indicative and disclaimed any guarantee regarding its accuracy or reliability. Rapido further denied that the impugned practice constituted an unfair trade practice, unfair contract or confirm shaming, submitting that consumers were not penalised for declining to increase the fare and that the prompts merely reflected prevailing market conditions and driver availability.
The CCPA, upon considering Rapido’s reply and submissions made during the hearings held on 04.07.2025 and 18.07.2025, was satisfied that a prima facie case of misleading advertisement, unfair trade practice, unfair contract and use of dark patterns was made out. Accordingly, in exercise of its powers under Section 19(1) of the Consumer Protection Act, 2019, the CCPA referred the matter to the Director General (Investigation) for detailed investigation.
CCPA’s Assessment, Findings and Decision
The CCPA considered the Investigation Report, Rapido’s objections, and the submissions advanced during the proceedings, and found that the principles of natural justice had been duly complied with. The Authority noted that Rapido had been apprised of the allegations against it and afforded adequate opportunities to file its response and participate in the hearings before the matter was adjudicated on merits.
The CCPA observed that Rapido’s prompts created a sense of urgency and shortage of service, implying that refusing to pay more could result in delay or denial of the ride which created a psychological pressure in consumers to increase their payment. It accordingly found that these prompts fall within the definition of “Confirm Shaming” under the Dark Patterns Guidelines and thereby constitutes an unfair trade practice and violation of consumer rights under the Act. The CCPA further examined the “Set your price” interface, and found that the use of favourable green signals for higher fares, cautionary red signals for lower fares, and an asymmetrically designed slider steered consumers towards paying more. As Rapido had not provided any data, methodology or verifiable basis for the warning that “captains were unlikely to accept lower fares”, the authority is satisfied that this constitutes an additional and independent form of dark pattern, namely, “Interface Interference”, in addition to Confirm Shaming.
The CCPA examined that the impugned prompts conveyed an implied representation that paying a higher amount will lead to faster ride confirmation. Since the opposing party failed to substantiate this claim and had itself admitted that rides could be secured without increasing the fare, the Authority found the representation to be misleading under Section 2(28) of the CP, Act.
The CCPA has also examined the submission of the opposite party, wherein it has relied upon its Terms and Conditions to contend that no expectation is created in the mind of the consumers. The CCPA was of the view that general disclaimers cannot cure specific, real- time representations made to consumers at the time of booking. The Authority observed that while Rapido’s Terms and Conditions described the displayed fare as merely indicative and disclaimed any guarantee as to its accuracy or reliability, the impugned prompts simultaneously suggested that offering a higher fare would improve the chances of obtaining a ride. The authority, held that the two operate at entirely different levels of consumer attention and cannot be treated as substitutes for one another, a principle that underlies the very object of the Dark Patterns Guidelines, 2023.
The CCPA, referring to Clause 14.15 of the Motor Vehicle Aggregator Guidelines, 2025, observed that, “A tip, by its very nature, is an ex post facto acknowledgment, it is offered, if at all, only after the consumer has experienced the service and has formed a subjective assessment of its quality, it cannot be converted into an ex ante condition precedent for the service to be rendered at all”. It was noted that the platform’s interface design, which nudges consumers through pre-ride prompts, encouraging them to make additional payments over and above the quoted fare, without demonstrating any additional service or benefit, creating a false impression that doing so will improve the chance of ride confirmation, constituting an “unfair trade practice” under Section 2(47) of the CP, Act.
The CCPA further observed that the “advance tip” prompts effectively operate as a mechanism for extracting surge or dynamic pricing under the guise of voluntary tipping. The authority, while relying on reasoning of Karnataka High Court in Uber India Systems Pvt. Ltd. v. State of Karnataka, observed that an aggregator cannot charge a premium arising from inadequate vehicle availability, particularly where the basis for such additional charges is not transparently disclosed.
The CCPA noted that once the fare had been quoted and accepted after calculating the distance, time, traffic conditions, it constitutes the complete and concluded terms of the service contract between the consumer and the opposite party. The subsequent introduction of the impugned “an amount over and above quoted fair”/ “advance tip message/prompts”, prompting consumers to make an additional payment as a condition for timely acceptance or delivery of the ride unilaterally alters the terms of this contract to the detriment of the consumer, without his informed consent. Such an obligation is unreasonable within the meaning of Section 2(46) Of the Act, resulting in an “unfair contract” within the meaning of Section 2(46) of the CP Act.
The CCPA clarified that the consequence of permitting such a practice would extend beyond the individual unfairness as the impugned practice would institutionalise a system of price discrimination, whereby consumers availing an identical service at an identical quoted fare may receive different levels of service depending on their willingness or ability to pay an amount over and above the stated fare.
The CCPA further noted that the impugned prompts were not merely a one-time or static practice. The earlier prompt, “Captains aren’t accepting at ₹60. Try adding more +10, +20, +30,” had subsequently been modified and replaced with “Skip the wait! Get a ride faster by adding extra,” which was observed to appear immediately upon initiation of a booking search. The CCPA contended that this was contrary to Rapido’s submission that such prompts appeared only in specific and limited circumstances. The authority treated the continued and evolving deployment of the impugned prompts as a subsequent contravention.
The CCPA after carefully considering the written submissions of the opposite party, the submissions made during the hearings, and the Investigation Report held that Rapido had violated
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Guidelines for Prevention and Regulation of Dark Patterns, 2023
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Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022
The CCPA also noted that Rapido offers its services in over 120 cities across India, and the impugned misleading advertisement & unfair trade practice including dark pattern prompts have been deployed systematically and uniformly across its platform, affecting a large number of consumers across all service modes. Therefore, CCPA in exercise of powers under Sections 20 and 21 read with Section 10 of the CP Act, imposed a penalty of ₹10 lakh. The Authority further directed Rapido to discontinue the impugned prompts and interface designs, ensure compliance with the applicable consumer protection framework, maintain functional official contact details, and submit a compliance report within 15 days of receipt of the order.
[Case Details: In the matter of: Misleading advertisement, unfair trade practices and use of dark patterns by Rapido (Roppen Transportation Services Private Limited), Case No: CCPA-2/53/2025-CCPA, decided on 31-08-2026]
Decided by: Mrs. Nidhi Khare, Chief Commissioner and Mr. Anupam Mishra, Commissioner
Advocates who appeared in this case:
For Rapido (Roppen Transportation Services Pvt Ltd): Mr. Kaustav Som, Advocate and Mr. Sagar Ramagondi