JUDGMENT :

1. Rule. Ms. Garima Malhotra, learned advocate waives service of notice of Rule for and on behalf of the respondent Nos.1 and 2.

2. The present petition, in all, challenges four orders passed by the Competition Commission of India (for short, hereinafter referred to as `CCI’). The impugned orders are as under:

(1) Order dated 2.5.2019 by which the petitioner has been directed to furnish certain documents and details and to make submissions on the quantum of penalty that may be levied in the event, the petitioner is held to have acted in contravention of the Competition Act, 2002 (for short, hereinafter referred to as `the Act’).

(2) Investigation Report dated 7.2.2019 prepared by the Office of the Director General, CCI in case No.30 of 2014 and case No.85 of 2015.

(3) Order dated 4.7.2019 rejecting the request of the petitioner to cross examine the informant of case No.30 of 2014 and informant in case No.85 of 2015.

(4) Orders dated 1.8.2014 and 17.11.2015 by the CCI under Section 26(1) of the Act by which the CCI has directed the Director General to file a joint investigation report in respect to the violations of the provisions of the Act in context of information case Nos.30 of 2014 and 85 of 2015.

3. The facts in brief are as under:

*The petitioner is a Public Limited Company engaged in the manufacture of paper and paper products such as Maplitho, Coated Paper/Art Paper, Virgin Fiber based packaging, Copier Paper and Specialty Paper MICR/Ledger/Parchment.

* It is the case of the petitioner that the respondent no.3, the Sivakasi Master Printers Association filed Information Petition No.30 of 2014. The petitioner was arrayed as opponent No.6. It was the case of Information Petitioner that there was a cartel amongst the paper mills which would get-together and facilitate price rise every month. It was the case of the informant that in order to stop this tendency and unfair trade practice to reduce this collusive increase in price, the Information Petitioner alleged contravention of Sections 3 and 4 of the Act. Similarly, the respondent No.4 – All India Federation of Masters and Printers filed Information Petition No.85 of 2015. The CCI clubbed the proceedings and by orders dated 1.8.2014 and 17.11.2015 directed the DG to undertake investigation prima facie opining that the petitioner seems to be indulging in contravention in the paper industry.

* Based on the orders so passed, the CCI carried out investigation and submitted a consolidated report dated 7.2.2019 which the petitioner received on 9.5.2019. Considering the report so filed, by the impugned order dated 2.5.2019, the CCI called upon the petitioner to file its objections/suggestions to the impugned report on or before 30.6.2019 and also issued directions to submit audited balance sheets and profit and loss account/turn over for the last three financial years i.e. 2015-16 to 2017-18. It also directed the petitioner to submit details of the profits/revenue generated from unquoted writing and printing papers during 2015-16 to 2017-18 by way of affidavit supported by certificate of the Chartered Accountant. These proceedings are therefore under challenge.

4. Mr. Mihir Thakore, learned Senior Counsel and Mr. Devang Nanavati, learned Senior Counsel assisted by Mr. Nirag Pathak, learned advocate for the petitioner made the following submissions:

* Inviting the Court’s attention to the provisions of Section 2 which defines the terms “agreement”, “cartel,” “relevant market,” and “relevant product market” together with the provisions of Section 3, Mr. Thakore would submit that reading the entire petition of the petitioners before the Commission, what is evident is that the concentration of the printers association was only to cartelisation in respect of writing paper and printing paper such as Maplitho, Cream Wove paper and Art Paper.

* Reading Section 19 of the Act, Mr. Th