CONSUMER PROTECTION LAW IN THE USA: LESSONS FOR INDIA

This Article is written by Manasi Yamgar of School of Law, MIT WPU, an intern under Legal Vidhiya.

ABSTRACT

In an increasingly digital and globalized marketplace, consumer protection has become a critical area of legal and policy development. This article presents a comparative analysis of consumer protection frameworks in the United States and India, focusing on institutional structures, enforcement mechanisms, and legislative evolution. The U.S. system, spearheaded by autonomous regulators such as the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB), has developed a mature regime supported by strong enforcement, class action litigation, and digital oversight.

India, while showing notable progress through the Consumer Protection Act, 2019 and the E-Commerce Rules, 2020, continues to face challenges related to institutional autonomy, judicial delays, and lack of awareness at the grassroots level. The establishment of the Central Consumer Protection Authority (CCPA) marks a shift toward a more modern consumer rights regime; however, its effectiveness is limited by structural and functional constraints.

This paper identifies key lessons from the U.S. model that can be adapted to the Indian context, including enhancing regulatory independence, formalizing collective redress mechanisms, and building technological enforcement capabilities. It concludes by emphasizing the need for not just legislative reform but also practical, inclusive, and rights-based implementation strategies to protect consumers in both traditional and digital economies.

KEYWORDS

Consumer Protection, United States, India, Federal Trade Commission (FTC), Consumer Financial Protection Bureau (CFPB), Central Consumer Protection Authority (CCPA), Class Action, Digital Consumer Rights, E-Commerce Regulation, Bottom of Form

INTRODUCTION

Consumer protection law lies at the heart of any functional market economy, serving as a tool to balance the inherent power asymmetry between businesses and consumers. As markets globalize and transactions increasingly move online, the challenges faced by consumers have grown more complex. They now range from unfair contract terms and misleading advertisements to privacy violations and algorithmic bias. In such a landscape, it becomes imperative for states to adopt robust legal frameworks that not only protect consumers but also create mechanisms for speedy and affordable redressal.

The United States provides an evolved model of consumer protection. It has built a layered legal and regulatory system anchored by the Federal Trade Commission (FTC), established in 1914, and later strengthened by the Consumer Financial Protection Bureau (CFPB), created under the Dodd-Frank Act of 2010[1]. These institutions possess both investigative and quasi-judicial powers, enabling them to regulate industries, initiate market-wide investigations, and penalize wrongdoers effectively[2].

India, though relatively newer to structured consumer protection, has shown commendable progress. The Consumer Protection Act of 1986 was a path-breaking law for its time, but with the digital economy reshaping commerce, it was eventually replaced by the Consumer Protection Act, 2019. The new Act introduces significant reforms such as the creation of the Central Consumer Protection Authority (CCPA), product liability norms, e-commerce rules, and mediation as an alternative to litigation[3].

However, India’s framework still suffers from under-enforcement, backlog in redressal forums, and limited institutional autonomy. While laws exist on paper, their implementation remains patchy, particularly in rural and semi-urban areas where legal literacy is low[4].

This paper adopts a comparative legal methodology to analyze the consumer protection ecosystems in the U.S. and India. By identifying areas of strength and concern in both jurisdictions, it aims to draw practical lessons for Indian policymakers, legal professionals, and regulatory agencies. The purpose is not to suggest a legal transplant but to contextualize best practices within India’s constitutional and federal structure.

EVOLUTION AND FRAMEWORK OF CONSUMER PROTECTION IN THE USA

The evolution of consumer protection in the United States reflects a steady shift from a laissez-faire model to a proactive, regulatory-led system. Historically, consumer transactions were governed by the doctrine of caveat emptor (let the buyer beware), which placed the burden of due diligence on the consumer. However, as industrialization progressed and products became mass-produced and distributed, it became clear that individual consumers lacked the bargaining power or information necessary to protect themselves from unfair trade practices[5].

A turning point came with the enactment of the Federal Trade Commission Act of 1914, which established the Federal Trade Commission (FTC). The FTC was tasked with preventing “unfair or deceptive acts or practices in or affecting commerce,” and this became the cornerstone of federal consumer protection enforcement[6]. The authority of the FTC was later expanded through court interpretations and legislative amendments, allowing it to address a wide range of issues, from misleading advertisements to fraud.

The Consumer Product Safety Act of 1972 introduced statutory safeguards for consumer goods and empowered the Consumer Product Safety Commission (CPSC) to set safety standards and issue recalls for defective products[7]. Similarly, the Magnuson-Moss Warranty Act of 1975 established federal standards for warranties on consumer products, enhancing transparency and consumer recourse against defective goods[8].

Following the 2008 financial crisis, consumer protection in financial services became a key focus. This led to the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, 2010, which created the Consumer Financial Protection Bureau (CFPB). The CFPB was given sweeping powers to regulate credit cards, mortgages, payday loans, and other financial instruments, especially with a view to protecting vulnerable consumers from predatory practices[9].

Thus, the U.S. consumer protection framework evolved through legislative responsiveness to economic crises, consumer advocacy, and judicial reinforcement. It reflects a regulatory philosophy grounded in transparency, market fairness, and institutional accountability—traits that have made it a global benchmark.

INSTITUTIONAL AND REGULATORY MECHANISMS IN THE USA

The success of the U.S. consumer protection regime rests largely on the robust and multi-tiered institutional mechanisms established over time. At the federal level, the Federal Trade Commission (FTC) serves as the cornerstone of consumer protection. Created in 1914, the FTC has broad authority to prohibit “unfair or deceptive acts or practices” under Section 5 of the Federal Trade Commission Act[10]. It undertakes investigations, issues cease-and-desist orders, brings civil suits, and educates both consumers and businesses. Importantly, the FTC functions as both a regulatory and quasi-judicial body, a dual role that strengthens its enforcement capacity.

The Consumer Financial Protection Bureau (CFPB), established under the Dodd-Frank Act of 2010, is one of the key federal body in the financial sector. The CFPB regulates financial institutions, formulates rules for disclosure and transparency in lending practices, and provides redress mechanisms for grievances related to credit cards, housing finance, and personal loans[11]. Unlike many Indian regulators, the CFPB enjoys operational independence and can initiate litigation against violators in its own name.

Specialized federal agencies also play a role. The Consumer Product Safety Commission (CPSC) enforces product safety standards and mandates recalls for dangerous goods[12]. The Food and Drug Administration (FDA) is responsible for food, drugs, and cosmetics, while the Federal Communications Commission (FCC) regulates advertising and digital communications.

A unique strength of the U.S. model is the role played by state attorneys general, who have concurrent jurisdiction to enforce both state and federal consumer laws. They often collaborate with federal agencies in multistate lawsuits against corporations engaged in systemic violations[13]. Additionally, the U.S. legal framework actively supports private enforcement through class action lawsuits, especially in antitrust, consumer fraud, and defective product claims. The contingency fee structure allows consumers to litigate without bearing upfront costs, while discovery procedures empower litigants with access to internal corporate documents[14].

This integrated institutional framework—combining federal, state, and private enforcement—offers a comprehensive model of consumer protection, characterized by responsiveness, autonomy, and accountability. It reflects a philosophy where consumers are seen not just as passive market participants but as rights-bearing individuals entitled to institutional support and redress.

CONTEMPORARY ISSUES AND ENFORCEMENT PRACTICES

The consumer protection landscape in the United States continues to evolve in response to rapid technological advancements and new forms of commercial deception. One of the most pressing modern challenges is the proliferation of “dark patterns”—user interface designs that intentionally manipulate consumers into making unintended choices, such as purchasing subscriptions, sharing data, or waiving rights without full knowledge. The Federal Trade Commission (FTC) has recognized dark patterns as deceptive trade practices and initiated multiple enforcement actions to curb their use[15].

Although online privacy and data protection is of great concern, the U.S. does not have an overarching federal data privacy law like the GDPR in the European Union so the FTC uses its enforcement authority under Section 5 of the FTC Act to enforce privacy rules. It has penalized several tech companies for failing to secure user data, making false representations in privacy policies, and unfair data handling practices[16]. Similarly, the Consumer Financial Protection Bureau (CFPB) monitors algorithmic discrimination in digital lending and credit scoring tools, underscoring its commitment to fairness in financial services[17].

Another area of increasing regulatory attention is AI and automated decision-making, especially as it affects consumer autonomy. For example, the use of algorithms in online pricing, content curation, and product recommendation systems is being scrutinized for bias, discrimination, and manipulation.

From an enforcement perspective, the U.S. system emphasizes both preventive and punitive mechanisms. The FTC and CFPB not only impose substantial fines but also require remedial actions like consumer refunds, public disclosures, and long-term compliance monitoring. Consumers can file reports/complaints directly with the government on websites such as SaferProducts.gov, and ConsumerSentinel.gov, which allows for rapid response from the regulatory agency if needed.

Class action lawsuits remain a powerful form of private enforcement. Recent years have witnessed major settlements in consumer data breaches, false advertising, and product liability. The litigation-friendly environment, bolstered by contingency fees and discovery rights, ensures corporate accountability and wide consumer participation[18].

Despite its strengths, the U.S. system faces challenges including overlapping jurisdictions, under regulation of Big Tech, and insufficient protections for marginalized communities. Nonetheless, it remains one of the most proactive and adaptive consumer protection regimes in the world.

CONSUMER PROTECTION FRAMEWORK IN INDIA

India’s consumer protection framework has undergone significant legal transformation since the late 20th century. The foundation was laid with the enactment of the Consumer Protection Act, 1986, which introduced statutory rights for consumers and provided for a three-tier quasi-judicial redressal mechanism. This law was lauded for its simplicity and accessibility, especially in a developing economy where the average consumer lacked bargaining power or legal awareness. However, by the 2010s, the 1986 Act had become outdated due to the rise of e-commerce, digital contracts, misleading influencer advertising, and complex supply chains[19].

Recognizing these challenges, the Indian Parliament enacted the Consumer Protection Act, 2019, replacing the earlier law and introducing a modern and comprehensive regulatory framework. The 2019 Act retains the three-tier adjudicatory system (District, State, and National Commissions) while incorporating new features such as product liability, mediation cells, electronic complaint filing, and the establishment of the Central Consumer Protection Authority (CCPA)[20].

The CCPA is empowered to investigate unfair trade practices, initiate class-action complaints, penalize false advertisements, and order the recall of unsafe goods. While conceptually similar to the U.S. FTC, the CCPA is still developing in terms of institutional capacity, autonomy, and enforcement mechanisms. Another major step forward was the notification of the Consumer Protection (E-Commerce) Rules, 2020, which apply to all e-commerce entities operating in India, including marketplaces and inventory-based models. These rules require transparent disclosure of product information, appointment of grievance officers, and consumer-friendly return and refund policies[21].

Technological integration has also improved access to justice. Platforms like E-Daakhil allow consumers to file complaints online without physical presence at consumer forums, thereby increasing inclusivity, especially in Tier II and III cities[22]. However, systemic issues such as vacancy in forums, delayed judgments, lack of legal literacy, and poor enforcement at the grassroots level continue to undermine the efficacy of the system.

While India’s legislation has kept pace with global standards, the gap lies in execution. Strengthening regulatory institutions, empowering consumer commissions, and ensuring legal awareness at the grassroots level are essential to make the consumer protection regime more effective.

COMPARATIVE ANALYSIS: USA VS INDIA

A comparative analysis of consumer protection laws in the United States and India reveals both converging aspirations and diverging implementation realities. Both jurisdictions recognize the need for robust consumer rights in the face of corporate power, misleading advertising, and digital market abuse. However, the legal systems, institutional setups, and enforcement models differ significantly.

In the U.S., institutions like the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) function as independent and well-funded watchdogs. These agencies have extensive powers to investigate, regulate, penalize, and educate. For instance, the FTC can initiate nationwide investigations, issue cease-and-desist orders, and even impose multimillion-dollar fines on violators under Section 5 of the FTC Act[23]. The CFPB, meanwhile, specializes in financial consumer rights and is equipped to deal with complex fintech practices[24].

India’s Central Consumer Protection Authority (CCPA), though structurally similar, operates under the administrative oversight of the Ministry of Consumer Affairs. Unlike its American counterparts, it lacks financial autonomy, investigative depth, and institutional presence across states[25]. Moreover, India’s redressal system—comprising District, State, and National Commissions—is plagued by delays, case backlogs, and inadequate staffing, which severely impacts consumer confidence[26].

Another key area of difference lies in litigation and enforcement culture. The U.S. legal environment supports class action lawsuits with contingency fee arrangements and discovery rights, enabling affected consumers to hold corporations accountable through collective action[27]. In contrast, India lacks a codified class action framework under consumer law, and existing provisions under the Civil Procedure Code are rarely used in practice.

Digital consumer protection also reflects this contrast. While the U.S. has actively prosecuted dark patterns and privacy breaches using broad statutory interpretation, India is still refining its approach to digital harms. The E-Commerce Rules, 2020 are a good starting point but require robust enforcement mechanisms and better institutional coordination[28].

In essence, India’s consumer protection framework shows legal ambition but weak institutional realization, whereas the U.S. model reflects mature regulatory enforcement and consumer activism. Bridging this gap requires India to draw adaptive lessons from the American experience without compromising its socio-legal context.

LESSONS FOR INDIA FROM THE U.S. SYSTEM

While India’s consumer protection regime has progressed significantly, the U.S. model offers several actionable lessons that could enhance the Indian system’s effectiveness, accessibility, and institutional integrity. These lessons do not suggest wholesale replication, but rather adaptive borrowing in light of India’s socio-economic and constitutional framework.

First, India must strengthen the autonomy and operational capacity of its key regulatory bodies. The Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) in the U.S. operate independently of political influence and are well-funded, allowing them to regulate industries without interference[29]. In contrast, the Central Consumer Protection Authority (CCPA) in India remains tethered to the Ministry of Consumer Affairs and lacks adequate financial or staffing resources[30]. Institutional independence is key for credible and timely action.

Second, India should consider formalizing a class action litigation framework within its consumer law. Class actions in the U.S. empower consumers to collectively challenge corporate misconduct, often with contingency fee models that lower litigation costs[31]. Although the Code of Civil Procedure permits representative suits under Order, I Rule 8, their use in consumer disputes remains rare and procedurally constrained[32]. A statutory structure for consumer class actions could significantly enhance access to justice.

Third, India must adopt a unified digital consumer protection strategy. The U.S. has actively prosecuted deceptive digital designs—so-called “dark patterns”—and data breaches using broad interpretations of unfair trade practice laws[33]. India’s E-Commerce Rules, 2020 are a step forward but must be accompanied by technical expertise and enforcement capability within the CCPA or an allied digital regulator[34].

Fourth, financial consumer protection needs refinement. The CFPB’s sector-specific oversight and algorithmic scrutiny provide a valuable model for India’s fragmented regulation of financial services, which currently involves the RBI, SEBI, IRDAI, and others.

Lastly, public-facing complaint portals, investigative dashboards, and regulatory transparency—hallmarks of the U.S. system—should inspire India to build participatory and data-driven enforcement tools. These reforms would not only ensure deterrence but also restore public faith in the consumer justice system.

CHALLENGES IN ADAPTATION TO INDIAN CONTEXT

While the United States offers valuable structural and institutional lessons in consumer protection, direct transplantation into India’s legal ecosystem is neither feasible nor desirable. India’s socio-economic diversity, constitutional structure, and developmental challenges necessitate cautious contextualization of foreign models. Several constraints exist that could hamper the effective adaptation of U.S. best practices.

Firstly, India’s quasi-federal structure often leads to jurisdictional overlap between central and state agencies. While the U.S. handles multi-level governance efficiently through cooperation between federal agencies and state attorneys general, India faces frequent bureaucratic friction between ministries, regulatory authorities, and state governments[35]. The absence of harmonized consumer protection frameworks across states adds to the confusion, particularly in e-commerce and digital services.

Secondly, the Indian legal system is plagued by chronic delays, infrastructural inadequacies, and under-resourced tribunals. Even though the Consumer Protection Act, 2019 provides for time-bound redressal, the consumer commissions—especially at the district level—suffer from long pendency, insufficient staffing, and lack of digital infrastructure[36]. This significantly reduces consumer confidence in formal justice systems.

Thirdly, legal literacy and access to justice remain deeply unequal in India. Rural and marginalized populations often lack the awareness, financial resources, or institutional support required to initiate consumer complaints. The U.S. system benefits from a mature civil society, higher internet penetration, and stronger legal awareness among its citizens—conditions that are still evolving in India[37].

Fourth, the absence of a dedicated class action mechanism and contingency fee culture makes collective litigation financially unviable for most Indian consumers. Efforts to introduce such features must be tailored to prevent misuse while enhancing accessibility[38].

Finally, digital consumer protection poses a major challenge. The CCPA lacks the forensic and technical expertise to investigate data manipulation, dark patterns, or algorithmic discrimination at the scale seen in developed countries. Strengthening institutional capabilities in cybersecurity, AI governance, and digital evidence management is essential if India hopes to keep pace with evolving online harms[39].

To adapt U.S. best practices, India must undertake legal, institutional, and social reforms that respond to local realities rather than imposing imported solutions wholesale.

RECOMMENDATIONS AND WAY FORWARD

Building a strong and inclusive consumer protection regime in India requires more than legislative ambition—it demands sustained administrative reforms, institutional empowerment, legal innovation, and public engagement. Drawing from the U.S. experience and contextualizing it within India’s socio-legal environment, the following multi-pronged recommendations are proposed:

• The Central Consumer Protection Authority (CCPA) must be granted greater financial and operational independence. Drawing from the U.S. FTC and CFPB, it should have its own investigative, regulatory, and adjudicatory arms. Appointments should be based on technical expertise rather than bureaucratic rotation[40].
• India must enact a dedicated class action mechanism under consumer law. This would allow affected consumers to aggregate claims and pursue relief collectively, increasing access to justice while reducing pressure on individual litigants. Judicial interpretation of Order I Rule 8 of the CPC should be liberalized or supplemented by statutory reforms[41].
• The rise of dark patterns, algorithmic manipulation, and misleading digital interfaces requires a consolidated regulatory strategy. The E-Commerce Rules, 2020 should be harmonized with data protection laws, and the CCPA must develop technical units to detect and investigate digital harms[42].
• While mediation is provided under the Consumer Protection Act, 2019, its use is limited. Strengthening ADR through capacity-building, online resolution tools, and integration with consumer commissions will reduce pendency and encourage early settlements[43].
• Inspired by U.S. campaigns led by the FTC and civil society groups, India should invest in public education, especially through regional languages and digital literacy tools. Legal aid programs must be expanded to help vulnerable groups navigate consumer redressal systems[44].
• The CCPA should release annual enforcement reports, conduct public consultations on key policy changes, and maintain open-access complaint dashboards similar to ConsumerSentinel.gov in the U.S. This will build trust and encourage participatory governance[45].

By pursuing these reforms, India can advance toward a consumer-first ecosystem—one that is not only rights-based and technologically equipped but also culturally responsive and socially inclusive.

CONCLUSION

Consumer protection today must address not only traditional marketplace issues but also challenges emerging from digital ecosystems, algorithmic decisions, and cross-border commerce. This comparative study has examined the U.S. model—anchored by autonomous institutions like the FTC and CFPB—as an example of robust enforcement, proactive regulation, and consumer empowerment.

India’s efforts, especially through the Consumer Protection Act, 2019 and the E-Commerce Rules, 2020, demonstrate a strong legislative intent. The creation of the CCPA, mediation mechanisms, and online complaint portals reflects this progress. However, practical limitations remain, such as enforcement delays, limited institutional autonomy, and low public legal awareness.

While both nations share similar goals, India must tailor global best practices to its own socio-economic and federal context. Strengthening regulatory independence, introducing class actions, enhancing digital oversight, and expanding legal literacy can bridge the enforcement gap. In essence, the future of consumer protection in India depends not just on sound laws but on their effective and inclusive implementation—ensuring that consumer rights are protected in both physical and digital marketplaces.

REFERENCES

1. Federal Trade Commission Act, 15 U.S.C. §§ 41–58 (1914).
2. Consumer Product Safety Act, 15 U.S.C. §§ 2051–2089 (1972).
3. Magnuson-Moss Warranty Act, 15 U.S.C. §§ 2301–2312 (1975).
4. Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5301 (2010).
5. Consumer Protection Act, No. 35, Acts of Parliament, 2019 (India).
6. Consumer Protection Act, No. 68, Acts of Parliament, 1986 (India).
7. Consumer Protection (E-Commerce) Rules, G.S.R. 462(E), Gazette of India, July 23, 2020.
8. Code of Civil Procedure, § Order I, Rule 8 (1908) (India).
9. Federal Trade Commission, Consumer Sentinel Network Data Book 2022, https://www.ftc.gov/system/files/ftc_gov/pdf/csn_annual_data_book_2022.pdf.
10. Federal Trade Commission, Bringing Dark Patterns to Light, FTC Staff Report (Sept. 2022), https://www.ftc.gov/system/files/ftc_gov/pdf/dark-patterns-report-sept2022.pdf.
11. Consumer Financial Protection Bureau, Supervisory Highlights: Issue 28 (Spring 2022), https://www.consumerfinance.gov/data-research/supervisory-highlights/.
12. Spencer Weber Waller, William Kovacic & Christopher Leslie, Consumer Protection in the United States: An Overview, Loyola Univ. Chicago School of Law Research Paper No. 2007-008 (2007), https://ssrn.com/abstract=1000226.
13. Ramesh Sakunaveeti, Guardians of the Consumer: A Comparative Analysis of Consumer Protection Laws Across Countries, 3 J. LEGAL SUBJ. 28, 33–34 (2023).
14. Rupali Mandal, Consumer Protection in India: An Analytical Study of the Legal Framework, Challenges, and Evolving Jurisprudence, 1 CONSUMER L. & POL’Y REV. 1, 6–7 (2025).
15. Reserve Bank of India (RBI), Report of the Working Group on Digital Lending Including Lending Through Online Platforms and Mobile Apps (Nov. 2021), https://rbidocs.rbi.org.in/rdocs/PublicationReport/Pdfs/DIGITALLENDINGF6A762E3A7B34FADB2300B7D6F83CD9C.PDF.
16. Department of Consumer Affairs, Ministry of Consumer Affairs, Govt. of India, Annual Report 2022–23, https://consumeraffairs.nic.in/annual-report.
17. Organisation for Economic Co-operation and Development (OECD), Protecting Consumers Online: A Brief Guide for Policymakers (2021), https://www.oecd.org/sti/consumer/brief-protecting-consumers-online.pdf.
18. Ajay Agnihotri & Neeraj Prakash Rai, Comparative Analysis of Consumer Protection Laws: Lessons for India from the United States and United Kingdom, 6 Int’l J. Res. Publ’ns & Revs. 5032 (2025).

[1] Federal Trade Commission Act, 15 U.S.C. § 45 (1914) (USA).

[2] Spencer Weber Waller et al., Consumer Protection in the United States: An Overview 2 (2011), https://ssrn.com/abstract=1000226.

[3] Consumer Protection Act, No. 35, Acts of Parliament, 2019 (India).

[4] Rupali Mandal, Consumer Protection in India: An Analytical Study of the Legal Framework, Challenges, and Evolving Jurisprudence, 1 CONSUMER L. & POL’Y REV. 1, 1–4 (2025).

[5] Spencer Weber Waller et al., Consumer Protection in the United States: An Overview 2–4 (2011), https://ssrn.com/abstract=1000226.

[6] Federal Trade Commission Act, 15 U.S.C. § 45 (1914) (USA).

[7] Consumer Product Safety Act, 15 U.S.C. §§ 2051–2089 (1972) (USA).

[8] Magnuson-Moss Warranty Act, 15 U.S.C. § 2301 et seq. (1975) (USA).

[9] Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5301 et seq. (2010) (USA).

[10] Federal Trade Commission Act, 15 U.S.C. § 45 (1914) (USA).

[11] Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5481 et seq. (2010) (USA).

[12] Consumer Product Safety Act, 15 U.S.C. §§ 2051–2089 (1972) (USA).

[13] Ramesh Sakunaveeti, Guardians of the Consumer: A Comparative Analysis of Consumer Protection Laws Across Countries, 3 J. LEGAL SUBJ. 28, 30–32 (2023).

[14] Spencer Weber Waller et al., Consumer Protection in the United States: An Overview 6–10 (2011), https://ssrn.com/abstract=1000226.

[15] Federal Trade Commission, Bringing Dark Patterns to Light 1–3 (Sept. 2022), https://www.ftc.gov/system/files/ftc_gov/pdf/P214800DarkPatternsFTCStaffReport.pdf.

[16] Federal Trade Commission Act, 15 U.S.C. § 45 (1914) (USA).

[17] Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5481 et seq. (2010) (USA).

[18] Ramesh Sakunaveeti, Guardians of the Consumer: A Comparative Analysis of Consumer Protection Laws Across Countries, 3 J. LEGAL SUBJ. 28, 31–32 (2023).

[19] Consumer Protection Act, No. 68, Acts of Parliament, 1986 (India).

[20] Consumer Protection Act, No. 35, Acts of Parliament, 2019 (India).

[21] Consumer Protection (E-Commerce) Rules, 2020, G.S.R. 462(E), Gazette of India, July 23, 2020.

[22] Ajay Agnihotri & Neeraj Prakash Rai, Comparative Analysis of Consumer Protection Laws: Lessons for India from the United States and United Kingdom, 6 IJRPR 5032, 5033–5034 (2025).

[23] Federal Trade Commission Act, 15 U.S.C. § 45 (1914) (USA).

[24] Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5481 et seq. (2010) (USA).

[25] Consumer Protection Act, No. 35, Acts of Parliament, 2019 (India).

[26] Ajay Agnihotri & Neeraj Prakash Rai, Comparative Analysis of Consumer Protection Laws: Lessons for India from the United States and United Kingdom, 6 IJRPR 5032, 5034–5035 (2025).

[27] Ramesh Sakunaveeti, Guardians of the Consumer: A Comparative Analysis of Consumer Protection Laws Across Countries, 3 J. LEGAL SUBJ. 28, 32 (2023).

[28] Consumer Protection (E-Commerce) Rules, 2020, G.S.R. 462(E), Gazette of India, July 23, 2020.

[29] Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5481 et seq. (2010) (USA).

[30] Consumer Protection Act, No. 35, Acts of Parliament, 2019 (India).

[31] Ramesh Sakunaveeti, Guardians of the Consumer: A Comparative Analysis of Consumer Protection Laws Across Countries, 3 J. LEGAL SUBJ. 28, 30–33 (2023).

[32] Code of Civil Procedure, § Order I, Rule 8 (1908) (India).

[33] Federal Trade Commission, Bringing Dark Patterns to Light 1–3 (Sept. 2022), https://www.ftc.gov/system/files/ftc_gov/pdf/P214800DarkPatternsFTCStaffReport.pdf.

[34] Consumer Protection (E-Commerce) Rules, 2020, G.S.R. 462(E), Gazette of India, July 23, 2020.

[35] Ramesh Sakunaveeti, Guardians of the Consumer: A Comparative Analysis of Consumer Protection Laws Across Countries, 3 J. LEGAL SUBJ. 28, 34 (2023).

[36] Ajay Agnihotri & Neeraj Prakash Rai, Comparative Analysis of Consumer Protection Laws: Lessons for India from the United States and United Kingdom, 6 IJRPR 5032, 5034 (2025).

[37] Rupali Mandal, Consumer Protection in India: An Analytical Study of the Legal Framework, Challenges, and Evolving Jurisprudence, 1 CONSUMER L. & POL’Y REV. 1, 5–6 (2025).

[38] Code of Civil Procedure, § Order I, Rule 8 (1908) (India).

[39] Consumer Protection (E-Commerce) Rules, 2020, G.S.R. 462(E), Gazette of India, July 23, 2020.

[40] Consumer Protection Act, No. 35, Acts of Parliament, 2019 (India).

[41] Code of Civil Procedure, § Order I, Rule 8 (1908) (India).

[42] Consumer Protection (E-Commerce) Rules, 2020, G.S.R. 462(E), Gazette of India, July 23, 2020.

[43] Rupali Mandal, Consumer Protection in India: An Analytical Study of the Legal Framework, Challenges, and Evolving Jurisprudence, 1 CONSUMER L. & POL’Y REV. 1, 6–7 (2025).

[44] Spencer Weber Waller et al., Consumer Protection in the United States: An Overview 12–13 (2011), https://ssrn.com/abstract=1000226.

[45] Federal Trade Commission, Consumer Sentinel Network Data Book 2022, https://www.ftc.gov/reports/consumer-sentinel-network-data-book-2022.

Disclaimer: The materials provided herein are intended solely for informational purposes. Accessing or using the site or the materials does not establish an attorney-client relationship. The information presented on this site is not to be construed as legal or professional advice, and it should not be relied upon for such purposes or used as a substitute for advice from a licensed attorney in your state. Additionally, the viewpoint presented by the author is personal.

Admin