The First Counsel

Practice Area

Competition & Antitrust

We handle merger clearance, cartel investigations, abuse-of-dominance proceedings and deceptive-marketing inquiries under the Competition Act 2010, before the Competition Commission of Pakistan and on appeal. We act for acquirers, respondents and complainants, from the first notice to the last court.

Competition proceedings in Pakistan are adversarial from the first page. An enquiry report reads like a charge sheet, a show-cause notice frames the case the Commission intends to prove, and the penalties under section 38 are calculated on turnover. We therefore treat every filing — including a merger application — as a document that may later be quoted back to the client, and we write it accordingly.

The practical craft lies in sequence. The party that engages early, on the enquiry rather than the show-cause notice, shapes the record everyone argues over later. The party that waits inherits a record built by someone else. We engage early, we put the economic case and the legal case in the same document, and where the Commission's order goes against the client we have already preserved the points the Tribunal and the Supreme Court will need.

The framework described here is as of mid-2026: the Competition Act 2010, the Merger Regulations of 2016 and the Commission's current thresholds and practice. Notification thresholds and the state of the long-running vires litigation should be confirmed at the time of any filing.

How We Serve

We prepare and file pre-merger applications under section 11 of the Competition Act 2010 and the Competition (Merger) Regulations 2016, and manage the Commission's Phase I and Phase II reviews. Where clearance requires it, we negotiate the conditions and undertakings on which approval issues, and we build the filing timetable into the transaction documents so the deal does not outrun its clearance.

We defend companies in investigations under section 4 of the Act, including enquiries begun by the Commission on its own motion and those triggered by complaint. We advise during search and inspection visits under sections 34 and 35, and on whether and when to seek leniency under the Commission's leniency regulations.

We act in proceedings under section 3 of the Act, from the Commission's enquiry under section 37, through the show-cause notice under section 30, to the hearing and any interim orders under section 32. We also advise dominant firms on pricing, discounting and refusal-to-deal questions before a complaint ever arrives.

Section 10 of the Act reaches false or misleading advertising, misuse of another firm's trademark or packaging, and unfounded comparative claims, and it has become one of the Commission's most used powers. We defend respondents in these proceedings and bring complaints for businesses injured by a competitor's campaign.

We take Commission orders to the Competition Appellate Tribunal and, from there, to the Supreme Court of Pakistan under the appeal provisions of the Act. Where the case warrants it, we also pursue constitutional petitions in the High Courts, in a field where challenges to the federal competition regime have been part of the landscape since the Act was passed.

We review distribution, franchise and joint-venture agreements against the Act before signature and, where an agreement needs one, apply to the Commission for an individual exemption. We also advise trade associations, whose ordinary meetings are where section 4 problems most often begin.

Representative Matters

  • 20—Advised the acquirer in the purchase of a majority stake in a Punjab-based food-manufacturing group, including CCP merger clearance.M&A
  • 20—Advised on the competition aspects of a two-to-one merger in a concentrated sector; cleared with commitments.Competition
All Representative Matters

Illustrative of the practice; matters anonymized consistent with confidentiality obligations.

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