SpiceJet Bookings Under Scanner as CCPA Imposes ₹1 Lakh Penalty

The Central Consumer Protection Authority (CCPA) has imposed a ₹1 lakh penalty on SpiceJet Ltd for allegedly using dark patterns on its online flight booking platform. The regulator held that the airline adopted deceptive interface designs that automatically enrolled customers in its loyalty programme and marketing communications without obtaining their explicit consent, violating India's consumer protection framework.

The action follows an inquiry led by Chief Commissioner Nidhi Khare and Commissioner Anupam Mishra , which found that users booking tickets were automatically enrolled in the SpiceClub Loyalty Programme through a pre-ticked checkbox . Customers were also deemed to have consented to receive promotional messages via SMS, WhatsApp and email , as the opt-in option was selected by default rather than through an affirmative action.

The CCPA noted that even after issuing a notice to the airline, SpiceJet merely replaced one pre-selected checkbox with another for promotional communications, effectively continuing the same practice. During the proceedings, the airline attributed the lapse to a technical error . However, the authority directed the company to submit an undertaking confirming that the corrective measures have been implemented permanently.

The regulator identified three prohibited dark patterns on the airline's platform— Forced Action , Interface Interference , and Trick Question . It observed that users were compelled into the loyalty programme without active consent, the interface favoured the company's preferred choices through default settings, and confusing consent language could mislead consumers during the booking process.

According to the CCPA, such practices impair consumer autonomy , undermine informed decision-making and violate the principles of fair and transparent digital commerce. It held that pre-ticked checkboxes, default settings and deceptive interface designs cannot constitute valid legal consent , as consumer approval must always be explicit, informed and affirmative .

The authority ruled that SpiceJet violated provisions of the Consumer Protection Act, 2019 , relating to unfair trade practices, misleading representations and unfair contract terms . It also found the airline in breach of Rule 4(9) of the Consumer Protection (E-Commerce) Rules, 2020 , which mandates affirmative consumer consent, along with the Guidelines for Prevention and Regulation of Dark Patterns, 2023 .

The 2023 Guidelines prohibit 13 categories of dark patterns , including False Urgency, Basket Sneaking, Confirm Shaming, Subscription Trap, Drip Pricing, Bait and Switch, Interface Interference, Trick Questions and Forced Action . They apply to e-commerce platforms, travel portals and digital service providers, making India among the first countries to introduce a dedicated regulatory framework against deceptive online interface designs.

The latest action reflects the CCPA's broader crackdown on manipulative digital practices. The regulator has increasingly directed online platforms to conduct self-audits and eliminate dark patterns, while Union Consumer Affairs Minister Prahlad Joshi has emphasised that consumer choice must be informed, not manipulated . Globally, regulators such as the European Union under the Digital Services Act (DSA) and the U.S. Federal Trade Commission (FTC) have also intensified scrutiny of deceptive online interfaces, highlighting a growing international push for transparent and consumer-centric digital experiences.