The Central Consumer Protection Authority (CCPA) has imposed a penalty of Rs. 10 lakh on Roppen Transportation Services Pvt. Ltd., which operates the app-based taxi aggregator Rapido, for the use of dark patterns in its ride-booking interface, misleading advertisements, and unfair contract terms against the Guidelines for Prevention and Regulation of Dark Patterns, 2023. The order is of significance because the violation did not arise from what Rapido advertised, but from how it manipulated consumers in making a choice.

The CCPA observed that the interface of Rapido first generates and displays the fare to the consumer computed by its algorithm; after quoting the fare itself, the consumer is prompted, through the language “Higher the price, higher the chance of getting a ride”, to increase the very price that the platform had itself just quoted to him. This invites the consumer to distrust and revise the figure upward that the app's own algorithm presented moments earlier.

The CCPA finds that such design, sequencing and language of the impugned prompts amount to a form of behavioural nudging that induces a sense of urgency which bears the essential characteristics of dark patterns, in particular Confirm Shaming and Interface Interference and directed Rapido to discontinue practices that steer consumers towards paying additional cost.

Dark Patterns: Regulating the Architecture of Consumer Choice

Section 21 of the Consumer Protection Act, 2019 caps the penalty for a false or misleading advertisement at Rs 10 lakh for a first contravention, rising to Rs 50 lakh for a subsequent one. The 2023 Guidelines were notified under Section 18 of the Act, and it covers the consumer manipulation through Dark Patterns.

The Guidelines for Prevention and Regulation of Dark Patterns, 2023, define 'dark patterns' as any practices or deceptive design patterns that are designed to mislead or trick users into doing something they originally did not intend by subverting or impairing consumer autonomy, decision-making or choice, amounting to misleading advertisement or unfair trade practice or violation of consumer rights.

Rapido's case cannot be read in isolation from CCPA's wider regulation of apps and digital platforms. The May 2025 notice was issued to eleven companies, including Zepto, Uber, and Ola, over pre-ride tipping and dynamic pricing. In December 2025, CCPA fined Zepto Rs 7 lakh for drip pricing and basket sneaking. In August 2026, several other platforms have been penalised by CCPA, including IndiGo, FirstCry, SpiceJet, PharmaEasy, BookMyShow, and Physics Wallah; penalties ranged from Rs 1 lakh to Rs 7 lakh.

The significance lies in consumer autonomy. The traditional consumer protection laws generally examine the representations made to the consumers, whether the price was accurately disclosed or whether the advertisement was misleading. Dark Patterns add another layer to the manner in which choices themselves are presented to protect consumers from manipulation.

Confirm Shaming: Pressure Disguised as Information

One of the practices identified in the CCPA in Rapido's interface was confirm shaming. Under the 2023 Guidelines, 'confirm shaming' involves the use of language or other means that creates a sense of fear, shame, ridicule or guilt in the mind of the user to nudge the user to act in a certain way that results in the user purchasing a product or service from the platform.

The prompts on Rapido are designed to psychologically pressure consumers into paying amounts above the stated fare by creating a sense of urgency and shortage of service, implying that failure to tip will result in denial of a ride or a longer wait for service. The question is not whether a consumer could refuse additional payment but whether the surrounding prompts and messaging impaired the consumer's ability to make that decision freely.

Interface Interference: When Design Influences the Decision

The second dark pattern identified by CCPA was Interface Interference. It is a design element in the interface that manipulates the user's choices by highlighting certain aspects and concealing other relevant factors that may have affected the user's decision.

The use of alarming red signalling and cautionary language specifically and exclusively at the point where a Consumer Seeks to pay less than the suggested/quoted fare, contrasted with affirming green signalling at the point where he pays more, constitutes a design choice calculated to discourage the exercise of a choice that is to manipulate the visual architecture of the consumer's choice.

The consumer has the power to reject an option while simultaneously being presented with an interface designed to make rejection appear less attractive, which steers the consumers towards paying more for their desired ride.

The Consumer Welfare: From Disclosure to Genuine Consumer Autonomy

The Consumer Protection Act under Section 2(47) defines “unfair trade practice” broadly enough to encompass deceptive practices adopted for promoting the sale or provision of goods or services. The order of the CCPA against Rapido demonstrates that these provisions can operate alongside a technology-driven market where the alleged unfairness is embedded in a digital interface.

In an era where Interfaces weaponise psychology, the traditional disclosure-based consumer protection is not sufficient for digital markets. A platform may disclose information while simultaneously arranging the interface in a way that one option is visually dominant, emotionally reassuring or may appear apparently necessary.

This does not mean that every design choice shall automatically become unlawful. Digital platforms necessarily use design, recommendations and pricing mechanisms to facilitate smooth transactions, but a line has to be drawn where legitimate design ends and consumer manipulation begins.

Protecting the Consumer Behind the Screen

The order against Rapido marks an important milestone in Indian consumer protection law, as the consumer in this digital era is no longer interacting only with the seller, an advertisement or a contract. Increasingly, the consumer is interacting with an interface designed by the seller to avail the services.

The interface can determine what is prominent, what is risky, what appears attractive and ultimately, what the consumer chooses. The CCPA, in its order, highlighted the risk of prompts in the app, which has the effect of institutionalising a practice where access to an essential and basic service becomes contingent on the consumer's willingness and ability to pay more than the stated price.

The consumer should not be psychologically pressured into an additional payment at the point of maximum vulnerability, when he has already committed to a journey and is waiting for ride confirmation. These practices will be fundamentally contrary to the principle of consumer welfare and fair market conduct.

The dark pattern regulation of the platforms and the apps in the contemporary time is not that technology itself is problematic. It is that the consumer's choice must remain genuinely consumer choice. Where the design techniques or the prompts impair the autonomy of the consumer for commercial gain, consumer law may have to examine not only the truthfulness of the information, but the architecture through which the information is presented.

Author is a 4th year, B.B.A LLB. (Hons.) student at Chanakya National Law University. Views are personal.