Madison alleges CCI 20-hour raid unlawful; calls search ‘opaque and unconstitutional’
In the days following the raid, Madison claims it was not given any clear inventory or access to the seized material, leaving it in the dark about what evidence the DG now holds.
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A late-night search operation by officials of the Competition Commission of India (CCI) at the Mumbai office of Madison Communications Pvt. Ltd. has become the focal point of a legal battle in the Delhi High Court. According to the writ petition filed by the agency, the raids were carried out without notice, relevance checks, or mandatory video recording, violating due process and statutory safeguards.
The advertising agency has accused the CCI’s Director General (DG) of conducting the March 18–19, 2025 raid in “complete violation of due process,” alleging indiscriminate seizure of data and documents, lack of transparency, and non-compliance with statutory safeguards.
The raid was conducted under a search and seizure warrant issued by the Chief Metropolitan Magistrate, Patiala House Courts, on February 14, 2025, as part of a broader investigation into alleged cartelization in India’s advertising industry. Madison claims it was not named in the original prima facie order issued by the CCI on August 9, 2024, making the raid its first awareness of any probe involving the company.
According to Madison’s petition, the search began on March 18, 2025, around 11 a.m., when DG officials, accompanied by armed police personnel, entered the company’s Mumbai office unannounced. No prior notice or intimation had been served. Employees were reportedly taken by surprise as investigators sealed off access points and commenced a floor-to-floor search of the premises.
Senior management and employees were instructed to surrender their devices, including laptops, mobile phones, iPads, and external drives, as DG officers began cloning hard drives and accessing email servers. The company has claimed that the search team operated without providing adequate clarity about the scope of the operation.
The search continued through the day and night, stretching nearly 20 hours, and concluded only at 7 a.m. the next morning. Madison alleges that throughout this period, company officials were not given any meaningful opportunity to understand or contest the basis of the operation.
“All electronic and physical records were seized without any relevance check,” the petition states. Investigators allegedly copied or cloned the entirety of devices belonging to employees and senior executives — including personal folders and sensitive information unrelated to company operations. Among the personal materials seized were medical records, which Madison says were taken without the owners’ consent or any legal undertakings.
At the end of the operation, the DG team prepared a Panchnama (search memo) — a mandatory legal document meant to list all items seized and the locations from which they were taken. Madison contends that this Panchnama was “incomplete and legally deficient.” It allegedly did not list:
The documents, books, or files seized;
The number of pages taken;
The electronic folders copied;
Or any distinction between personal and official data.
This, the company argues, is a violation of Section 103(5) of the Bharatiya Nagarik Suraksha Sanhita (BNSS), which mandates detailed documentation of seized articles. Madison’s petition also cites the Supreme Court’s judgment in Rajesh v. State of MP (2023), which stressed that a Panchnama must clearly describe every item seized to ensure accountability.
No Video Recording, No Notice
Madison has also alleged that the entire search and seizure operation was not recorded through audio-visual means, in contravention of Section 105 of the BNSS, which mandates video recording to maintain transparency. This safeguard was introduced to prevent arbitrary searches and preserve evidence of the procedure followed by investigators.
Furthermore, Madison has stated that no notice or opportunity to participate in preliminary inquiries was provided before the raid, violating Sections 41(4) to 41(7) of the Competition Act, which require the DG to establish “reasonable belief” before obtaining a warrant.
In the days following the raid, Madison claims it was not given any clear inventory or access to the seized material, leaving it in the dark about what evidence the DG now holds. The company has called the seizure “indiscriminate, opaque, and unconstitutional,” and has petitioned the Delhi High Court seeking the return or deletion of seized data, setting aside of the Panchnama, and declaration that the search was illegal. It is also seeking the quashing of subsequent summons issued by the DG, describing them as “cryptic and unlawful.”
The operation at Madison’s office is being closely watched across the advertising and legal sectors, as it could set an important precedent on the limits of investigative powers under India’s competition law and the standards of procedural safeguards during dawn raids.
