Rajadhiraja Limited

COMPETITION COMMISSION OF INDIA

Combination Registration No. C-2025/09/1333

7^th November 2025

Notice under Section 6(2) of the Competition Act, 2002 given by Rajadhiraja Limited

CORAM:

Ms. Ravneet Kaur
Chairperson

Ms. Sweta Kakkad
Member

Mr. Deepak Anurag
Member

Order under Section 31(1) of the Competition Act, 2002

1. On 25^th September 2025, the Competition Commission of India (Commission) received a Notice under Section 6(2) of the Competition Act, 2002 (Act) given by Rajadhiraja Limited (Acquirer) in relation to acquisition of shareholding in La Renon Healthcare Private Limited (LRHPL/Target) [hereinafter, the Acquirer and the Target are collectively referred to as the ‘Parties’].

2. The Notice was filed pursuant to the execution of: (i) the share purchase agreement executed amongst the Acquirer, the Target and Mr. Pankaj Kumar Singh (Promoter) (Promoter SPA); (ii) the securities purchase agreement entered into by and between the Acquirer and Peak XV Partners Investments IV (Investor SPA); and (iii) the amended and restated shareholders’ agreement executed amongst, inter alia, the Acquirer, the Target, and the Promoter (SHA), each dated 9^th September 2025.

3. The Proposed Combination envisages the acquisition of 7% of the fully diluted share capital of the Target by the Acquirer. Pursuant to the Promoter SPA and the Investor SPA, the Acquirer has agreed to purchase shares representing 5% and 2% of the fully diluted share capital of the Target respectively. As per the SHA, the Acquirer shall have, inter alia, the right to nominate a director on the board of directors of the Target, and certain affirmative voting rights.

4. In terms of Regulation 14 of the Competition Commission of India (Combinations) Regulations, 2024 (Combinations Regulations), vide letter dated 9^th October 2025 certain information and clarifications were sought from the Acquirer (RFI). The Acquirer submitted the response to RFI on 13^th October 2025 (Response) and followed the Response by certain additional voluntary submissions on 21^st October 2025.

5. The Acquirer is a special purpose vehicle held solely by Creador VI L.P. (Creador VI). Creador VI is a closed-end fund which, directly and indirectly, makes privately negotiated equity and equity-related investments. Creador VI is a part of the larger Creador Funds and each of the funds that form a part of the Creador Funds is managed by its respective general partner and these general partners are ultimately indirectly held by an individual, Mr. Brahmal Vasudevan. As submitted, the Creador Funds have invested in a variety of companies in India, in sectors such as insurance, laboratory devices, healthcare, NBFC lending, information technology, quick service restaurants, and retail etc.

6. LRHPL, including through its subsidiaries, is involved in the pharmaceutical sector and more particularly undertakes the following business activities: (i) manufacturing of: (a) pharmaceutical drugs (including injectables); (b) nutraceuticals and dietary supplements; and (c) active pharmaceutical ingredients; (ii) distribution and marketing of: (a) pharmaceutical drugs; (b) nutraceuticals and dietary supplements; and (iii) API and formulation development services for both regulated and semi-regulated markets etc.

7. For the purpose of competition assessment, the Commission considered the activities of Creador Funds (including their portfolio investments in India) on one hand and LRHPL and its subsidiaries and affiliates on the other. Based on the information contained in the Notice, it was observed that there are no horizontal overlaps in the activities of Creador Funds and the Target in India. However, there are certain Creador Funds entities which have presence in the broader healthcare sector viz., (i) healthcare services through hospitals (Paras Healthcare Limited), (ii) manufacturing and sale of pharmaceutical packaging products (Shriji Polymers (India) Limited), (iii) laboratory devices (Accumax Lab Devices Private Limited) and (iv) insurance broking (Edme Services Private Limited).

8. The Commission observed that some of the linkages arising from the aforesaid presence of Creador Funds in India (viz., linkages between laboratory devices and insurance broking activities of Creador Funds and pharmaceutical manufacturing and related activities of LRHPL) are weak to even constitute a vertical/complementary linkage and by their nature itself are not likely to raise concerns of appreciable adverse effect on competition (AAEC) in any plausible market that could be delineated for the purpose of competition assessment. As regards the linkages between healthcare and pharmaceutical packaging activities of Creador Funds and the activities of manufacturing and sale of pharmaceutical and related products of LRHPL, the Commission observed that the presence of entities of Creador Funds and LRHPL in their respective market segments is insignificant to cause any change in, or confer, any ability/incentive to the Parties to engage in foreclosure strategies in any market in India that could have been delineated for the purpose of assessment of the Proposed Combination.

9. Considering the material on record, including the details provided in the Notice and the assessment of the Proposed Combination based on the factors stated in Section 20(4) of the Act, the Commission is of the opinion that the Proposed Combination is not likely to have AAEC in India. Therefore, the Commission approves the Proposed Combination under Section 31(1) of the Act.

10. The order may be revoked if, at any time, the information provided by the Acquirer is found to be incorrect.

11. The information provided by the Acquirer shall be treated as confidential in terms of and subject to provisions of Section 57 of the Act.

12. The Secretary is directed to communicate to the Acquirer accordingly.