Confirm-Shamed and Consent Trapped: Rethinking India’s Regulatory Response to Algorithmic Dark Patterns in E-Commerce

India’s Central Consumer Protection Authority (‘CCPA’) has, since 2023, moved from soft admonition to active enforcement against ‘dark patterns’ interface designs engineered to manipulate consumer decision-making. Penalty orders in 2025 and 2026 against Zepto, Physics Wallah and McAfee Software India mark the first sustained sanctions under the Guidelines for Prevention and Regulation of Dark Patterns, 2023. This paper asks whether India’s existing architecture, the Consumer Protection Act 2019, the 2023 Guidelines, the Consumer Protection (E-Commerce) Rules 2020, and the Digital Personal Data Protection Act 2023 can address dark patterns that are algorithmically generated, personalised and adaptive, rather than static. It argues that the framework, though newly energetic in enforcement, remains reactive and calibrated to isolated instances of misleading advertisement or unfair trade practice, rather than to the data-driven architecture that produces such instances at scale. Comparing this with Article 25 of the European Union’s Digital Services Act, under which the European Commission fined X Corp €120 million in December 2025 for deceptive design, and the United States Federal Trade Commission’s USD 2.5 billion settlement with Amazon over Prime enrolment and cancellation design, the paper contends that India lacks an ex-ante, statute-backed design-fairness obligation and a mechanism connecting its consumer-protection, data-protection and competition regulators. It proposes elevating core dark-pattern prohibitions from guideline to statutory rule, mandating periodic algorithmic design audits for high-traffic platforms, linking penalties to platform revenue, and establishing an information-sharing protocol between the CCPA, the Data Protection Board of India and the Competition Commission of India. The thesis is not that India has failed to act, but that it has acted at the wrong layer, addressing symptoms of manipulation one order at a time, while leaving the design systems that generate them substantially unregulated.