CHAPTER 1

INTRODUCTION

1.1 Background

The automobile sector of India is one of the most significant industries. The history of it
seems to start from the bullock cart when the people used to take the help of animals for
conveyance purposes. This method was not very long lasting and also gave rise to the matter
of animal atrocities in later times when animal rights were also being considered. The whole
automobile industry was set up when the burden was shifted from animals to motor vehicles.
The people nowadays have become totally dependent on petrol and diesel automobiles. This
situation may get reformed in future but the reality of the time is that people get dependent
only on machines for conveyance purposes.

Consumers are the community which is affected by any trade or competition issue and the
relationship between trade and competition is very intrinsic which is not created in a vacuum.
As per the estimate, India overtook Japan as the third-largest market for new automobiles in
2022.1 Automobile market will contribute around 7.1 % share in India’s GDP and 35mn
employment is generated through it.2 It will soon share 40% in global R&D and 4.7% share
in India’s exports.3 With the increasing competition in the automotive market, competition
issues are also prevalent in this industry. Shamsher Katria Case, Maruti Suzuki case, etc. are
the live examples of deep rooted nexus of competition issues and their effect on consumers.

The competition issues in the automobile industry have a stronghold as the players in the
market are giant players and further numerous cases have been reported of product liability
which are ultimately affecting the consumers. The section 3 of the Competition Act, 2002
deals with the anticompetitive agreements which create adverse effects on the competition
in the market and section 4 refers to the abuse of dominant position which curb the big
players in the market to use their position to exploit the market as well as consumers.
Consumers are the main sufferers in both ways whether it is competition issues or product
1
India tops Japan to become world’s 3rd largest auto market, Fortune India, Jan 9, 2023, available at:
https://www.fortuneindia.com/macro/india-tops-japan-to-become-worlds-3rd-largest-auto-market/111086 (last
visited on January 10, 2023).
2
The $222 Bn Automobile industry is expected to reach $300 Bn by 2026, Invest India, available at:
https://www.investindia.gov.in/sector/automobile (last visited on January 5, 2022).
3
Ibid.
1
liability issues. Presently there is no solution available where competition laws and
consumer protection laws can work together in a harmonious way.

The most important and contributing factors to the Indian automotive market and its growth
were the opening up of the Indian market after the economic reform in 1991 and the grant of
permission for the hundred percent FDI in the automobile sector of India. Up to 1991 there
were very few brands which were producing automobiles in India. However, after the
reforms there was a constant boom under the catalytic conditions of liberalisation. Since the
policy of privatisation and liberalisation, several Indian manufacturers in this field have also
expanded their domestic as well as international operations. Further development occurred in
the market due to the India-specific investment via creation of subsidiaries or Joint ventures.
This helped a lot in boosting the automotive industry.

At the present time, the Indian auto market is worth $44 billion. As part of its international
trade strategy, the Indian government has taken steps to encourage Indian businesses to ship
car parts to Brazil, South Africa, Russia, Iran, and China. Using the market connected focus
product strategy, they are now exporting around twenty-three different vehicle components.
The Automotive Component Manufacturers Association of India (ACMA) predicts that by
2020, the Indian automotive sector would have generated a revenue of US $100 billion, with
exports contributing between US$80 and US$100 billion by 2026.4

The car industry has moved its headquarters to India. The first is located in the vicinity of the
Indian cities of Mumbai and Pune, and it is a major hub for the western car sector. Where
massive amounts of manufacturing are performed. Companies including General Motors,
Volkswagen, Skoda, Mahindra & Mahindra, Tata Motors, Mercedes-Benz, Land Rover,
Jaguar Cars, Fiat, and Force Motors all have assembly factories in the Chakan corridor close
to Pune, Maharashtra. In addition to GM's Halol factory and the proposed Tata Nano plant in
Sanand, Gujarat is quickly becoming a major global player in the car industry.

4
Growth and Sustainability through technology and teamwork, 39th Annual Report 2019-20, Automotive Excels
Limited, available at: https://bsmedia.business-
standard.com/_media/bs/data/announcements/bse/23072020/832f30b3-c5aa-41a3-9601-286f94de927b.pdf (last
visited on January 11, 2022).
2
The competition issues in the automobile industry first came into the light when on August
25th, 2014 in the landmark decision of the Shamsher Kataria,5 A hefty penalty of 2544
crore rupees was imposed on 14 car manufacturing companies by the Competition
Commission of India (CCI). The main issue here was the restriction of sale and supply of
auto spare parts in the open market which seemed to be a clear violation of section 3(4) and
section 4 of the Competition Act, 2002. The name of the companies which were penalised by
the Competition Commission of India are Ford India, Hindustan Motors, Mahindra &
Mahindra, Maruti Suzuki, Mercedes-Benz India, Nissan Motor India, General Motors India,
Skoda Auto India, Tata Motors, Toyota, Honda India, BMW India, Volkswagen India and
Fiat India. Other three companies Hyundai India, Mahindra Reva and Premier were also
under the garb of it.

Another worth highlighting case is the Maruti Suzuki India Ltd Case6 where the
Competition Commission of India in an order dated August 23, 2021 imposed a penalty of
INR 2 billion on Maruti Suzuki India Limited. The issue was restriction and controlling the
benefits to the consumer which must be reached to them through retailers in the form of
discount. The act was considered as anticompetitive and against the competition in the
market. The act was categorised in the basket of resale price maintenance which is a serious
violation of the Competition Act, 2002.

With the growth and competition, competitive issues are also arising on different levels.
Shamsher Kataria case questioned the competitiveness of the Indian Automotive Industry.
One of the recent cases is the Maruti Case related to cartelization and resale price
maintenance is also highlighting the increasing competition issues in the automobile industry.
The ultimate effect on the consumers through the competition issues and product liability
gives a thought and scope of further research to make concrete solutions for the problem.
Here in the research the assessment of the automobile industry in India is done in the light of
competition laws of India and ultimate effect on consumers.

5
CCI, Case No. 03 of 2011, Dated: October 25, 2014, available at:
https://www.cci.gov.in/antitrust/orders/details/750/0 (last visited on August 5, 2022).
6
CCI, Case No. 01 of 2019, Dated: July 4, 2019, available at:
https://www.cci.gov.in/images/antitrustorder/en/0120191652430186.pdf (last visited on 5 August 2022).
3
1.2 Review of Literature

“Global Players and the Indian Car Industry'' a book authored by Jatinder Singh (2019)7
is a forerunner in presenting the first critical and crucial analysis of the industry of
automobiles in India. It provides an overview of the industry and in depth analysis of the
passenger car industry. It further studies the working of FDI based companies in a
continuously emerging sector of technology under the different economic regimes.

Johannes Van Biesebroeck and Timothy J. Sturgeonpaper (2010) in their work “Effects of
the crisis on the automotive industry in developing countries: a global value chain
perspective”8 analysed the global value chain to understand and to present a clear picture of
recent trends in the global industry of automobiles. The authors have paid more attention to
study the impacts of the immediate economic crisis on the developing countries Industries.
There has been a rapid growth in car production and variation in models due to close co-
location of resources and tech. As the market size is increasing and as well as the
manufacturing base the different strategies adopted by countries like Mexico, China and India
are converging.

The work of Smita Miglani (2019) in his book titled “The Growth of the Indian
Automobile Industry: Analysis of the Roles of Government Policy and Other Enabling
Factors”9 A contrasting feature of the Indian automobile industry which sets it apart from
other automobile producing countries is its ability to provide and cater for the needs of low
income and middle income groups of masses. As a result of governmental policies,
infrastructure , policies placed India at the 4th rank of automobile market in 2017 and demand
for Indian manufactured vehicles and components has witnessed an increase in domestic as
well as international market.

7
J. Singh, Global Players and the Indian Car Industry: Trade, Technology and Structural Change (Taylor &
Francis, 2018).
8
J. Van Biesebroeck, & T. J. Sturgeon, Effects of the crisis on the automotive industry in developing countries:
a global value chain perspective (The World Bank, 2010).
9
S. Miglani, The Growth of the Indian Automobile Industry: Analysis of the Roles of Government Policy and
Other Enabling Factors. In Innovation, Economic Development, and Intellectual Property in India and China
439-463 (Springer, Singapore 2019).
4
Satyaki Roy in his chapter titled "Automobile Industry in India: Emerging Conflicts
between Scale and Scope"10 Although policy has been a major factor in propelling the
Indian car sector forward, domestic demand may become a limiting factor if things keep
trending in their present direction.

Brajesh Chhibber and Rajat Dhawan (2019) in his research work “6 ways to reignite India’s
auto industry”11 put forth that the automobile industry has the capability to give birth to the
next rise in its way and for that they discuss the embracement of six points of action to
achieve the upward slope in the trajectory of the industrial ecosystem.

Chandni Chawla, Kripi Kathuria, Manjula Chawla and Ritika Ganju (2020) in their article
titled “At a glance: automotive industry disputes in India”12, Allegations of anti-
competitive behaviour within the automotive industry are regularly investigated by the
Competition Commission of India (CCI), the institution regulating competition in India. The
CCI either opens investigations on its own initiative (suo-moto) with the help of outside
parties (premised on news reports and statistics from similar cases) or opens investigations at
the request of outside parties (based on evidence provided to it). Shamsher Kataria v.
Honda Siel Cars India Ltd & Ors13, is the most famous competition case involving the
automotive industry. In this case, the CCI looked into claims that car manufacturers were
restricting the ability of independent service and repair providers to sell their own brand-
name spare parts and diagnostic tools.

M M Sharma in his research work titled “Auto Dealers -Be Aware of emerging
competition issues in your industry -An eyeopener”14, The Indian car industry is the
world's fourth largest. Car dealerships play a significant role in the industry as the first point
of contact between manufacturers and buyers. They also play a crucial role in the aftermarket

10
S. Roy, Automobile Industry in India: Emerging Conflicts between Scale and Scope. Industrial Development
in China and India: Comparison of the Clusters and Firms (eds.) Moriki Ohara and Koichiro Kimura, Institute
of Developing Economies (IDE-JETRO), Japan (2010).
11
Chhibber, B. and Dhawan, R., 6 ways to reignite India’s auto industry (2019), Live Mint, April 21, 2021
available at: https://www.livemint.com/industry/manufacturing/6-ways-to-reignite-india-s-auto-industry-
11571157981126.html
12
C. Chawala, K. Kathuria, M. Chawala and R. Ganju, At a glance: automotive industry disputes in India,
LEXOLOGY April 21, 2021, available at: https://www.lexology.com/library/detail.aspx?g=3513facc-9d40-
4815-bbd1-b1485feca8a3 (last visited on August 2, 2022).
13
Case No. 03 of 2011 (Competition Commission of India, 25 October 2014).
14
M. Sharma, Antitrust and Competition Law Blog, Auto Dealers -Be Aware of emerging competition issues in
your industry -An eye opener, April 21, 2021 available at: https://www.competitionlawyer.in/auto-dealers-be-
aware-of-emerging-competition-issues-in-your-industry-an-eye-opener/ (last visited on August 2, 2022).
5
by supplying services like vehicle maintenance and repair, as well as providing additional
products and services like vehicle insurance and financing. Yet, OEMs regularly engage in
unfair business tactics with dealerships ("OEM"). They also serve an important function in
the aftermarket by delivering replacement parts, ensuring the safety and upkeep of vehicles,
and offering a host of supplementary services, including insurance and financing.

Satyaki Roy in his research work titled “Automobile industry in India has grown faster in
the post-liberalisation period”15. The increasing purchasing power of the middle class in
recent years has contributed significantly to this trend, as has the need for unique
automobiles. Indian producers, both assemblers and component makers, are progressively
drawn into the global value chain as a result of the reforms, which might lead to the entry of
foreign direct investment in this sector as well as equity involvement by international
enterprises.

Ghanashyam in his article titled “Automotive Industry and Relevant Laws”16, India's car
sector is the world's fastest-growing market. The automobile industry in India is expanding at
a rate of 9.5% each year, making it the fourth biggest in the world in terms of production,
marketing, and sales. Most of the world's automotive giants are already active in the Indian
market and contributing to its expansion, making the automobile industry one of the most
dynamic sectors of the country's economy.

Shu Wei Wong in his research work titled “Competition Landscape in India's Automotive
and Auto Parts Sector”17, One of India's most prolific and rapidly expanding industrial
sectors is the car industry. Positioned as the eleventh biggest passenger vehicle manufacturer
worldwide. India takes the top spot for motorbikes and the second spot for scooters. India,
while adopting policies of liberalisation to open its market for all players, has attracted more
than 2 dozen automobile manufacturers to set up plants and shops in the country.

15
S. Roy, Automobile Industry in India: Emerging Conflicts between Scale and Scope. Industrial Development
in China and India: Comparison of the Clusters and Firms (eds.) Moriki Ohara and Koichiro Kimura, Institute
of Developing Economies (IDE-JETRO), Japan, (2010).
16
Vakil Ghanasyam, Automotive Industry And Relevant Laws, April 21, 2021, available at: from
https://vakilsearch.com/advice/automotive-industry-and-relevant-laws/ (last visited on August 2, 2022).
17
Wong, S.W., Street Directory.com, Competition Landscape in India’s Automotive and Auto Parts Sector,
May 19, 2021 available at:
https://www.streetdirectory.com/travel_guide/50549/car_parts/competition_landscape_in_indias_automotive_an
d_auto_parts_sector.html (last visited on August 2, 2022).
6
Ratnesh Sharma in his research work titled “Recent Competition law developments in
Automobile Industry in India”18, The Organization Internationale des Constructeurs
d'Automobiles (OICA) ranks India's automotive industry as the sixth largest in the world, and
it contributes 22 percent of the country's manufacturing GDP (Gross Domestic Product). This
is due in large part to the country's growing middle class and its increased demand for
passenger cars and commercial vehicles. The de-licensing and liberalisation reforms of 1991
ushered in sweeping developments including expanded production capacity, cutting-edge
technology, and fiercer market competition.

Haritha Saranga in her research work titled “Competitiveness of the Indian Auto
Component Industry: An Empirical Study”19, once China's manufacturing sector rose to
prominence, India became an attractive alternative. India has a distinct competitive edge over
other Asian nations in the manufacturing sector, and this sector is expected to be where the
next wave of offshoring takes place. Altering population structures in both the developed and
developing worlds work in India's advantage. New contracts and increased sales can be won
temporarily through technology licensing, but becoming too dependent on this strategy can
be disastrous in the long run. Instead, businesses must invest in internal R&D, strive to
internalise technological knowledge, and develop new technologies from the ground up in
order to thrive in today's increasingly globalised economy.

L. G. Burange and Shruti YaminiIn their research work titled “Competitiveness of Firms in
Indian Automobile Industry”20, While India's economy was opened in the 1990s, the signs
of growth in the automobile sector have just been apparent in the past five years. It's due to a
number of factors, including rising competition in the market as a result of global companies
setting up shop in India through joint ventures, collaborations with domestic firms, or wholly
owned subsidiaries, and shifting economic conditions, especially in the financial sector and in
foreign direct investment. The study of the elements that guide competitive advantage has
shown the competitive character of Indian enterprises and their competition.

18
R. Sharma, Indian National Bar Association, Recent Competition law developments in the Automobile
Industry in India, May 20, 2021 available at: https://www.indianbarassociation.org/recent-competition-law-
developments-in-automobile-industry-in-india/ (last visited on August 2, 2022).
19
H. Saranga, Competitiveness of the Indian auto component industry: An empirical study. Bangalore: IIM
Publication (2011).
20
L. G. Burange, & S. Yamini, Competitiveness of firms in the Indian automobile industry. In International
Conference on Transportation System Studies, Department of Economics, University of Mumbai, Mumbai
(2008).
7
Mr. Mangesh D. Jadhao and Dr. Arun P. KedarIn their research work titled “Service Quality
Challenges in an Indian Automobile Service Industries”21, In the last ten years,
computation in the industry has caused rapid changes in the market landscape. Customers
drive innovation in both product design and technological advancement. There are a lot of
companies whose primary responsibility is to provide high-quality services. Increased client
expectations of recognisable brands have created a challenging environment for the vehicle
servicing industry. This research provides an overview of the difficulties encountered by the
Indian vehicle service industry, and it identifies the gaps that will have an impact on service
quality and the factors that influence it. The report wraps up by discussing the voids in the
four-wheeler service industry's existing position and market share in the car service industry.

Vikas Varma in his research paper titled “Automobile Industry on Challenges Business
Strategy Revolution, Trends & Unsolved Problems”22, There are new, urgent problems
that must be solved in the car sector. The industry as we know it is being upended by
globalisation, individualization, digitization, and intensifying competition. Future shifts will
be influenced by a number of factors, including mandatory safety regulations and voluntary
environmental pledges made by the car sector. Nowadays, little businesses have just as good
a shot at success as big ones. Businesses that can think of new methods to create value will be
the ones who succeed in the future. This article will provide a high-level summary of the
current car industry and will focus on some of the problems facing this industry.

Avinandan Mukherjee in his research paper titled “The Indian Automobile Industry :
Speeding into The Future?23”, For the last three years, the market has averaged a growth
rate of over 25%. Lower pricing, thanks to reduced customs and taxes and gradual
indigenization, and higher earnings among the middle class are expected to fuel the industry's
continued expansion in the highly price sensitive market. Very low penetration in rural and
semi-urban regions, which might open up new consumer bases. The market is already
saturated, there is a lot of rivalry, and there are capacity limitations throughout the sector, all
of which pose challenges for new entrants.

21
M. M. D. Jadhao, & A. P. Kedar, Service Quality Challenges in an Indian Automobile Service Industries.
22
V. Varma, INTERNATIONAL JOURNAL FOR INNOVATIVE RESEARCH IN MULTIDISCIPLINARY
FIELD, Automobile Industry on Challenges Business Strategy Revolution, Trends & Unsolved Problems, June
7, 2021 available at: https://www.ijirmf.com/wp-content/uploads/201709023.pdf (last visited on August 2,
2022).
23
A. Mujherjee, GERPISA, THE INDIAN AUTOMOBILE INDUSTRY : SPEEDING INTO THE FUTURE ?,
June 7, 2021 available at: http://gerpisa.org/ancien-gerpisa/actes/28/28-4.pdf (last visited on August 2, 2022).
8
In the research work of DR. U. M. Premalatha titled “Global Business Opportunity and
Challenges for Automotive Industries in India”24, An important growth area for India is
the car component industry. Demand from the world's major automakers has propelled the
SME sector into a period of unprecedented growth. Studying the trends, commercial
prospects, and constraints for development in the automotive sector in India is the focus of
this research. This will allow for a more accurate revision of the history of the automotive
industry in India. The small and medium-sized enterprises (SMEs) producing car components
will need to adopt cost competitiveness, customer orientation, and lead time if they are to
thrive in the new global setting.

Shri Shamsher Kataria versus Honda Siel Cars India Ltd. & Ors25, was the most
important case relating to competitive issues in the automobile sector, there were 14
automakers found to have violated the Competition Act, 2002 by the Competition
Commission of India (the "Commission"). After conducting an exhaustive investigation, the
Commission came to the conclusion that the Car Companies had violated section 3(4) of the
Act by imposing absolute restrictive covenants in their agreements with local Original
Equipment Suppliers (OESs) and authorised dealers, which had the effect of closing down the
aftermarket for the supply of spare parts and other items. To add insult to injury, the
Commission additionally levied a penalty of Rs. 2544.64 crores, or 2% of the average
revenue of the 14 vehicle firms. Within 60 days after receiving the order, the fine must be
paid in full.

Consequently, there are studies and reports accessible that demonstrate the development of
the vehicle industry in India. One of India's rapidly developing sectors is the car industry.
Concerns about a lack of competition were raised by the Competition Commission of India in
the Shamsher Kataria case26. One of the important issues raised was the creation of market
constraints for the automobile parts. Giant companies were exploiting the market and not
giving access and availability to the small players in the market. It was clear anticompetitive
practice in the chain of vertical supply arrangements. With the growth of any industry there
are a number of anticompetitive issues in the market. This research studies the competition
24
U.M. Premalatha, GALAXY International Interdisciplinary Research Journal, GLOBAL BUSINESS
OPPORTUNITIES AND CHALLENGES FOR AUTOMOTIVE INDUSTRIES IN INDIA, June 8, 2021 available
at: http://internationaljournals.co.in/pdf/GIIRJ/2014/March/20.pdf (last visited on August 2, 2022).
25
CCI, Case No. 03 of 2011, Dated: October 25, 2014, available at:
https://www.cci.gov.in/antitrust/orders/details/750/0 (last visited on September 5, 2022).
26
Ibid.
9
issues in the automobile industry and explores possible available competition issues with
every market dynamics of past, present and future. The research has great scope and potential
as there is no concrete research on the issue.

1.3 Statement of the Problem

India's automobile industry is thriving. People's requirements continue to grow, resulting in

an increased reliance on automobiles. Dependence has a direct effect on industry demand. At
some locations, demand is genuine, while at others, demand is fabricated. It is a combination
of the two in the automobile business. The company is involved in all aspects of automobile
maintenance, from purchasing to servicing. Due to the impossibility of servicing all
automobiles, consumers typically take their vehicles to local service centres to save time and
money. Automobile manufacturers do not wish to outsource vehicle servicing to independent
service shops. Automotive businesses attempt to restrict market access to local service
centres for automobile spare parts in order to develop an attractive and compelling business.
The issue begins at this point, and examination begins with the identification of relevant
geographical and product markets. Spare parts markets with 100 percent domination exist
because substituting one company's spare part for another is not conceivable. The possibility
of power abuse is prominent here. Abuse of dominance evolves into an anti-competitive
agreement that is utilised to monopolise the market. CCI has also adjudicated a few
complaints and discovered anti competitive behaviour. The research is a competition law
analysis of the Indian automobile industry. The analysis will look at the automobile sector's
industrial characteristics. The review will look into the industry's competition concerns and
make recommendations for corrective action.

1.4 Research Methodology

The methodology suggested for the study will be majorly doctrinal in character including
empirical study to support findings. The research will be based on an analysis of existing data
and an in-depth examination of both current and potential future consequences. Primary
sources such as statutes, court rulings, and other laws would be consulted. Secondary sources
include books, internet materials, newspaper articles, research papers, various reports, and
periodicals. The method for defining and explaining the outcomes would be entirely factually
accurate and based on available data. Due to the mixed doctrinal and empirical nature of the

10
study, all qualitative and quantitative data will be analysed in light of existing doctrine,
hypotheses, and judgments. Quantitative data shall also be analysed, if necessary, using
accessible authorised software. The conclusions shall be consistent with the analysed data,
and all corrective steps and recommendations will be rigorously examined.

1.5 Research Objectives

1. To study the existing Competition laws in India and its impact on the Automobile
Industry.

2. To identify the competition issues in the automobile industry prevalent in India and
study its impact on the consumers.

3. To identify issues in the automobile industry related to product liability under the
Consumer Protection Act, 2019.

1.6 Research Hypothesis

1. The Indian automobile industry is rapidly expanding, resulting in increased competition

issues amidst dynamic challenges.

2. India's automotive industry's competition issues directly affect consumers and create issues
related to product liability.

1.7 Research Questions

1. What are the current competition challenges in the Automotive Industry of India and
how does the Competition Commission of India respond to the competition issues?

2. What is the impact of competition issues of the automobile industry on the consumers
and how does it affect the related product liability?

3. What remedial actions could the automobile sector take to avoid anti-competitive
behaviour and maintain market competition?

11
1.8 Chapterisation
Chapter 1: Introduction

Introduction makes a foundation of the research where all the important components like

statement of problem, brief literature review, research questions, research objectives,

hypothesis are incorporated. This chapter introduces the background of the automobile

industry and the projection of the research ahead.

Chapter 2: Trade & Competition: Conceptual Contours

Second chapter details the historical background of the automobile industry and its growth in

India. Connection between trade and competition has been highlighted under this chapter.

Stages of development of automobile industry in India from ancient time to present time has

been explained.

Chapter 3: Trade & Competition in India: Legislative & Regulatory Framework

In this chapter the legislative and regulatory framework will be analysed. The research is

related to the competition issues in the automobile industry in India so the analysis of

competition laws is an inevitable part of the research.

Chapter 4: Indian Automobile Industry & Competition: Issues & Challenges

The chapter assesses the market and identifies the issues & challenges of the Indian

Automobile Industry. In this chapter probable solutions to the issues will also be provided.

The chapter evaluates every competition issue of the automobile industry and how the

Competition Commission of India dealt with all the issues.

12
 Chapter 5: Indian Automobile Industry & Competition: Impact on the consumers

Chapter five deals with the situations where competition issues of the automobile industry

creates impact upon the consumer. Ascertainment of product liability in case of default will

be explained in the chapter. The analysis of available laws and its implementation on present

competition issues will be assessed in the chapter. This chapter will also include the empirical

study which has been completed through the analysis based on collected data by

questionnaire with more than 300 responses.

Chapter 6: Conclusion and Recommendations

Lastly the chapter concluded all previous chapters with final conclusion on every aspect of

research conducted. Further conclusion will map the objectives and hypothesis of the

research with the final outcomes. Moreover the recommendation evolved out of the study will

also be provided to concrete it with a final solution.

13
14