In 2017 a two-judge Supreme Court Bench upheld the 'relevant turnover' approach to competition penalties, holding that 'turnover' in section 27 of the Competition Act means turnover from the goods affected by the contravention, not a firm's total turnover. A digest of the bid-rigging facts, the proportionality reasoning, the DG's investigative scope, and how the 2023 Amendment has since changed the penalty base.