Introduction In 2023, the Competition Commission of India (‘CCI’ or ‘the Commission’) found itself in an unprecedented situation . With only an Acting Chairperson and a Member, the Commission faced a backlog of pending merger approvals. This led to the invocation of the doctrine of necessity  in order to examine and approve combination agreements, i.e, mergers and acquisitions. Normally, an M&A approval, being an administrative function, requires a quorum of three members, a