ISLAMABAD – The Competition Appellate Tribunal (CAT) has upheld the Competition Commission of Pakistan’s (CCP) order against 20 medical centers and laboratories and their five associations for collusive price-fixing, territorial allocation of customers, and other anti-competitive practices in mandatory pre-departure medical exams for Pakistani workers heading to Gulf countries.
While the Tribunal confirmed the violations, it reduced the penalties significantly—from Rs. 20 million per medical center and Rs. 10 million per GAMCA to Rs. 2 million per center and Rs. 1 million per GAMCA.
The case concerns a captive market of low-income Pakistani laborers securing jobs in Saudi Arabia, Qatar, Oman, Bahrain, and Kuwait. These workers must undergo medical tests at GCC-approved centers before departure.
The CCP’s investigation revealed that GAMCAs in Islamabad/Rawalpindi, Lahore, Peshawar, Karachi, and Multan were allocating customers on a rotational basis, effectively eliminating competition on price and service quality. Workers were bound to specific centers, charged uniform fees, and in some cases forced to pay for unnecessary repeat tests.
The inquiry was initiated following a complaint from the Pakistan Overseas Employment Promoters Association (POEPA). The CCP concluded that fee fixation, territorial division, and customer allocation violated Section 4 of the Competition Act, 2010.
Dr. Kabir Sidhu, CCP Chairman, warned business associations against facilitating collusive practices or business allocation schemes. He emphasized that such platforms should promote sectoral growth, fair competition, and consumer benefit, adding that any anti-competitive conduct will be strictly addressed under competition law.



