Oripa in India: how a run is structured, and the questions for your lawyer

An oripa — short for original pack — is a pack a shop builds itself. You take singles from your own inventory, sort them into tiers, seal them, set a price and sell them across a run of a fixed number of packs. In Japan it is ordinary shop practice and a normal way to move a drawer of slow singles.

It is also the part of the card business with the most regulatory exposure, in Japan and now in India. This piece sets out how a run is structured and which questions belong with your own lawyer. It is not legal advice, and where we state a law we name it so you can read it yourself.

How a run is put together

• Fix the pack price first, then work backwards from it.
• Decide a payout share: the total value of the cards going into the run against the total the run will take in. Hold that across the run, and be clear with yourself that holding it across the run means individual packs come in below price.
• Write down the valuation basis before anything else — which price source you are using for each card, and on what date. Retail asking price, your own buy price and a marketplace average give wildly different numbers, and the number you advertise has to be the one you can reconstruct later.
• Build tiers: a small top tier, a middle, and a floor every pack clears.
• Decide the floor deliberately. Practitioners in Japan advising on this point argue for the conservative version, where the objective value of each pack is at least the price paid. That is a design choice that reduces risk, not a legal safe harbour.
• Fix the pack count, disclose it, and decide in advance what happens to the run if it does not sell out, because an unsold run means the odds you published did not materialise and the top cards are still in your hands.
• Keep records good enough to rebuild every number you advertised, and keep them after the run closes.

If you want to talk a structure through, we do this with shops regularly, including the parts where the answer is that a planned run is a bad idea.

What Japan’s experience actually teaches

Two separate legal questions come up there, and most write-ups only mention one.

Advertising. Japan’s Act against Unjustifiable Premiums and Misleading Representations, the Keihyoho, is the law that bites in practice: overstating the chance of a hit, implying a guaranteed high-value pull, or advertising a return rate the run cannot deliver. An amendment that took effect on 1 October 2024 added direct penalties for deliberate misrepresentation. Note also that Japan has no legal requirement to publish tier odds at all, and shop practice varies — which is exactly why the claims a shop chooses to make are where the risk sits.

Gambling. For online oripa, Japanese practitioners look first at the gambling provisions of the Penal Code, articles 185 and 186, rather than at the advertising law. The structure they worry about is one where the buyer risks losing value and the gain is contested between buyer and operator, or between buyers. Operator buy-backs and points redemption make that analysis worse rather than better. Online oripa was also raised in the House of Representatives Special Committee on Consumer Affairs on 4 April 2023, with the Consumer Affairs Agency answering on misleading representations.

The lesson that transfers: the cards are rarely the problem. The claims and the cash-out are.

The Indian position, as of September 2026

Four things a shop here should know, and one of them is new.

Gambling is a state subject. There is no single national definition. The tests that courts have applied turn on whether skill or chance predominates, running from the Chamarbaugwala line of cases through the 1996 Lakshmanan judgment, and the older Public Gambling Act 1867 excludes games of mere skill. What applies to your counter depends on your state.

Lotteries. The Lotteries (Regulation) Act 1998 is addressed to state governments and confines lotteries to state-run ones. The provision that reaches a private operator is the criminal one: keeping an office or place for drawing an unauthorised lottery, now section 297 of the Bharatiya Nyaya Sanhita 2023, which replaced the old Indian Penal Code section when the IPC was repealed on 1 July 2024. If you have seen the old section number quoted in a blog, it is out of date.

Online money games are now banned outright. The Promotion and Regulation of Online Gaming Act 2025 received assent on 22 August 2025, and the commencement notification of 22 April 2026 brought it into force on 1 May 2026. It prohibits offering an online money game, defined as an online game played by paying fees or depositing money or other stakes in the expectation of winning money or other enrichment, irrespective of whether the game is based on skill or chance, with imprisonment of up to three years and a fine of up to one crore rupees attached. The Act does not name loot boxes or mystery packs. Its definition turns on there being an online game, which is why a pack sold across a physical counter reads differently from a pack sold on a website with a reveal animation. If you are considering selling packs online in India, that distinction is the first thing to put in front of a lawyer, not the last.

Consumer law applies regardless. The Consumer Protection Act 2019 and the CCPA cover misleading claims, and the authority has been active on dark patterns in online interfaces — which is the category a badly built reveal flow falls into.

None of the above is advice and we are not lawyers. The conservative design most consistent with all of it: every pack contains goods whose stated value the buyer can check, the buyer knows what they are buying before paying, the pack count and the valuation basis are disclosed, no cash or credit is offered for a pulled card, nothing is described as a prize or a draw, and online sale is treated as a separate question requiring its own advice.

Why a shop does it anyway

Inventory that will not move on its own. Every shop accumulates mid-value singles. In a tiered run they can leave the building at a price you set rather than sitting in a binder — provided you value them at what a customer would actually pay, not at what your spreadsheet says. Valuing dead stock generously is the fastest route to the advertising problem described above.

Footfall at a fixed hour. A run with a published count and an opening time is an event. People arrive together, and they buy sleeves, singles and drinks while they are there.

Opening in your shop rather than at home. Opening is social, and the shop that hosts it owns the community and the next sale.

Before you run one

• Take state-specific legal advice before the first pack is sealed, and separate advice if you intend to sell online.
• Write the run down in full before you build it, valuation basis included, and keep it.
• Publish the pack count and the top-tier cards so the run is verifiable from outside.
• Do not offer cash, credit or a buy-back price for a card pulled from your own pack. An ordinary buy counter for singles a customer brings in is a separate business and is not what this means.
• Set an age policy and understand why: section 11 of the Indian Contract Act defines who is competent to contract, and Indian case law has long held that an agreement with a minor is void, so a sale you cannot enforce is a sale you should not make.
• Decide the unsold-run rule in advance and state it.
• Sort out invoicing and the GST treatment of a mixed-content pack with your accountant before the first sale, not after.

What we do, and what we do not

We build and sell original packs, and we supply Japanese singles and sealed product that Indian shops build their own runs from. We will talk through a run structure with you, and we have an interest in this category being run well, since a badly built pack damages all of us. Treat our views as those of a supplier who also sells packs, not as independent advice.

What sits on our side is the import: customs, FSSAI where food is involved, Indian labelling on what we import, an Indian invoice in rupees and an Indian contract. What sits on yours is how you sell to your customers — the gambling and consumer-law compliance of your own run, in your own state. We are not able to take that on for you and you should be sceptical of any supplier who says they can.

Tell us what your counter sells and we will put a supply line and, if you want it, a run structure in front of you. For stocking sealed product, see Japanese-language TCG in India, and for figures and small goods, sorting the anime goods shelf by licence tier.

Laws named here were checked in September 2026: the Keihyoho and its amendment effective 1 October 2024, the Bharatiya Nyaya Sanhita 2023, the Lotteries (Regulation) Act 1998, the Promotion and Regulation of Online Gaming Act 2025 with rules effective 1 May 2026, the Consumer Protection Act 2019 and the Indian Contract Act 1872. Read them, or have someone read them for you, before you act.