CCI Orders Probe Into Mrs India Inc Over Restrictive Conditions Imposed On Pageant Participants

The Competition Commission of India (CCI) on Tuesday ordered a Director General investigation into Mrs. India Inc.

The Commission prima facie found that certain conditions imposed on participants and winners of its beauty pageants appeared to prevent them from entering other beauty pageants for five years, undertaking professional engagements without approval, and requiring them to associate only with social causes recognised by the organiser.

A coram of Chairperson Ravneet Kaur and Members Anil Agrawal, Sweta Kakkad and Deepak Anurag passed the order on an information filed by Rinima Borah Agarwal.

Agarwal was the first runner-up in the 2024 Mrs. India pageant and was awarded the title of "Mrs. India Galaxy".

“In light of the above analysis, the Commission is of the opinion that a prima facie case of contravention of the provisions of Sections 3(4)(a), 3(4)(b), 4(2)(a)(i), 4(2)(b)(i) and 4(2)(d) of the Act by the OP is made out in the present matter,” the Commission observed.

Agarwal alleged that Mrs. India Inc., a beauty pageant organiser for married women, required participants to pay registration and grooming fees. She stated that she paid ₹6.75 lakh for a premium package. According to the information, details of the available packages were not disclosed at the time of registration.

She alleged that after making the payment, she was required to sign a Non-Disclosure Agreement and Participants' Terms and Conditions. According to her, the agreements contained restrictive conditions.

Agarwal further alleged that after she was declared first runner-up and awarded the title of “Mrs. India Galaxy”, she was required to sign a Winners' Terms and Conditions agreement. She alleged that the agreement imposed additional obligations on winners.

According to the information, the conditions included restrictions on participating in or being associated with other beauty pageants for five years. Winners were also required to obtain approval before accepting professional assignments. The agreements further required association with social causes recognised by the organiser. They also contained clauses permitting the organiser to use participants' photographs and videos for publicity and promotional purposes.

The informant also alleged that the organisation demanded up to ₹25 lakh to enable her participation in the International Mrs. Galaxy pageant. She further alleged that additional payments were sought towards public relations, charity, travel, wardrobe and participation in international competitions.

After terminating her association with the organisation in January 2025, the informant alleged that Mrs. India Inc. continued to use her photographs and videos. She claimed that the organisation relied on contractual clauses permitting such use even after termination.

The Commission rejected the allegation that the organiser and international pageant organisers had formed a cartel or pre-decided winners.

“With respect to the allegation at point (a) above, the Commission notes that the Informant has placed no evidence on record of there being any kind of agreement between the OP and Mrs. Globe organisers wherefrom it can be discerned that the winner of the competition was pre-decided. As such, on the mere statement of the Informant, cognizance of allegation of cartelisation between the OP and an international organiser cannot be mad,” the Commission held.

Examining the contractual arrangements, the Commission observed that some clauses appeared to be in the nature of exclusive dealing and tie-in arrangements.

The Commission defined the relevant market as the “Market for services of beauty pageants for married women in India for sending its winners to major international beauty pageants”.

The Commission observed that Mrs. India Inc. appeared to be a dominant player in that market. It noted that the organisation held exclusive licences to send its winners to represent India at international pageants such as Mrs. Globe, Mrs. Galaxy, Mrs. International Summit and Mrs. International World.

The Commission noted that winners and runners-up up to the 25th position were required to comply with the agreements for five years. During that period, they were prohibited from participating in other pageants as participants, consultants, judges, mentors, founders or co-founders. The Commission also noted that professional engagements required the organiser's approval. Participants were also required to associate with social causes recognised by the organiser.

“Accordingly, the Commission, in terms of the provisions contained in Section 26(1) of the Act, directs the Director General ('DG') to cause an investigation into the matter and submit the investigation report within a period of 90 days from the receipt of this order.” the Commission directed.

The Commission also clarified, "It is made clear that, if during the course of the investigation, the DG comes across anti-competitive conduct of any other entity in addition to those mentioned in the Information, the DG shall be at liberty to investigate the same.”

The Commission clarified that nothing stated in the order should be treated as a final expression of opinion on the merits of the case. It directed the Director General to conduct the investigation without being influenced by the observations made in the order.