CCI orders DG probe into Mrs India Inc over alleged anti-competitive clauses and abuse of dominance.

June 2, 2026 : The Competition Commission of India (CCI) has ordered a detailed investigation against Mrs. India Inc., one of the country’s most prominent beauty pageant organizers for married women, over allegations of anti-competitive conduct, abuse of dominant position, and the imposition of restrictive contractual conditions on participants. The Commission found a prima facie case under multiple provisions of the Competition Act, 2002, and directed the Director General (DG) to conduct an investigation within 90 days.

The case was initiated by Rinima Borah Agarwal, who participated in the 2024 edition of the Mrs. India beauty pageant and was declared the first runner-up with the title of “Mrs. India Galaxy.” According to her complaint, Mrs. India Inc., operated by Mohini Sharma, leveraged its position in the niche market of beauty pageants for married women to impose unfair, one-sided, and restrictive conditions on contestants while demanding substantial financial payments at different stages of participation.

The informant alleged that after paying a registration fee, she was required to purchase a compulsory grooming package costing either ₹3.25 lakh or ₹6.75 lakh. She claimed that the details of these packages were not disclosed during registration and that she was persuaded to choose the premium package with assurances of better prospects in international competitions. The complaint further stated that participants were encouraged to contribute funds to a charitable trust associated with the proprietor of Mrs. India Inc., with incentives linked to advancement in the competition.

The dispute escalated after the competition concluded. Agarwal alleged that she was asked to sign a series of agreements containing stringent conditions that significantly restricted her professional and commercial activities. Among the challenged clauses were provisions barring contestants and winners from participating in, promoting, mentoring, judging, funding, or associating with any other beauty pageant for a period of five years. The agreements also allegedly granted Mrs. India Inc. extensive control over contestants’ endorsements, modelling assignments, acting opportunities, public appearances, and collaborations with third parties. Participants were reportedly prohibited from entering into contracts with any person, business, charity, or organization without prior written approval from the organizer.

The informant further contended that winners were compelled to support only those social causes approved by the organizer and were required to contribute funds toward designated charitable initiatives. She also challenged provisions allowing the organizer to continue using contestants’ photographs and videos for promotional purposes even after termination of their association. According to the complaint, additional demands amounting to as much as ₹25 lakh were made to facilitate participation in international beauty pageants, leaving contestants with little practical choice but to comply.

Agarwal argued that these conditions not only restricted competition within the beauty pageant industry but also infringed her professional freedom. She claimed that the five-year restrictions adversely affected her ability to pursue livelihood opportunities and were inconsistent with the constitutional guarantee under Article 19(1)(g), which protects the right to practice any profession or occupation.

The complaint also included allegations that winners of certain competitions were predetermined through financial arrangements and that Mrs. India Inc. had entered into a cartel-like arrangement with international pageant organizers. However, the CCI found that no supporting evidence had been produced to substantiate these claims. Consequently, the Commission declined to proceed on the cartelization allegations, observing that “on the mere statement of the Informant, cognizance of allegation of cartelisation between the OP and an international organiser cannot be made.”

While rejecting the cartel allegation, the Commission undertook a detailed examination of the contractual restrictions imposed on participants. The CCI observed that the agreements appeared to create exclusive dealing and tie-in arrangements that could potentially violate Sections 3(4)(a) and 3(4)(b) of the Competition Act. It noted that preventing participants from associating with competing pageants and requiring them to engage only with social causes approved by the organizer raised competition concerns.

A significant aspect of the order relates to market definition and dominance. The Commission held that beauty pageants for married women constitute a distinct market because they cater to a unique category of participants and cannot be substituted with other competitions. After examining public domain material and the organizer’s own representations, the CCI tentatively 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 noted that Mrs. India Inc. appeared to be a dominant player in this market due to its exclusive licenses and franchise rights linked to several major international pageants.

The Commission highlighted that Mrs. India Inc. had itself claimed before the Bombay High Court that it possessed exclusive franchise rights in India for several international beauty pageants, including Mrs. Globe, Mrs. Galaxy, Mrs. Earth, Mrs. International Summit, and related competitions. The CCI observed that these rights, combined with the organization’s national reach and public visibility, indicated a strong market position.

After reviewing the contractual terms, the Commission found several provisions to be prima facie exploitative. It specifically questioned clauses requiring prior approval before winners could enter into contracts with any third party, restrictions preventing contestants from participating in competing pageants for five years, mandatory association with designated social causes, and limitations on public appearances without approval from the organizer. The CCI observed that such conditions appeared “one-sided and unfair in nature” and could amount to abuse of dominant position under Sections 4(2)(a)(i), 4(2)(b)(i), and 4(2)(d) of the Competition Act.

The Commission also expressed concern that key contractual obligations were disclosed only after participants had already paid substantial amounts. According to the order, such information should have been made available before registration and payment so that contestants could make informed decisions regarding participation.

Concluding that a prima facie case existed, the CCI directed the Director General to investigate alleged violations of Sections 3(4)(a), 3(4)(b), 4(2)(a)(i), 4(2)(b)(i), and 4(2)(d) of the Competition Act, 2002. The Commission clarified that its findings are only preliminary and do not constitute a final determination on the merits of the case. The DG has been authorized to investigate any additional anti-competitive conduct that may emerge during the inquiry. The complainant’s request for interim relief, including suspension of the disputed contractual clauses, will be considered separately.

The order is significant because it extends competition law scrutiny beyond traditional commercial sectors into the entertainment and beauty pageant industry. The investigation could have wider implications for talent management contracts, exclusivity arrangements, non-compete clauses, and licensing practices adopted by organizations that control access to prestigious national and international platforms. If the allegations are ultimately established, the case may serve as an important precedent regarding the limits of contractual restrictions imposed on contestants, performers, influencers, and other individuals participating in specialized professional competitions.

Case Reference: Rinima Borah Agarwal v. Mrs. India Inc., Case No. 12 of 2025, Competition Commission of India, Order under Section 26(1) of the Competition Act, 2002.