CCI orders probe against Mrs India Inc over unfair terms imposed on beauty pageant participants

The Competition Commission of India (CCI) has ordered an investigation against Mrs India Inc over allegations that it imposed unfair and restrictive conditions on participants and winners of its beauty pageant for married women.

The order was passed on a complaint filed by Rinima Borah Agarwal, who was a participant and runner-up in the Mrs. India Inc beauty pageant held in 2024.

A coram comprising CCI Chairperson Ravneet Kaur and members Anil Agrawal, Sweta Kakkad and Deepak Anurag found that a prima facie case was made out against Mrs. India Inc for the alleged contravention of Sections 3 and 4 of the Competition Act, 2002.

The CCI has directed its Director General (DG) to investigate the matter and submit a report within 90 days.

Agarwal had alleged that Mrs India Inc, a sole proprietorship run by Mohini Sharma, held exclusive licences for several international beauty pageants in the “Mrs” category and used its position to impose one-sided conditions on participants.

According to the complaint, Agarwal had first paid a registration fee of ₹3,000 to participate in the pageant. She was later asked to choose between a Basic Package priced at ₹3.25 lakh and a Premium Package priced at ₹6.75 lakh for training and grooming.

The informant alleged that she chose the Premium Package after being told that it would give her a guaranteed chance to be among the top participants and enter international competitions.

After she was declared first runner-up and awarded the title of “Mrs India Galaxy”, Agarwal was allegedly asked to sign a “Winners’ Terms and Conditions Agreement." She claimed that the agreement barred her from participating in any other beauty pageant, whether as a participant, consultant, judge, mentor, founder or co-founder, for five years.

She also alleged that the pageant organiser demanded up to ₹25 lakh to enable her participation in the international Mrs. Galaxy pageant in 2025.

The Commission also took note of clauses allowing Mrs India Inc to use photographs and videos of participants for publicity, marketing and promotion free of cost, even after termination of the agreements.

The CCI said such terms should have been disclosed before registration or payment of the fee for the compulsory training and grooming package so that participants could take an informed decision

"Such information should have been disclosed to the Informant prior to registration or payment of compulsory package for training and grooming so that she could have taken an informed decision,” the order said.

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.

It found that Mrs India Inc appeared to be a dominant player in this market, given its franchise holdings, national reach, media visibility and exclusive licences to send winners to international pageants such as Mrs Globe, Ms Galaxy, Mrs International Summit and Mrs International World.

The CCI, however, rejected the allegation of cartelisation between Mrs India Inc and the international organisers of Mrs Globe. It said no evidence had been placed on record to show any agreement under which winners were pre-decided.

At the same time, the Commission found that the restrictive clauses in the agreements appeared to be in the nature of tie-in and exclusive dealing arrangements under Section 3(4) of the Competition Act.

It also found that certain clauses prima facie appeared to be exploitative and may amount to an abuse of dominance.

The Commission concluded that a prima facie case was made that the Competition Act may have been violated. Accordingly, it has ordered a probe into the allegations against Mrs. India Inc.

The informant was represented by a team from Hammurabi & Solomon comprising Founding Partner Shweta Bharti, Senior Partner Jyoti K Chaudhary, Ankit Konwar (Partner Designate), Avdhesh Bairwa (Partner Designate), Prateek Singh (Associate), and Nishi Rathore (Associate).

[Read Order]