The Competition Commission of India (CCI) has launched an investigation into Mrs India Inc following accusations of imposing unfair and restrictive conditions on participants and winners of its beauty pageant designated for married women. This directive was in response to a complaint lodged by Rinima Borah Agarwal, a participant and runner-up in the 2024 edition of the Mrs. India Inc beauty pageant.
The investigatory order was issued by a panel comprising CCI Chairperson Ravneet Kaur and members Anil Agrawal, Sweta Kakkad, and Deepak Anurag, who identified a prima facie case against Mrs. India Inc for potential violations of Sections 3 and 4 of the Competition Act, 2002. Consequently, the CCI has mandated its Director General (DG) to conduct a thorough investigation and deliver a report within a 90-day timeframe.
Agarwal’s complaint alleges that Mrs India Inc, a sole proprietorship managed by Mohini Sharma, leveraged its exclusive licenses to several international beauty pageants in the “Mrs” category to impose unilateral conditions on its participants. The complaint outlines that Agarwal initially paid a registration fee of ₹3,000 to enter the pageant. Subsequently, she was required to select between a Basic Package costing ₹3.25 lakh and a Premium Package priced at ₹6.75 lakh for training and grooming.
The informant claimed she opted for the Premium Package after assurances of guaranteed advancement into the top tier participants and opportunities to compete internationally. Despite being named the first runner-up with the title “Mrs India Galaxy,” Agarwal was allegedly compelled to sign a “Winners’ Terms and Conditions Agreement.” This agreement purportedly prohibited her from participating in any other beauty pageant roles for five years. Furthermore, Agarwal alleged that a demand for up to ₹25 lakh was made to facilitate her participation in the international Mrs. Galaxy pageant in 2025.
The Commission also scrutinized clauses that permitted Mrs India Inc to utilize participants’ photographs and videos for marketing and promotion at no cost, even post-agreement termination. The CCI noted that such crucial terms should have been disclosed before registration or package payment to enable an informed decision by the participants. “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 stated.
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The CCI defined the relevant market as the services market for beauty pageants for married women in India that send winners to major international competitions. It was observed that Mrs India Inc seemed to be dominant in this market, given its extensive franchise network, national reach, media presence, and exclusive licenses for international pageants such as Mrs Globe, Ms Galaxy, Mrs International Summit, and Mrs International World.
However, the Commission dismissed allegations of cartelization between Mrs India Inc and international organizers of Mrs Globe, citing a lack of evidence for any pre-determined winner agreements. Nonetheless, the Commission found that the restrictive clauses in the agreements resembled tie-in and exclusive dealing arrangements under Section 3(4) of the Competition Act, potentially constituting an abuse of dominance.
The Commission concluded that the allegations warranted further investigation into possible violations of the Competition Act. The legal representation for the informant was provided by Hammurabi & Solomon, including Founding Partner Shweta Bharti, Senior Partner Jyoti K Chaudhary, Partner Designate Ankit Konwar, Partner Designate Avdhesh Bairwa, Associate Prateek Singh, and Associate Nishi Rathore.
