Case No. 12 of 2025, Rinima Borah Agarwal v. Mrs. India Inc

Background

On June 2, 2026, the CCI directed the Director General (‘DG’) to investigate Mrs. India Inc., a sole proprietorship that organises beauty pageants for married women, and to report within 90 days. The CCI found a prima facie case of contravention of Sections 3(4)(a), 3(4)(b), 4(2)(a)(i), 4(2)(b)(i), and 4(2)(d) of the Act.

Parties

Smt. Rinima Borah Agarwal (‘Informant’) took part in the 2024 edition of the Mrs. India pageant, was declared first runner-up, and received the title of Mrs. India Galaxy. Mrs. India Inc. (‘OP’), run by Smt. Mohini Sharma, conducts an annual national competition and holds the India franchise for a number of international pageants in the Mrs. category, including Mrs. World, Mrs. Globe, Mrs. Earth, Mrs. Galaxy, and Mrs. International Summit, along with a non-exclusive licence for Mrs. Universe.

Allegations

The Informant paid a registration fee of INR 3,000 in 2023 and was then told over WhatsApp that a training and grooming package was compulsory for the Indian round, priced at INR 325,000 for the basic option and INR 675,000 for the premium one. Neither package had been disclosed at the time of registration or on the Mrs. India website. She was persuaded to take the premium package on the assurance that it guaranteed a place among the top participants. In July 2024, she received an e-mail asking her to raise funds for UDAAN Charitable Trust, run by the proprietor of Mrs. India, with direct entry into the top 25 promised to whoever raised the most.

A non-disclosure agreement and the Participants’ Terms and Conditions were sent on September 30, 2024, weeks before the finale held at Jaipur between October 23 and 27, 2024, and the Winners’ Terms and Conditions were presented only after the result. Together these barred her for five years from taking part in any other pageant as a participant, consultant, judge, mentor, founder or co-founder, or from promoting or funding one on social media; placed her professional engagements under Mrs. India’s sole management for a year; required Mrs. India’s written approval for any contract or appearance; entitled Mrs. India to the whole of her third-party earnings subject to a 15 percent talent management fee; made contribution to a social cause chosen by Mrs. India compulsory; and gave Mrs. India free and perpetual use of her photographs and videos, including after termination. Mrs. India then demanded up to INR 2.5 million (approximately USD 26,000) to enable her participation in Mrs. Galaxy 2025, with further sums sought for public relations, charity, travel, and wardrobe. She issued a notice of termination on January 31, 2025, which Mrs. India did not accept.

The Informant also alleged that winners were decided in advance in return for payment, and that Mrs. India and the international organiser of Mrs. Globe had formed a cartel within the meaning of Section 2(c). Alongside the Information, she filed an interlocutory application, IA No. 178A of 2025, seeking a stay on the operation of the impugned clauses. Mrs. India was given several opportunities but filed neither comments on the Information nor the additional information sought by the CCI by its Order dated July 30, 2025.

CCI’s Findings

On the cartel allegation, the CCI found nothing on record to show any agreement between Mrs. India and the Mrs. Globe organisers, and held that cognisance could not be taken on the Informant’s statement alone. No case under Section 3(3) was made out. The agreements between the Informant and Mrs. India were in any event vertical rather than horizontal, and the clauses restraining her from being part of any other pageant looked like exclusive dealing under Section 3(4)(b), while the requirement to support only Mrs. India’s chosen social cause looked like a tie-in under Section 3(4)(a).

On market definition, the CCI held that beauty pageants have no substitute, that pageants for women are separate from those for men, and that the Big Four in India, being Miss World, Miss Universe, Miss Earth, and Miss International, do not admit married women. Organisers of international Mrs. pageants generally accept one delegate per country, so the national title is the route to the international stage. The relevant market was defined as the market for services of beauty pageants for married women in India for sending its winners to major international beauty pageants.

No market share data is published for this segment. The CCI instead looked at Mrs. India’s international franchise holdings, national reach, media visibility and longevity, at the fact that its website is the first result on a search for a Mrs. pageant in India, and at its admission before the Bombay High Court in Suit No. 11338/2024 that it holds the sole franchise licences for Mrs. World, Mrs. Globe, Mrs. Earth, Mrs. Galaxy, and Mrs. International Summit for the territory of India. It noted that the Mrs. India World licence has since gone to Marvelous Mrs. India, Mrs. India having earlier held the Mrs. World licence and produced Sargam Koushal, Mrs. World 2022. On this basis Mrs. India appears to be dominant in the delineated market.

Turning to abuse, the CCI observed that the requirement to sign the Participants’ Terms and Conditions was disclosed only days before the finale and the Winners’ Terms and Conditions only after it, when the money had already been paid and an informed decision was no longer possible. The bar on entering any contract without Mrs. India’s written approval appeared unfair and one-sided under Section 4(2)(a)(i); the five year restraint on association with other pageants appeared to limit the provision of her services under Section 4(2)(b)(i); and the compulsory contribution to Mrs. India’s social cause, together with prior approval for all appearances, appeared to make the contract conditional on supplementary obligations unconnected with its subject matter under Section 4(2)(d).

The DG has been given liberty to examine the conduct of any other entity that surfaces during the investigation. The CCI clarified that its observations are not a final expression of opinion on the merits, and that the interim relief application will be taken up separately.