CCI initiates probe into five‑year restrictive clauses in beauty pageant agreements

The Competition Commission of India (CCI) has directed a detailed investigation into alleged anti‑competitive conduct by Mrs. India Inc. (the OP), a beauty pageant organiser for married women, acting on information filed by Smt. Rinima Borah Agarwal (the Informant). The case raises important questions on how exclusivity, long lock‑in clauses, and post‑termination obligations in talent and entertainment contracts may fall foul of the Competition Act, 2002.

This order is not a final adjudication. The CCI has only formed a prima facie view that certain provisions of the agreements between the Informant and the OP may be anti‑competitive and amount to abuse of dominant position, warranting investigation by the Director General (DG) under Section 26(1) of the Competition Act, 2002.

Background: Mrs. India Inc. and the Informant’s participation

The Informant is an individual who took part in the 2024 edition of the ‘Mrs. India’ pageant conducted by Mrs. India Inc. She ultimately emerged as first runner‑up and was conferred the title ‘Mrs. India Galaxy’, which entitled her to represent India at the ‘International Mrs. Galaxy’ beauty pageant.

According to the information filed:

  • Mrs. India Inc. organises an annual pageant, ‘Mrs. India Inc.’, for married women.
  • The overall winner is crowned ‘Mrs. India World’ and goes on to participate in ‘Mrs. World’.
  • Runners‑up receive titles that act as gateways to other international “Mrs.” competitions such as Mrs. Galaxy, Mrs. International Summit, Mrs. Earth and Mrs. Globe.

The Informant asserted that this segment – beauty pageants for married women that feed into global “Mrs.” pageants – is a niche field in India, and that Mrs. India Inc. has significant prominence, owing to its exclusive rights and licenses from leading international organisers.

Registration, training packages and charitable fundraising

The sequence of events narrated by the Informant shows how she was integrated into the OP’s ecosystem:

  1. In 2023, she approached the OP to participate in the 2024 competition.
  2. She was asked to pay a registration fee of INR 3,000, which she promptly deposited.
  3. Upon registration, she received login details for the OP’s online portal.
  4. After payment of the registration fee, she was told that a training and grooming package was mandatory for the Indian round of ‘Mrs. India Inc., Season 5’.

The OP allegedly communicated two paid packages via WhatsApp:

  • A Basic Package of INR 3,25,000
  • A Premium Package of INR 6,75,000

The Informant stated that these packages and their pricing were not disclosed:

  • At the initial registration stage; or
  • On the OP’s website.

She alleged that:

  • The OP actively pushed her towards the more expensive Premium Package.
  • She was assured that the Premium Package would offer substantial benefits, including a strong likelihood of finishing among the top contestants and thereby obtaining eligibility for international competitions.
  • Motivated by these assurances and her desire to compete on global “Mrs.” platforms, she opted for – and paid for – the Premium Package.

Separately, she received an e‑mail dated 31.07.2024 from info@mrsindiainc.org with the subject “Season 5 – Mrs. Beyond Giving Task”. This e‑mail:

  • Required participants to collect or remit funds to “UDAAN Charitable Trust”, allegedly run by the owner of the OP, Smt. Mohini Sharma.
  • Offered specific competitive advantages:
    • Direct placement in the “Top 25” for those raising the highest funds.
    • Conferment of the title “Mrs. Beyond Giving”.
    • A special reward from a celebrity jury member at the finale.

The Informant alleged that fundraising was thus linked to competition outcomes and titles.

Imposition of Non‑Disclosure and Participants’ Terms & Conditions

The 5th Season of ‘Mrs. India Inc. Competition’ was held from 23.10.2024 to 27.10.2024 at Jaipur. After significant payments had already been made, the OP allegedly introduced further documentation.

On 30.09.2024, almost on the eve of the finale, the Informant received an e‑mail requiring her to execute:

  • A Non‑Disclosure Agreement (NDA), and
  • Participants’ Terms and Conditions (Participants’ T&C).

She claimed:

  • These agreements contained several stringent, one‑sided clauses.
  • Given the proximity to the finale and the large sums already spent, she felt compelled to sign them and continue in the competition.

Winners’ Terms & Conditions and further monetary demands

After the finale on 27.10.2024, the Informant:

  • Was declared first runner‑up, and
  • Received the title “Mrs. India Galaxy”, which entitled her to participate in the International Mrs. Galaxy pageant in 2025, representing India.

At this juncture, the OP allegedly presented her with yet another standard‑form contract, the Winners’ Terms and Conditions Agreement (Winners’ T&C), which she characterised as a “take‑it‑or‑leave‑it” document, containing additional restrictive obligations. According to the Informant, these included:

  • A blanket prohibition on taking part in any other beauty pageant (as participant, judge, mentor, consultant, founder or co‑founder) for five years from the 2024 win.
  • Liability to pay unspecified, non‑refundable fees.
  • Compulsory financial contributions to a charitable entity owned or controlled by the OP’s proprietor.

For participation in the International Mrs. Galaxy 2025 competition, the OP allegedly demanded further payments allegedly up to INR 25,00,000. The Informant stated that:

  • She was effectively forced to choose between paying this significant amount or forfeiting both her title and the heavy expenditure already made.
  • Even after this, further monetary demands allegedly continued for public relations, charity, travel, wardrobe and other heads, leaving her little choice but to comply so as not to jeopardise her title and prospects.

Termination by the Informant and continuing use of her content

Frustrated by the demands and conditions, the Informant issued a termination notice on 31.01.2025, clearly stating that:

  • She was severing all ties with the OP, and
  • The OP should not use her photographs, videos or related content in its marketing materials.

Despite this, she alleged that: