CCI Orders Investigation into Mrs. India Inc. for Alleged Abuse of Dominance and Restrictive Contractual Practices

On 2 June 2026, the Competition Commission of India (CCI) directed the Director General (DG) to investigate allegations against Mrs. India Inc., a beauty pageant organiser for married women, for alleged contraventions of Sections 3 and 4 of the Competition Act, 2002 (Competition Act).¹ The information was filed by a participant and first runner-up in the 2024 edition of the Mrs. India Inc. pageant.

Cartelisation Allegations Rejected

The CCI rejected allegations of cartelisation between Mrs. India Inc. and international pageant organisers, noting the absence of evidence to support claims that winners were pre-determined.

Allegations of Abuse of Dominance Under Section 4

With respect to Section 4, the Informant alleged that Mrs. India Inc., which holds exclusive rights to send Indian representatives to international pageants such as Mrs. Globe, Mrs. Galaxy and Mrs. International Summit, imposed unfair and restrictive contractual conditions on participants and winners.

These conditions included:

• Five-year non-compete obligations
• Restrictions on professional engagements and endorsements
• Mandatory participation in designated charitable initiatives
• Continued commercial use of participants’ photographs and videos even after termination of the agreements

The Informant also alleged that substantial fees were charged for training, grooming and participation in international competitions.

Relevant Market Definition

For the purpose of assessing the abuse of dominance allegations, the CCI defined the relevant market as the market for services of beauty pageants for married women in India for sending winners to major international beauty pageants.

The CCI observed that Mrs. India Inc. appeared to be a significant player in this niche segment owing to its exclusive international pageant rights.

Prima Facie Findings and Direction to Investigate

On a prima facie review, the CCI found that the impugned contractual provisions appeared capable of restricting participants’ commercial opportunities and limiting engagement with competing pageants.

The CCI observed that the clauses may amount to exclusive dealing and tie-in arrangements under the Competition Act. It further noted that the conditions could constitute unfair and supplementary obligations. Specifically, the following provisions were identified:

• Sections 3(4)(a) and 3(4)(b) — exclusive dealing and tie-in arrangements
• Sections 4(2)(a)(i), 4(2)(b)(i) and 4(2)(d) — unfair and supplementary obligations

Accordingly, the CCI found a prima facie case and directed the DG to investigate the matter.

Business Takeaway

The order demonstrates that restrictive contractual provisions, particularly long-term exclusivity obligations extending beyond the duration of a commercial relationship, may attract competition law scrutiny where they limit market access or commercial opportunities.

Businesses that enjoy a strong position within specialised markets should carefully review exclusivity provisions, post-termination restrictions, and ancillary obligations imposed on customers and business partners.

Last Updated on 17 July, 2026