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Case Updates
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.
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.
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 included five-year non-compete obligations, restrictions on professional engagements and endorsements, mandatory participation in designated charitable initiatives, and 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.
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.
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 Sections 3(4)(a) and 3(4)(b) of the Competition Act. It further noted that the conditions could constitute unfair and supplementary obligations attracting Sections 4(2)(a)(i), 4(2)(b)(i) and 4(2)(d). 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.
CCI Orders Investigation into Alleged Exclusive Dealing Arrangements in Delhi’s Liquor Market
On 4 May 2026, the CCI directed the DG to investigate alleged anti-competitive conduct involving liquor manufacturer Pernod Ricard and certain wholesalers and retailers operating in Delhi under Section 26(1) of the Competition Act.2
The information alleged bid-rigging in tenders floated by the Department of Excise, Entertainment and Luxury Tax for the wholesale supply of country liquor in Delhi, as well as broader cartelisation during the implementation of the Delhi Excise Policy, 2021-22. According to the Informant, manufacturers, wholesalers and retailers coordinated their conduct to manipulate bids, allocate markets and influence liquor distribution in Delhi.
The CCI, however, found insufficient material to establish a prima facie case of bid-rigging. While certain tenders had been cancelled due to procedural
violations or concerns regarding narrow bid price ranges, the material on record was insufficient to infer collusion. Allegations of a horizontal agreement between major liquor manufacturers to allocate markets were likewise unsupported by adequate evidence at the prima facie stage.
The CCI nevertheless expressed concern regarding allegations that Pernod Ricard had entered into arrangements with certain wholesalers and retailers to promote its brands and increase market share. For this purpose, it delineated the relevant market as the market for sale and supply of Indian Made Foreign Liquor (IMFL) in Delhi and noted that Pernod Ricard had consistently held the highest market share in the broader wines, spirits and liquors segment.
The CCI noted material suggesting that Pernod Ricard may have provided financial support and corporate guarantees to selected retailers and entered into strategic arrangements aimed at securing preferential stocking and promotion of its brands. Such conduct, according to the CCI, could amount to an exclusive dealing arrangement under Section 3(4)(b) by potentially foreclosing competing brands, distorting consumer choice and restricting competition in the Delhi IMFL market. Accordingly, the CCI found a prima facie case under Section 3(4)(b) read with Section 3(1) and directed the DG to investigate the conduct of Pernod Ricard and certain associated wholesalers and retailers.
Business Takeaway :
The order highlights the CCI's continued scrutiny of vertical arrangements that may facilitate market foreclosure. Financial incentives, preferential supply arrangements and commercial strategies that encourage distributors or retailers to favour one supplier over competing brands may attract competition law scrutiny where they limit consumer choice or restrict market access for rivals.
Footnotes
1 CCI: In Re: Rinima Borah Agarwal and Mrs. India Inc., Case No. 12 of 2025, order dated 2 June 2026.
2 CCI: Mr. Mohit v. Pernod Ricard India Private Limited & Ors., Case No. 09 of 2024, order dated 4 May 2026
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