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CDJ 2026 MHC 7093 My Notes print Preview print print
Court : High Court of Judicature at Madras
Case No : W.P.No. 37538 of 2026 & W.M.P.No. 42155 of 2026
Judges: THE HONOURABLE MR. JUSTICE D. BHARATHA CHAKRAVARTHY
Parties : M/s. Tamil Nadu Amateur Body Building Association, Rep. by its Chairman, Arasu Versus The Government of India, Ministry of Youth Affairs and Sports, Rep by Under Secretary, Shastri Bhavan, New Delhi
Appearing Advocates : For the Petitioner: S. Prabhu, Advocate. For the Respondents: R1, M. Ramamoorthi, Special Panel Counsel, R4, Pooja, Advocate.
Date of Judgment : 18-09-2026
Head Note :-
Constitution of India - Article 226  -

Comparative Citation:
2026 MHC 3889,
Judgment :-

(Prayer: Petition filed under Article 226 of the Constitution of India, directing the respondents 1 to 3 to take action on the fourth respondent for violation.)

The prayer in the writ petition is to issue a writ of mandamus directing the fourth respondent not to conduct any sports event in the name and style of ‘Mr.India 2026’ at Hamsa Doraiji Mahal, Kanchalan Street, Waljapet, Ranipet District on 20.09.2026.

2. The petitioner is the recognised state association for Tamil Nadu.

3. Mr.S.Prabhu, the learned counsel for the petitioner, would submit that the fourth respondent is not a recognised National Level Federation authorised to conduct any official competition. If that is the position, the Department of Sports, Ministry of Youth Affairs and Sports, Government of India, in a circular dated 05.07.2011, had already clarified that the expression ‘India’ or ‘Indian’ should not be used by unauthorised associations without prior approval from the Government, and that they shall not organise or conduct any official recognised events, including Annual National Championships for the sports. Further, a circular dated 16.10.2018 is also relied upon, whereby unauthorised associations are forbidden from using the word ‘India’ or ‘Indian’ in their names. Therefore, the learned counsel would submit that while the fourth respondent is free to conduct the competition, the title ‘Mr India’ cannot be given to the winner, and they should not use the term ‘India’ in any manner whatsoever.

4. Per contra, Ms.Pooja, the learned counsel appearing on behalf of the fourth respondent would submit that it is their right to conduct a competition. They are not claiming, in any manner, to be the National Federation. The competition conducted by the fourth respondent, though at the national level, is a private competition and is not the official national-level competition. The winners are not promised Form-II and III for employment, nor will any other benefits accrue from the same with reference to education or any reservation whatsoever. They will also not claim to represent ‘India’ in any international competition based on this title. It is simply a competition conducted by the fourth respondent, and because it is conducted at the Indian level, considering the nature of the sport, the winner is termed ‘Mr.India’. Learned counsel would also rely on this Court's judgment in W.P.No.14635 of 2025.

5. With reference to the tournament, if the organizers have used the name ‘Indian competition’ or ‘All India National Championship’, the circular will apply in full force. However, the term ‘India’ is used only in the title, as in ‘Mr. India’. ‘Mr India ', ‘Mr South India’, ‘Mr Chennai’, or even ‘Mr locality’, is unique to body-building competitions. This Court has considered this in W.P.No.14635 of 2025. This does not amount to misrepresentation that it is an official national-level competition, or that the person declared Mr.India is officially representing India. The terms ‘Mr.’ and ‘Ms.’, are with reference to the area of coverage of the competition; are unique and to body-building competition alone. Therefore, that distinction has to be borne in mind. In any event, the submission made by the learned counsel for the fourth respondent that the person will only be ‘Rambo Classic 2026 - Mr India’ and not with reference to the official national competition or officially declared as ‘national champion Mr.India’ is recorded. The circular cannot be interpreted so as to affect the term ‘Rambo Classic 2026 Mr.India’ also. In view thereof, this Court is not inclined to interfere with the conduct of the tournament.

6. The printed Certificate produced by the learned counsel for the fourth respondent categorically mentions and is prominently printed that it is ‘Rambo Classic 2026 -Mr.India’. Therefore, considering the certificate also, I am not of the view that the fourth respondent is passing off its competition as any recognised competition or as the official national-level championship.

7. It is further made clear that the fourth respondent shall categorically make disclosure to all the participants that it is not the official competition to all the competitors and their performance will not in any manner be deemed to be representing the State or Nation and they will have nothing to do with the petitioner Tamil Nadu State Bodybuilder Association or National Federation and no benefits of employment or education will accrue on account of the competition.

8. With reference to the name of the association, it again mentions ‘Indian Bodybuilders Association’. In this regard, the first respondent may call for an explanation with reference to its circulars dated 05.07.2011 and 16.10.2018, and the fourth respondent may appropriately modify its name immediately or before the next renewal of its registration.

9. With the aforesaid liberty granted to the first respondent to take action, and with liberty to the fourth respondent to appropriately modify its name in tune with the circulars, this Writ Petition is disposed of. No costs. Connected miscellaneous petition is closed.

 
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