Madras High Court: ‘Mr. India’ Or ‘Mr. South India’ Titles In Bodybuilding Competitions Not Violative Of Emblems & Names Act

The Madras High Court dismissed a Writ Petition filed by the Puducherry Body Builders & Fitness Association.

Update: 2025-06-03 04:00 GMT

Justice D Bharatha Chakravarthy, Madras High Court 

The Madras High Court held that titles in bodybuilding competitions like ‘Mr. India’ or ‘Mr. South India’ are not violative of the Emblems and Names (Prevention of Improper Use) Act, 1950 (the Act).

The Court dismissed a Writ Petition filed by the Puducherry Body Builders & Fitness Association seeking to forbear the Respondents from allowing the conduct of sports event in the name and style of or using the name of 'Mr.India' and 'Open Mr.South India' or 'National' at Rock Beach, Puducherry.

A Single Bench of Justice D Bharatha Chakravarthy held, “Thus, it can be seen that the nation’s name or emblem cannot be used in any trade, business, calling or profession, or in the title of any patent, or in any trademark or design or any name or emblem specified in the Schedule or any colourable imitation thereof, without the previous permission of the Central Government. As far as the concerned sport of bodybuilding is concerned, it is common knowledge that whoever wins the competition is called Mr. or Ms. South India or India or World. That is common and specific to the said sport. That does not in any manner mean that it is the use of any national emblem or name of the country for any trade, business, calling or profession. It is synonymously used to refer to the title winner of such bodybuilding competitions. The Sport is conducted to encourage physical fitness among individuals. I do not see the same as in any manner violative of Section 3 of the said Act.

Advocate P.Suresh Babu appeared for the Petitioner, while Senior Panel Counsel A.S.Vijayaragavan represented the Respondents.

Brief Facts

The Petition was filed on the premise that when the advertisement contains the words Mr.India and Open Mr.South India, etc., the same is violative of Section 3 of the Act. It was submitted that the private associations run by Respondents were conducting a bodybuilding competition and had advertised it as "Open Mr.South India 4th Fitness Zone Classic 2025, Bodybuilding & Fitness Competition" and "8th Mr.Kanagasabai Classic- 2025, Mr. India".

Court’s Reasoning

The High Court noted, “As far as the order passed in the earlier writ petition is concerned, it can be seen that it is an interim order passed on the consent of parties in the said case. The only question to be decided by the Court is whether the impugned action is violative of Section 3 of Act No. 12 of 1950.”

The Bench held, “In view thereof, I am unable to accede to the prayer made by the learned counsel appearing for the petitioner. Finding no merits, the writ petition stands dismissed. Consequently, connected miscellaneous petition is closed. No costs.”

Accordingly, the High Court dismissed the Petition.

Cause Title: Puducherry Body Builders & Fitness Association v. The Government Of India & Ors. (Neutral Citation: 2025:MHC:1133)

Appearance:

Petitioner: Advocate P.Suresh Babu

Respondents: Senior Panel Counsel A.S.Vijayaragavan; Additional Government Pleader R.Sreedhar

Click here to read/download the Order



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