Conferring Titles Such As “Mr. India”, “Mr. South India” Not Violative Of Emblems And Names Act: Madras High Court

Justice Bharatha Chakravarthy said that conferring such title to the winner of a body building competition would not in any manner mean that it is a use of the national emblem or the name of the country for trade, business etc and is merely used to refer to the title winner. Noting that the sport is only aimed at encouraging physical health, the court found no violation of the law.

“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,” the court said.

The court was hearing a petition filed by Puducherry Bodybuilders and Fitness Association seeking directions to forbear the conduct of any sports event in the name of style of “Mr. India” and “Open Mr. South India”, or “National”.

The petitioner association argued that the private respondents were conducting a body building competition and the advertisement for it contains words such as Mr India and Open Mr South India etc which is violative of Section 3 of the Emblems and Names (Prevention of Improper Use) Act, 1950.

The Centre and the State submitted that the competition was being conducted by private organisations and they had nothing to do with the matter.

The court noted that as per Section 3 of the Act, what was prevent was using the nation's name or emblem in any trade, business, calling or profession, or in the title of any patent, or in any trademark or design without the previous permission of the Central Government.

The court noted that conferring the title would not be violative of the Act and was thus not inclined to allow the relief.

Counsel for the Petitioner: Mr. P. Suresh Babu

Counsel for the Respondent: Mr. A. S. Vijayaragavan Senior Panel Counsel (Government of India), Mr. R. Sreedhar Additional Government Pleader

Case Title: Puducherry Body Builders & Fitness Association v. The Government of India

Citation: 2025 LiveLaw (Mad) 184

Case No: W.P.No.14635 of 2025