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When I say earn I mean he fought the gym leader and won, and then he got the badge. Not counting Orange Islands

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I will list the badges Ash has not earned through actual victory, as most of his wins were legitimate. This list counts an "actual victory" as knocking out a Gym Leader's team to earn a badge, regardless of circumstances (e.g., not actually taking place in a proper gym). Forfeits and ties are counted as non-wins in these rules, I can change that if you wish.

  • Kanto, Boulder Badge (Ash forfeits right before winning, Brock awards a badge anyway for showing compassion.)
  • Kanto, Cascade Badge (Ash defeats Team Rocket. It is stated, however, that he would've won against Misty anyway due to his type advantage.)
  • Kanto, Marsh Badge (Ash makes Sabrina and Haunter laugh, rendering them incapable of battle.)
  • Kanto, Rainbow Badge (Ash rescues a Gloom from a fire.)
  • Kanto, Earth Badge (Ash defeats Team Rocket, who drop the badge. However, they had been temporarily appointed as gym leaders.)
  • Johto, Glacier Badge (Pryce forfeits.)
  • Sinnoh, Cobble Badge (Ends in a tie.)

In short, Ash has won 41 out of his 48 badges through legitimate battle.

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It doesn't matter if it counts as a gym battle, the asker is looking for the number of gym BADGES. The badge that is earned is merely a replica, so it isn't an "actual earned gym badge". Even if it were, Ash already has that badge.
Though, I think it's worth to note there.
Though, your answer, so idc. People can still look at the comments.
Actually he did I not earn earth badge, since he did not battle the actual team, and it was never handed to him - it fell out of team rockets hand also jess and James are not gym leaders
I didn’t list it as Team Rocket had been temporarily appointed the official gym leaders, meaning they were to act as proper gym leaders while the usual one (Giovanni) was away. I counted them as gym leaders under this ruling, meaning their team would be a “gym leader’s team”. Since Ash fought the team, won, and gained a badge out of it, I counted it as “earning a badge” despite the leaders never actually handing it to him.

Though, if you’d like me to include it anyway I can do so; this is your question after all.
It would satisfy if me if you did, but you don't have to.