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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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You forgot the Earth Badge(Meowth made the bomb to explode and "Blasted of again" droping the badge in ash's hand)
For the Earth Badge, Team Rocket had been temporarily appointed the Gym Leaders. Since Ash defeated them and gained a badge out of it, I count that as "defeating a gym leader".
Good point.Didn't thought about that.
Afsy, in the SM anime Ash beat Misty while in the gym, and in my opinion that counts as a 'gym battle'
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.