Delhi High Court Affirms Dressage Team Selection, Reinforces Judicial Restraint in Sports Governance

In a significant decision on the scope of judicial review in sports administration, the Delhi High Court upheld the Equestrian Federation of India’s (EFI) selection of the Indian dressage team for the 2026 Asian Games. The matter was initiated by leading dressage players Anush Agarwalla and Sudipti Hajela, who challenged the EFI’s selection of the Indian contingent for the Asian Games.

The petitioners contended that the Federation had deviated from its published selection criteria by improperly determining the Minimum Eligibility Requirements (MERs), failing to conduct further selection trials, and constituting a Selection Committee in a manner that allegedly compromised the fairness of the selection process. They argued that these departures rendered the selection arbitrary and sought judicial review of the final team.

A Single Judge of the Delhi High Court rejected the challenge, holding that the petitioners had failed to establish arbitrariness or mala fides warranting judicial interference. The riders thereafter preferred appeals before the Division Bench, reiterating that the Federation had not properly implemented its published selection criteria.

Upon examining the appeals, the Division Bench upheld the Single Judge’s decision and declined to interfere with the finalised national contingent. The Court held that the appellants had failed to establish arbitrariness, perversity, or mala fides in the selection process sufficient to justify judicial intervention. Reiterating the limited scope of judicial review in matters involving sporting merit, the Bench observed that constitutional courts should not substitute the assessment of expert bodies entrusted with athlete selection.

The judgment reflects the application of established principles of administrative law in the field of sports governance. While decisions of National Sports Federations remain amenable to judicial review, courts will ordinarily intervene only where there is clear arbitrariness, mala fides, perversity or a substantial violation of the principles of natural justice. Mere disagreement with the manner in which selection criteria have been applied, without demonstrating illegality or manifest unfairness, is unlikely to justify interference, particularly where doing so would disrupt national sporting preparations.

In a similar matter in September 2024, the Delhi High Court had dismissed the petition filed by Shruti Vora, another dressage athlete, challenging the Selection Criteria Notice 2024 issued by the Equestrian Federation of India (EFI). In the matter, the court had similarly stated that, Absent clear evidence of arbitrary or capricious decision-making, or a selection criterion that blatantly disregarded fairness or applicable standards, the Court had to defer to the expertise and discretion of the sport’s governing bodies.