Sanjana vs Union Of India & Ors.
- Court
- Delhi High Court
$~
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Judgment reserved on: 02.09.2026
Judgment pronounced on: 07.09.2026
Judgment uploaded on: 08.09.2026
# CNR No. DLHC010410172026
+ W.P.(C) 12670/2026
SANJANA .....Petitioner
Through: Mr. Vibhas Kumar Jha and
Mr. Azad Singh, Advocates,
with petitioner in person.
versus
UNION OF INDIA & ORS. .....Respondents
Through: Ms. Puja S. Kalra, CGSC for
UOI.
Ms. Kumudavalli Seetharaman
and Ms. Geetika Vyas, Advs.
for R-2.
Mr. Rajneesh Bhaskar and Mr.
Siddharth Makkar, Advs. for
R-3.
CORAM:
HON'BLE DR. JUSTICE SWARANA KANTA SHARMA
JUDGMENT
DR. SWARANA KANTA SHARMA, J
1. By way of the present writ petition, the petitioner seeks
quashing the notification dated 22.08.2026 [hereafter „ impugned
notification ‟] issued by respondent no. 1, Union of India through the
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Ministry of Youth Affairs & Sports [hereafter „ Ministry ‟], and a
direction to the Ministry to forthwith forward her name to the
relevant respondents for participation in the Women‟s 77 kg
Weightlifting event at the 20th Asian Games, Aichi-Nagoya 2026,
and to include her name in the final list of athletes for the said
Games.
FACTUAL BACKGROUND
2. The case set out by the petitioner is that she is an Indian
weightlifter who competes in the Senior Women‟s 77 kg category
and has represented the country at international competitions.
Respondent no. 1 is the Union of India through the Ministry,
respondent no. 2 is the Indian Olympic Association ( IOA ),
respondent no. 3 is the Indian Weightlifting Federation ( IWF ), being
the National Sports Federation recognised for the sport, respondent
no. 4 is the Sports Authority of India ( SAI ), and respondent no. 5 is
the Chief Executive Officer, Target Olympic Podium Scheme. It is
stated that the criteria governing selection of the Indian contingent
for multi-sport events, including the 20th Asian Games, Aichi-
Nagoya 2026, scheduled to be held in Japan from 19.09.2026 to
04.10.2026, was notified by the Ministry vide letter dated 24.09.2025
[hereafter „ Ministry’s Selection Criteria ‟]. The IWF thereafter
framed its own Selection Policy for the said Games, updated as on
20.05.2026 [hereafter „ Selection Policy of IWF ‟], prescribing a
benchmark total of 214 kg for the Women‟s 77 kg category.
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3. The petitioner participated in the 2026 AWF Asian Senior
Weightlifting Championships, held at Gandhinagar from 11.05.2026
to 17.05.2026, which was one of the mandatory evaluation events
under the aforesaid policy/criteria. She secured the third position in
the Women‟s 77 kg category with a total lift of 220 kg, comprising
96 kg in Snatch and 124 kg in Clean & Jerk, and won Bronze Medals
in the Snatch, Clean & Jerk and Total events. The Selection
Committee of the IWF, in its meeting held on 22.06.2026,
recommended five men and five women, including the petitioner, for
the Games. Thereafter, by communication dated 03.07.2026, the IWF
confirmed to the SAI and the IOA that all the athletes so nominated
satisfied the prescribed criteria, the petitioner being shown therein as
„Qualified‟. The IWF also issued a certificate dated 25.08.2026
certifying her performance at the Championships and commending
her candidature.
4. In the meanwhile, the Ministry, by order dated 22.08.2026
addressed to the IOA, accorded approval for the participation of 492
athletes, comprising 265 male and 227 female athletes, in 35
disciplines at the said Games, the name-wise list whereof was
annexed thereto. In the discipline of weightlifting, one male and four
female athletes came to be approved, and the name of the petitioner
was not included. It is this exclusion of the petitioner which has given
rise to the present petition.
SUBMISSIONS BEFORE THE COURT
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5. The learned counsel appearing for the petitioner argues that
the petitioner satisfies the eligibility and performance requirements
prescribed under the applicable framework, but her candidature has
nonetheless not been considered. It is argued that Clause 4(c) of the
Selection Policy of the IWF provides for the selection of five athletes
each in the male and female sections for the Asian Games. It is
further argued that, where more than five athletes achieve the
qualifying total, the Selection Committee may finalise the team
having regard to the relevant weight category, medal potential and
overall competition prospects. It is argued that, notwithstanding the
said Policy, the impugned notification dated 22.08.2026 approved
only four female weightlifters and one male weightlifter, thereby
leaving the fifth female slot unfilled. It is argued that the benchmark
total prescribed for the Women‟s 77 kg category is 214 kg, which the
petitioner bettered by 6 kg, having achieved a total lift of 220 kg at
one of the mandatory evaluation events recognised under the Policy.
It is further argued that the petitioner satisfies the criteria contained in
the Ministry‟s Selection Criteria dated 24.09.2025, under which a
National Sports Federation is eligible to nominate an athlete who has
matched or bettered the sixth-place performance at the last Senior
Asian Championships. The Selection Policy of the IWF itself adopted
the corresponding sixth-place performance for the Women‟s 77 kg
category as the benchmark of 214 kg. It is argued that the Selection
Committee, in its meeting held on 22.06.2026, considered and
recommended the petitioner; that the IWF, by its communication
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dated 03.07.2026, expressly recorded her status as „Qualified‟; and
that it commended her candidature by certificate dated 25.08.2026. It
is argued that, despite her performance, eligibility and
recommendation by the IWF, the petitioner‟s name did not find place
in the approved list dated 22.08.2026, i.e., the impugned notification,
and no reason for her exclusion has been communicated to her. It is
argued that, having framed a selection policy, the respondents are
bound to apply it fairly and uniformly to all eligible athletes and
cannot adopt different standards for similarly situated athletes
without disclosing rational reasons. Therefore, it is prayed that the
present petition be allowed
6. The learned CGSC appearing for respondent no.
1/Ministry , on the other hand, opposes the petition and argues that
the selection for the 20th Asian Games, 2026, is governed by the
Ministry‟s Selection Criteria, notified on 24.09.2025, which prescribe
uniform benchmarks to ensure that only likely medal probables
represent the country. It is argued that, since the Women‟s 77 kg
category was not contested at the last Asian Games, the applicable
benchmark was required to be determined under Clause 4.1(I)(b) of
the said Criteria, by reference to the last Senior Asian
Championships. It is further argued that, as only five athletes from
less than six countries competed in that category at the 2026 AWF
Asian Senior Weightlifting Championships at Gandhinagar, the „Top
2‟ cut-off prescribed under Clause 6 of the Criteria stood attracted,
resulting in a benchmark of 260 kg, as against the petitioner‟s total of
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220 kg. It is argued that securing third position in a field of five
athletes neither establishes competitive depth nor creates a right to
nomination; that a vacant quota slot cannot render an otherwise
ineligible athlete eligible; and that no athlete was approved in the said
category, which negates any allegation of discrimination. It is further
argued that relaxing a uniformly applied benchmark would set an
unworkable precedent and prejudice athletes of other disciplines
excluded under the same Criteria. It is also argued that a writ court
does not sit in appeal over the decisions of experts, and that no case
for interference under Article 226 of the Constitution of India is made
out.
7. The learned counsel appearing for respondent no. 3/IWF ,
however, supports the petitioner and argues that its nine-member
Selection Committee had, on 22.06.2026, unanimously recommended
five men and five women, including the petitioner, for the Asian
Games 2026. It is argued that the Selection Policy of the IWF fixes
the benchmark for the Women‟s 77 kg category at 214 kg, which the
petitioner has bettered by 6 kg. It is further argued that Clause 6 of
the Ministry‟s Selection Criteria, being only a ranking cut-off
provision, cannot operate as a standalone bar divorced from Clause
4.1(I)(b), Clause 7 and the sport-specific policy, particularly when
the number of countries entering a category depends upon the entry
choices of foreign federations, a matter beyond the athlete‟s control.
It is further contended that the possibility of relaxation under Clause
5 of the Ministry‟s Selection Criteria remained unconsidered, and
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that the petitioner‟s inclusion would only fill the fifth female slot
permissible under the Games framework, which was left vacant by
the impugned notification dated 22.08.2026.
8. This Court has heard arguments addressed on behalf of the
petitioner as well as the respondent no. 1 and respondent no. 3, and
has perused the material available on record.
ANALYSIS & FINDINGS
9. The principal issue that arises for consideration is whether –
notwithstanding the petitioner‟s having secured a total of 220 kg in
the Women‟s 77 kg category at the 2026 Senior Asian Weightlifting
Championships and having been recommended by the IWF Selection
Committee on the basis of its own Selection Policy – she satisfied the
eligibility requirements prescribed under the Ministry‟s Selection
Criteria dated 24.09.2025 for being nominated to represent India at
the 20th Asian Games, Aichi-Nagoya 2026.
10. At the outset, it is apposite to note that the Ministry‟s Selection
Criteria was notified on 24.09.2025, well before the commencement
of the selection process for the 20th Asian Games, Aichi-Nagoya
2026. Clause 4 of the said criteria prescribe objective performance
benchmarks for measurable individual sports and events. The same
reads as under:
“ 4. Benchmarks for individual sports and events and team sports
and events
4.1 The benchmarks are being prescribed so that likely medal
probable are representing India and quality of the participation is
ensured in multidisciplinary sports events such as Asian Games,
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Para-Asian Games, Commonwealth Games, Asian Indoor games,
Asian Beach Games, Youth Olympics, Asian Youth Games,
Commonwealth Youth Games, similar events in para-sports as also
the winter editions of such games.
(I) Measurable Individual Sports and Events:
a. Where the sport or event was contested at the last Asian
GamesThe NSF will be eligible to nominate an athlete if the athlete
has matched or bettered the 6th-place performance from the last
Asian Games at a competition recognized by the international sports
federation for that sport, held within the 12 months preceding the
upcoming Asian Games.
b. Where the sport or event was not contested at the last Asian
Games but Senior Asian Championships was conducted for the sport
or event within 12 months preceding the upcoming Asian Games -
The NSF will be eligible to nominate an athlete if the athlete has
matched or bettered the 6th-place performance from the last Senior
Asian Championships at a competition recognized by the
international sports federation for that sport, held within the 12
months preceding the upcoming Asian Games.”
11. Clearly, Clause 4.1(I)(a) applies where the relevant sport or
event was contested at the last Asian Games, in which case the
benchmark is the sixth-place performance at those Games. Clause
4.1(I)(b) applies where the sport or event was not contested at the last
Asian Games but a Senior Asian Championships was conducted
within the preceding twelve months, in which case the benchmark is
the sixth-place performance at the last Senior Asian Championships.
The Ministry has, therefore, prescribed a specific mechanism for
determining the benchmark in respect of events which were not part
of the preceding Asian Games.
12. Clause 6 deals with the determination of the ranking cut-off in
cases where there is low participation in the Asian Championships.
The same reads as under:
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6. Determination of ranking cut off in cases where there is low
participation in Asian Championships
Number of participating countries at Asian Championships
• If number of competing countries are less than 12 in an event, then
the following shall be considered:
No. of participating
countries in a particular
Position required to secure Asian
Games eligibility
event at Asian
Championships
6-12 Top 4
Less than 6 Top 2
13. It provides that where the number of competing countries in an
event is less than twelve, the following cut-offs would apply – (i)
where the number of participating countries is between 06 and 12, an
athlete must finish within the top four; and (ii) where the number of
participating countries is less than 06, an athlete must finish within
the top two. Apparently, the object of Clause 6 is to ensure that a
high position obtained in an event with limited participation is not, by
itself, sufficient to ensure eligibility, and it consequently prescribes a
stricter ranking cut-off in such cases.
14. The Selection Policy of IWF has to be understood in this
background. As evident from a perusal of the said policy, the same
was framed for the selection of athletes in view of the change in
bodyweight categories with effect from 01.08.2026, and the fact that
the Asian Games 2026 would be the first major event to be conducted
in the new categories. Clause 4(c) of the IWF Policy proposes
selection of five male and five female athletes for the Asian Games.
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Clause 4(d) of the IWF Policy provides that, for the purpose of
selection, the total performance in the respective bodyweight
category during the preceding one year would be considered. It also
prescribes a benchmark total for each weight category.
15. In the present case, the relevant weight category is the
Women‟s 77 kg category. The Selection Policy of IWF prescribes a
benchmark total of 214 kg for this category. The petitioner
admittedly achieved a total of 220 kg at the 2026 AWF Asian Senior
Weightlifting Championships held at Gandhinagar. She, therefore,
exceeded the benchmark prescribed by the IWF by 6 kg. The
petitioner also secured the third position in the Women‟s 77 kg
category at the said Championships, with a total of 220 kg,
comprising 96 kg in Snatch and 124 kg in Clean & Jerk. Her
performance was recognised by the IWF, and the IWF Selection
Committee recommended her name along with the names of four
other female athletes. The IWF thereafter communicated to SAI and
IOA that the nominated athletes had satisfied the criteria under the
IWF Selection Policy, and the petitioner was marked as “Qualified”.
16. However , the fact that the petitioner achieved the benchmark
prescribed by the IWF and was recommended by the IWF Selection
Committee does not, by itself, conclude the issue of her eligibility for
nomination to the Asian Games, inasmuch as the final selection for a
multidisciplinary event is subject not only to the sport-specific policy
of the concerned NSF, but also to the Ministry‟s Selection Criteria.
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17. It is also not in dispute that the Women‟s 77 kg category was
not contested at the preceding Asian Games held at Hangzhou in
2023. Consequently, Clause 4.1(I)(a) of the Ministry‟s Selection
Criteria, which applies where the sport or event was contested at the
last Asian Games, could not apply to the petitioner‟s case. The
applicable provision was Clause 4.1(I)(b), since the relevant event
had not been contested at the last Asian Games and a Senior Asian
Championships had been conducted within twelve months preceding
the forthcoming Asian Games. Accordingly, the benchmark for the
petitioner‟s eligibility had to be determined with reference to the
performance at the 2026 Senior Asian Weightlifting Championships
held at Gandhinagar. The petitioner herein had participated in the
said Championships and secured the third position in the Women‟s
77 kg category. The relevant field, however, consisted of only five
athletes, thus, representing fewer than six participating countries.
18. Therefore, in view of the limited participation in the said
Women‟s 77 kg category, Clause 6 of the Ministry‟s Selection
Criteria would be attracted. Since the number of participating
countries in the relevant event was less than six, the prescribed
ranking cut-off was the top two. As per record, the performance of
the top two athletes in the Women‟s 77 kg category at the
Gandhinagar Championships was 265 kg and 260 kg respectively.
Thus, in terms of the Ministry‟s Selection Criteria, the relevant
benchmark was required to be assessed with reference to the top-two
performance in the event. The petitioner‟s performance of 220 kg
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was lower than the second-place performance by 40 kg and was
consequently below the benchmark applicable under the notified
criteria.
19. In view of the above discussion, the petitioner‟s contention that
she had exceeded the IWF benchmark of 214 kg cannot come to her
rescue. The IWF benchmark appears to have been relevant to the
sport-specific selection process undertaken by the IWF, whereas the
Ministry‟s criteria prescribe the conditions governing the eligibility
of an athlete for nomination to the Asian Games. The two
requirements, therefore, operate at different stages of the selection
process. Consequently, the petitioner‟s satisfaction of the IWF
benchmark could not be treated as dispensing with the separate
requirement of satisfying the Ministry‟s notified criteria. Likewise,
the recommendation made by the IWF, on the basis of its Selection
Policy, may not by itself be construed as a determination that the
petitioner had fulfilled every condition prescribed by the Ministry.
The recommendation was undoubtedly a relevant consideration, but
the ultimate decision regarding nomination was required to be taken
within the framework of the Ministry‟s applicable criteria.
20. Insofar as the submission of the IWF that Clause 6 of the
Ministry‟s Selection Criteria cannot be read in isolation, divorced
from Clause 4.1(I)(b), is concerned, this Court is of the view that a
harmonious reading of the two provisions would indicate that Clause
4.1(I)(b) lays down the general performance benchmark applicable
where the relevant sport or event was not contested at the last Asian
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Games, whereas Clause 6 specifically addresses the additional
situation of low participation in the relevant Asian Championships.
Clause 6, therefore, operates as a specific provision within the
broader framework of Clause 4.1(I)(b), and cannot be disregarded
merely because the athlete has satisfied the prescribed performance
benchmark.
21. The petitioner has also relied upon the fact that the IWF
Selection Committee recommended five female athletes and that the
fifth female slot was not filled in the Ministry‟s notification dated
22.08.2026. However, the existence of a vacant slot cannot create
eligibility where the applicable performance and ranking criteria have
not been satisfied. A vacant slot may permit the competent authority
to consider whether any eligible athlete can be nominated or whether
relaxation under Clause 5 of the Ministry‟s Selection Criteria is
warranted, but it does not confer an automatic right upon an athlete
who does not meet the prescribed criteria. In this regard, the
petitioner has also not demonstrated that the competent authority was
under a mandatory obligation to fill every available slot, irrespective
of the eligibility criteria. The mere fact that the approved number of
female weightlifters was four, although the IWF had recommended
five, cannot render the Ministry‟s decision arbitrary when the
petitioner did not satisfy the benchmark applicable under the
Ministry‟s criteria.
22. Furthermore, the Ministry‟s Selection Criteria has neither been
challenged in the present writ petition, nor has been shown to have
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been applied selectively against her. The requirement of satisfying
the applicable performance benchmark, read with the prescribed top-
four or top-two ranking cut-off in cases of low participation, forms
part of a general policy governing measurable sports and events. The
petitioner has not shown that any similarly situated athlete, who had
not satisfied the applicable criteria, was nevertheless nominated for
the Asian Games. Her plea of discrimination, therefore, cannot be
accepted merely because she had achieved the IWF benchmark or
had been recommended by the IWF. In the absence of any material
showing arbitrary, discriminatory or inconsistent application of the
Ministry‟s Selection Criteria, the petitioner cannot claim a right to
nomination merely because a slot remained available.
23. The Court is also of the considered view that it cannot
substitute its own assessment of the petitioner‟s medal prospects for
the assessment reflected in the notified criteria. The policy decision
to insist upon the top-two cut-off where participation is below six
countries is within the domain of the Executive and the competent
sporting and administrative authorities. The Court‟s jurisdiction
under Article 226 of the Constitution is not to undertake a fresh
evaluation of athletes or to determine which athlete ought to
represent the country, unless the decision is shown to be arbitrary,
irrational, discriminatory, mala fide or contrary to the governing rules
or policies. In this regard, reliance can also be placed on the
following observations of the Coordinate Bench of this Court in
Yamini Mourya v. Indian Olympic Association: 2023 SCC OnLine
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Del 6213 :
“18. The selection criteria has been evolved by experts and
this Court is of the opinion that the criteria which has been
evolved by the Respondent No.2 on 10.07.2023, is not
perverse. The writ court must only see whether the criteria
which have been arrived at is in good faith and whether the
decision is reasonable. The writ court must not sit as an
Appellate Authority over the decisions arrived at by experts
if the same is reasonable and has been taken in good faith.
*
22. The criteria adopted by the Respondents by ranking the
players in their respective weight categories, keeping in mind
their world rankings and arriving at their respective Asia
ranking and to restrict only those players who have achieved
8th rank in their respective category to be sent to represent
the country in Asian Games, cannot be said to be arbitrary or
perverse. There is nothing on record which shows that the
criteria has been evolved to oust the Petitioners herein. It has
been found that only three athletes in women category in -70
kg, -78 kg and +78kg category and one male athlete in -100
kg category alone satisfy the criteria evolved by the
Respondents and they have been selected to represent the
country in the Asian Games.
23. Even if two opinions are possible, the Court while
exercising its jurisdiction under Article 226 of the
Constitution of India must restrain itself from substituting its
opinion to the decision arrived at by the authorities. This
Court, therefore, does not find any merit in the writ petition.”
24. In the present case, the Ministry has explained that the
Women‟s 77 kg category at the 2026 Senior Asian Weightlifting
Championships had only five participating countries. Consequently,
the top-two cut-off under Clause 6 was applied. The top-two
performances were 265 kg and 260 kg, whereas the petitioner‟s
performance was 220 kg and that she had secured third position. The
petitioner, therefore, did not satisfy the applicable benchmark under
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the Ministry‟s Selection Criteria. The explanation furnished by the
Ministry is, therefore, consistent with the language and purpose of
the notified criteria and does not suffer from any apparent infirmity.
25. This Court appreciates the petitioner‟s achievement and
acknowledges her distinction in representing the country. However,
at the same time, the Court is conscious that the Ministry‟s Selection
Criteria constitutes a uniform policy applicable to all athletes across
the country. That criteria, therefore, has to be applied strictly and
consistently, and any relaxation beyond what is expressly permitted
under the policy would not only dilute the prescribed standards but
also be unfair to other athletes who are governed by the same criteria.
26. This Court accordingly finds that the petitioner‟s exclusion
from the final list cannot be held to be arbitrary and the petitioner has
failed to establish any enforceable right to a direction requiring the
Ministry to forward or include her name in the final list of athletes for
the Women‟s 77 kg weightlifting event at the Asian Games. The
relief sought would, in substance, require this Court to disregard or
dilute the Ministry‟s notified criteria and to direct selection of an
athlete who does not satisfy the applicable eligibility requirement.
Such a direction cannot be issued in exercise of writ jurisdiction.
27. For the foregoing reasons, this Court finds no infirmity in the
application of the Ministry‟s Selection Criteria to the petitioner‟s
case.
28. The writ petition is, accordingly, dismissed.
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29. The judgment be uploaded on the website forthwith.
DR. SWARANA KANTA SHARMA, J
SEPTEMBER 07, 2026/zp
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