Delhi High Court
Administrative and Public LawSports Law

Absent a prescribed opening date, adopting the criteria’s publication date does not retrospectively alter selection rules.

Vaasvi Khaitan (Minor) Thr Her Father Mr Vedant Khaitan vs Ad-Hoc Committee For The Governance Of Equestrian Federation Of India & Ors.

Delhi High CourtJUDGMENT: September 24, 20264 MIN READSOURCE JUDGMENT
Absent a prescribed opening date, adopting the criteria’s publication date does not retrospectively alter selection rules.. Vaasvi Khaitan (Minor) Thr Her Father Mr Vedant Khaitan vs Ad-Hoc Committee For The Governance Of Equestrian Federation Of India & Ors.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant, a minor equestrian rider, challenged the selection of Respondent No. 5 to represent India in Show Jumping at the Youth Olympic Games 2026, with Respondent No. 6 appointed as reserve rider and the Appellant placed as Reserve Rider 2.

Source reference: paras. 3–7

FEI required riders to obtain a Certificate of Capability (“COC”), and the EFI Selection Criteria, uploaded on 8 May 2026, identified various qualitative parameters for choosing among riders holding valid COCs, including technical difficulty, consistency, recency, horse-rider stability, and championship readiness.

Source reference: paras. 3–7

The Appellant had obtained qualifying scores in CSI1* competitions between December 2025 and May 2026.

Source reference: paras. 10–13, 36–37

On 13 May 2026, the Selection Committee considered the Appellant and one other rider and selected the Appellant, but subsequently, after FEI confirmed on 20 May 2026 that seven Indian riders possessed valid COCs, EFI invited all seven riders to submit recent results by 25 July 2026 for final selection.

Source reference: paras. 10–13, 36–37

On 6 August 2026, the Selection Committee ranked Respondent No. 5 first, the Appellant second, and Respondent No. 6 third.

Source reference: paras. 19–25

Following the Appellant’s representation, the Committee reconsidered the matter on 24 August 2026 and assessed results obtained between 8 May and 25 July 2026, while also considering the Appellant’s 1 May 2026 result as her COC result.

Source reference: paras. 19–25

The Appellant was thereafter ranked third and designated Reserve Rider 2.

Source reference: paras. 19–25

The Appellant contended that the Selection Criteria did not prescribe 8 May 2026 as the opening date and that the Committee had retrospectively excluded results obtained between 8 November 2025 and 7 May 2026.

Source reference: paras. 26–28

The learned Single Judge declined to interfere, holding that no retrospective alteration had been established.

Source reference: paras. 26–28

The Appellant consequently preferred the present appeal.

Source reference: paras. 26–28
02

Issues

1. Whether the Selection Committee retrospectively altered the selection window by treating 8 May 2026 as the commencement date and thereby excluding results obtained before that date?

Source reference: paras. 32–34, 44–47

2. Whether the results obtained from 8 November 2025, including the FEI qualifying competitions, were required to be considered in determining the comparative order of merit of the eligible riders?

Source reference: paras. 33–39, 47

3. Whether the selection of the Appellant on 13 May 2026 concluded the selection process, such that EFI could not subsequently conduct a comparative assessment among all seven COC holders?

Source reference: paras. 36–43

4. Whether the Impugned Minutes, Impugned Resolution, and Selection Decision-II warranted judicial interference?

Source reference: paras. 45–49
03

Law Applied

The Court applied the principle that a selection process must be assessed with reference to the criteria and process actually prescribed and communicated by the competent authority; a later decision is not rendered retrospectively invalid merely because an earlier date was not expressly identified as the opening date, unless the record establishes that a different date had been prescribed or adopted.

Source reference: paras. 38, 44, 47

The Court also applied the principle that results used for obtaining a COC or establishing eligibility are distinct from results considered for final comparative selection, particularly where all eligible candidates are subsequently brought into a common selection process.

Source reference: paras. 34, 37, 41–43

Under the EFI Statute, publication of the Selection Criteria on the EFI website was relevant to their operative application.

Source reference: para. 30.2

The Court emphasised the broader administrative-law requirements of clarity, transparency, consistency, and fair communication in sporting selections, although lack of clarity alone does not justify rewriting the selection window or granting relief unsupported by the record.

Source reference: paras. 45–47

The Appellant relied upon Tej Prakash Pathak v. High Court of Rajasthan, (2025) 2 SCC 1, and K. Manjusree v. State of Andhra Pradesh, (2008) 3 SCC 512, concerning impermissible alteration of selection criteria after commencement of a selection process; however, the Court found those principles inapplicable because no pre-existing 8 November 2025 selection window was established.

Source reference: para. 29.16; paras. 44, 47
04

Reasoning

The Court held that the record did not establish 8 November 2025 as the opening date of the final selection process.

Source reference: paras. 35–40

The competitions held on 8 and 10 November 2025 were relevant to the qualification/COC process, but the final comparative selection arose only after FEI confirmed that seven riders had valid COCs and EFI invited all seven to submit recent performances for consideration.

Source reference: paras. 35–40

The Appellant’s selection on 13 May 2026 was not treated as conclusive because only the Appellant and one other rider had then been comparatively assessed; the subsequent communication dated 10 June 2026 expressly placed all seven COC holders in a common long-list process.

Source reference: paras. 41–43

Although the Selection Committee’s treatment of the Appellant’s 1 May 2026 result appeared internally inconsistent with an 8 May opening date, that inconsistency did not establish that 8 November 2025 was the legally applicable commencement date.

Source reference: para. 44

Since no document prescribed or adopted 8 November 2025 as the opening date for final merit assessment, the Court declined to order a recalculation based on that date.

Source reference: paras. 38, 44, 47
05

Holding

The Court answered the principal issues against the Appellant.

It held that the adoption of 8 May 2026 as the commencement date for considering recent results in the final comparative selection did not amount to a retrospective alteration of the Selection Criteria, and that the Appellant’s earlier selection on 13 May 2026 had not concluded the process.

Source reference: paras. 43–44

While directing EFI to ensure greater clarity, transparency, and consistency in future selection processes, the Court found no ground to interfere with the Impugned Minutes, Impugned Resolution, or Selection Decision-II.

Source reference: paras. 45–48

The appeal was dismissed, all pending applications were disposed of, and there was no order as to costs.

Source reference: para. 49
Delhi High Court

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Vaasvi Khaitan (Minor) Thr Her Father Mr Vedant KhaitanvsAd-Hoc Committee For The Governance Of Equestrian Federation Of India & Ors.

Delhi High Court · September 24, 2026

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