Delhi High Court
Administrative and Public LawConstitutional Law

Article 226 cannot compel alteration of a finalized sporting contingent absent an arbitrary eligibility determination.

Ankit Mer vs Union Of India & Ors.

Delhi High CourtJUDGMENT: September 25, 20263 MIN READSOURCE JUDGMENT
Article 226 cannot compel alteration of a finalized sporting contingent absent an arbitrary eligibility determination.. Ankit Mer vs Union Of India & Ors.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioners, Ankit Mer and Nitesh Singh, sought directions to the Union of India and other authorities to approve and financially support their participation in the 2026 Asian Games in Taekwondo, and to treat them as eligible athletes under the applicable selection criteria.

Source reference: p. 2, para. 1

The selection process involved India Taekwondo conducting trials, forwarding shortlisted names to the Indian Olympic Association (“IOA”), scrutiny by the Sports Authority of India (“SAI”), and final approval by the Ministry of Youth Affairs and Sports.

Source reference: p. 3, para. 2

India Taekwondo conducted open selection trials and forwarded the names of eight athletes, including the Petitioners, to the IOA.

Source reference: p. 3, para. 3

However, the Ministry stated that the Petitioners’ names were not included in the final list forwarded by the IOA for administrative clearance.

Source reference: p. 4, para. 5

The Ministry further relied on the applicable competition structure, under which the -54 kg and -58 kg categories were combined into one -58 kg category, with only one athlete per country permitted in that category.

Source reference: p. 4, para. 6

It also stated that Ankit Mer had not participated in the 2026 Asian Championship and therefore did not satisfy the eligibility criteria.

Source reference: p. 4, para. 6

The Respondents also submitted that no recognised National Sports Federation existed for Taekwondo, that the Ministry retained the final authority to approve athletes, and that the sanctioned contingent had already been finalised.

Source reference: p. 4, para. 7

The Asian Games had commenced on 19 September 2026, although the Taekwondo event was scheduled to commence on 1 October 2026.

Source reference: p. 5, para. 9
02

Issues

Whether the Petitioners were entitled to a direction requiring the Respondents to approve and financially support their participation in the 2026 Asian Games in Taekwondo after their names had been forwarded by India Taekwondo to the IOA.

Source reference: p. 3, paras. 3–4

Whether the exclusion of the Petitioners from the final contingent was arbitrary, discriminatory, or based on an unreasonable determination of their eligibility, warranting interference under Article 226 of the Constitution.

Source reference: p. 2, para. 1(c); p. 5, para. 10

Whether the Court could direct alteration of the already-finalised contingent and grant consequential administrative clearances when the Games had commenced.

Source reference: p. 5, paras. 9–11
03

Law Applied

The Court applied Article 226 of the Constitution, under which a writ of mandamus may issue against public authorities where a legal duty exists and its breach is established, but judicial review does not permit the Court to substitute its assessment for that of competent administrative authorities or subject experts.

Source reference: p. 5, paras. 8–10

Interference is justified where the decision is arbitrary, irrational, or reached without due application of mind; however, a finalised administrative decision concerning the composition of a sporting contingent will ordinarily be respected where it is objectively based on eligibility requirements, event regulations, and administrative feasibility.

Source reference: p. 5, paras. 8–10

The Court also applied the principle that no effective or meaningful relief should be granted where the relevant process has culminated and the claim has become a fait accompli.

Source reference: p. 5, para. 11
04

Reasoning

The Court accepted the Ministry’s explanation that the Petitioners’ names had never reached it in the final list submitted by the IOA and that subsequent scrutiny showed that they did not satisfy the applicable requirements.

Source reference: p. 5, para. 8

The Court also accepted the objective constraints arising from the Asian Games’ combined -54 kg and -58 kg category, the one-athlete-per-country limit, and the stated eligibility deficiency concerning Ankit Mer.

Source reference: p. 4, para. 6

Since the Ministry’s decision was not shown to be arbitrary or to have been made without due application of mind, the Court declined to reassess the authorities’ determination regarding the Petitioners’ inclusion in the contingent.

Source reference: p. 5, para. 10

Further, the contingent had already been sanctioned and the Games had commenced; granting the requested relief would have required multiple administrative clearances and alteration of the finalised contingent.

Source reference: p. 5, paras. 9–11

The Court therefore held that the requested relief had become practically ineffective and that the matter was a fait accompli.

Source reference: p. 5, paras. 9–11
05

Holding

The Court held that no ground was made out for exercising jurisdiction under Article 226 to interfere with the sanction order or to direct the Respondents to include and financially support the Petitioners in the 2026 Asian Games.

Both writ petitions were accordingly dismissed, and a copy of the order was directed to be placed in both matters.

Source reference: p. 6, paras. 13–14
Delhi High Court

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Ankit MervsUnion Of India & Ors.

Delhi High Court · September 25, 2026

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