Court Upholds Merit-Based Selection Despite Procedural Non-Compliance Where Time Constraints Render Fresh Selection Trials Impracticable

In brief

The question

1. Whether the EFI prepared the Selection List in strict conformity with the published Selection Criteria and its subsequent Amendment

The court held

The court held that while EFI committed procedural lapses by failing to follow Clauses 15(a) and 15(b), the underlying merit list was prepared rationally according to the technical hierarchical rules of Individual vs. Team MERs.

It also directed

The court declined to interfere with the Selection List because the 15.07.2026 entry deadline made fresh trials logistically "impracticable". The court dismissed the appeals, permitting the current team to proceed in the national interest while directing EFI to strictly comply with Selection Criteria in the future.

01Facts

The Appellants, international Dressage riders, challenged their placement in the "Reserve List" for the 20th Asian Games (Japan, 2026) by the Equestrian Federation of India (EFI).

pp. 2-3

The Selection Criteria (Version 4.0) prescribed Minimum Eligibility Requirements (MER) based on horse-rider performance in three tests: Prix St. Georges (PSG), Intermediate-I, and Intermediate-I Freestyle.

pp. 3-4

EFI issued an Amendment on 17.04.2026, requiring at least one MER during a "Peak-window" (17.04.2026–15.06.2026).

pp. 6-7

On 16.06.2026, EFI published a Selection List placing the Appellants as Reserves 1 and 2.

p. 7

The Appellants alleged EFI bypassed mandatory procedures under Clause 15(b)—which required a Training Period and further competitions for "Probables" before finalization—and improperly calculated merit.

pp. 11-12, 16

A Single Judge dismissed their Writ Petitions on 29.06.2026, leading to these appeals.

p. 2, 8

02Issues

i.1. Whether the EFI prepared the Selection List in strict conformity with the published Selection Criteria and its subsequent Amendment

p. 31/para. 31

ii.2. Whether the non-compliance with the mandatory Training Period competitions under Clause 15(b) vitiates the final Selection List

p. 31/para. 33

iii.3. Whether the comparative merit assessment between horse-rider combinations was conducted rationally based on Team vs. Individual MER categories

pp. 36/para. 47-49

03Law Applied

The court applied the principle of limited judicial review in sporting selections, establishing that courts will not sit in appeal over expert committees unless decisions are arbitrary or contrary to law.

p. 31/para. 32

It interpreted Clause 13(g) and 8(f) of the Selection Criteria, which mandate that combinations with "Individual MERs" rank higher than those with only "Team MERs".

p. 4, 36

Clause 13(d) was applied to resolve ties in the same MER category based on the highest cumulative percentage scores.

p. 5, 38

The court also noted the power to amend criteria under Clause 15(f) in "compelling circumstances".

p. 6, 34

Provisions in the judgment · 7

National Sports Development Code of India, 2011 Selection Criteria

Code of Civil Procedure, 1908 Section 148A

Competition Commission of India (Term of the Selection Committee and the Manner of Selection of Panel of Names) Rules, 2008 Section 5Section 8Section 13Section 15Section 19

04Reasoning

The court found that EFI failed to comply with Clause 15(b), as it did not conduct the mandatory competitions for "Probables" during a Training Period to finalize merit.

pp. 32-33/para. 38

EFI’s justifications—paucity of time and the "Peak-window" amendment—were found insufficient because EFI failed to formally invoke its amendment powers under Clause 15(f) to dispense with these trials.

pp. 34/para. 42-43

Regarding merit calculation, the court held that Rank Nos. 1-3 were correctly placed because they achieved "Individual MERs," which are contractually superior to the "Team MERs" achieved by the Appellants.

p. 36/para. 47

It rejected Mr. Agarwalla’s claim for higher ranking because his best scores from CDI Hagen were invalid due to non-participation in all three mandatory tests (PSG, Int-I, Int-I Freestyle).

pp. 37/para. 51-52

For Ms. Hajela, the court held that among those with Team MERs, Mr. Chheda was correctly ranked higher under Clause 13(d) due to a superior cumulative aggregate score across all three tests.

p. 38/para. 54