Courts cannot reassess expert sports selections absent arbitrariness, perversity, mala fides, or illegality.

The Appellant, Master Shubh Chowdhari, was one of seven Indian riders who obtained a Certificate of Capability (“COC”) for participation in the Show Jumping event at the Youth Olympic Games, Dakar, 2026 (“YOG 2026”).

EFI’s notified selection criteria required consideration of technical difficulty and level of competitions, consistency of international performance, recency, stability of the horse-rider combination, championship readiness, competitiveness at CSI1*/CSI2* events, and overall merit.

After the Appellant submitted his recent competition results, EFI initially ranked Respondent No. 3 first, Respondent No. 4 second, and the Appellant third, giving preference to performances at 135 cm over those at 130 cm.

Following the Appellant’s challenge, EFI reconsidered the selection. A reconstituted five-member Selection Committee assessed results between 8 May and 25 July 2026, treated 130 cm and 135 cm results equally, and regarded a completed round involving not more than eight penalties as a “qualifying performance”.

Under Selection Decision II dated 27 August 2026, Respondent No. 3 was ranked first, the Appellant second, and Respondent No. 4 third. The Appellant challenged the decision, contending that EFI had unlawfully introduced the undisclosed criterion of the number of qualifying performances and that he ought to have been ranked by reference to average penalties.

The learned Single Judge dismissed the writ petition, holding that the decision was neither mala fide, arbitrary, perverse, nor contrary to the notified criteria. The Appellant consequently preferred the present appeal.

Whether EFI’s use of the number of qualifying performances, based on completed rounds with not more than eight penalties, constituted an impermissible alteration or introduction of selection criteria after commencement of the selection process?

Whether the Appellant was entitled to have the riders ranked by reference to average penalty points rather than the number and consistency of qualifying performances?

Whether Selection Decision II was inadequately reasoned, arbitrary, perverse, mala fide, or contrary to the notified selection criteria so as to warrant judicial interference?

Whether the enlargement of the Selection Committee from three to five members invalidated the reconsideration process?

The Court applied the principle that judicial review of expert sports-selection decisions is limited and that courts do not sit in appeal over comparative sporting merit or substitute their own assessment for that of a duly constituted expert committee; interference is justified only where the decision is mala fide, arbitrary, irrational, perverse, or contrary to binding criteria, as recognised in Dalpat Abasaheb Solunke v. B.S. Mahajan, Basavaiah v. H.L. Ramesh, Sushil Kumar v. Union of India, and Anush Agarwalla v. Ad-Hoc Committee for Governance of Equestrian Federation of India.

The Court further applied the principle that reasons must be tested on the basis of the reasons contemporaneously recorded and cannot ordinarily be supplemented by subsequent explanations.

Chirag Khandal v. Equestrian Federation of India was distinguished as prohibiting a change in an existing criterion, while Manjeet v. Indian Olympic Association was distinguished as involving departure from a binding international qualification system.

The Court held that a selection body may adopt a reasonable and uniform methodology to operationalise broadly notified criteria such as consistency, competitiveness, recency, and overall merit, provided that the methodology is rational, non-discriminatory, and applied equally to all candidates.

The Court distinguished between the notified criteria and the methodology used to implement them. The criteria required assessment of consistency, competitiveness, technical level, recency, and overall merit, but did not prescribe the precise assessment period, treatment of incomplete rounds, or method of evaluating consistency.

The Selection Committee’s methodology—using the period from 8 May to 25 July 2026, giving equal weight to 130 cm and 135 cm results, excluding incomplete two-phase competitions, and treating completed rounds with not more than eight penalties as qualifying performances—was held to be a permissible operationalisation of the notified criteria rather than a new criterion.

The eight-penalty threshold was objectively connected to the FEI’s COC standard, had also been relied upon by the Appellant to demonstrate consistency, and was applied uniformly, including to exclude the Appellant’s own 12-penalty result.

The Court rejected ranking by average penalties because an average based on a smaller number of selected results could favour a rider who competed less frequently and did not necessarily establish repeated consistency. The Appellant’s own calculations also varied depending on which result was included or excluded.

The Minutes disclosed the assessment period, competition formats, treatment of two-phase events, qualifying-performance methodology, and comparative ranking, and therefore supplied adequate contemporaneous reasons.

The Court found no rule prohibiting enlargement of the Selection Committee from three to five members. The reconstitution followed the Appellant’s own objection to the original Committee, and he participated in the reconsideration through his father without objecting to the Committee’s composition.

Since the methodology was uniformly applied and no mala fides, perversity, arbitrariness, or violation of binding criteria was established, judicial substitution of the Court’s assessment for that of the expert Selection Committee was impermissible.

Ranking by average penalties was not mandated by the criteria, and the Selection Decision was supported by adequate contemporaneous reasons.

The appeal was dismissed, the judgment of the learned Single Judge dated 17 September 2026 was upheld, and all pending applications were disposed of without an order as to costs.

The Court nevertheless directed EFI to frame and implement future selection criteria and timelines with greater clarity and precision to avoid uncertainty and repeated litigation.