Courts cannot substitute expert sporting assessments absent arbitrariness, perversity, mala fides, or illegality.

The petitioner, an equestrian athlete, challenged the Equestrian Federation of India’s fresh selection decision dated 27 August 2026 for the Show Jumping event at the Youth Olympic Games 2026.

The Fédération Équestre Internationale had prescribed eligibility requirements and competition regulations, including a Certificate of Capability and classification primarily by penalty points and time.

By Selection Decision-II dated 27 August 2026, respondent no. 3 was retained as the selected rider and the petitioner was upgraded to reserve rider.

EFI treated completed rounds involving not more than eight penalty points as qualifying performances, considered results at both 130 cm and 135 cm with equal weightage, and found that respondent no. 3 had five qualifying performances against the petitioner’s four.

1. Whether the Selection Committee correctly applied EFI’s notified selection criteria while assessing the eligible riders’ performances, particularly consistency, recency and comparative merit.

2. Whether the Committee was required to consider every performance during the relevant period, including performances involving more than eight penalty points.

3. Whether the Committee was bound to assess consistency and comparative merit by calculating the average penalty points secured by each rider.

4. Whether the impugned selection decision was arbitrary, perverse, mala fide, contrary to the notified criteria or otherwise amenable to interference under Article 226 of the Constitution.

The Court applied the principle that judicial review under Article 226 examines the legality and rationality of the decision-making process, not the correctness of the expert assessment on merits.

Relying on Union Public Service Commission v. M. Sathiya Priya, (2018) 15 SCC 796, the Court held that assessment by an expert committee should not be interfered with absent bias, mala fides or arbitrariness.

It relied on Tajvir Singh Sodhi v. State of Jammu & Kashmir, (2023) 17 SCC 147, for the rule that courts cannot assume an appellate role over the evaluation undertaken by selection bodies.

The Court also followed Shumel v. Union of India, 2010 SCC OnLine Del 4706; Sushil Kumar v. Union of India, 2016 SCC OnLine Del 3660; Sujeet v. Union of India, 2023 SCC OnLine Del 5801; and Anush Agarwalla v. Ad-Hoc Committee for Governance of Equestrian Federation of India, 2026 SCC OnLine Del 4965, which recognise that selection of sportspersons for international events is ordinarily best left to expert bodies, subject to judicial review for arbitrariness, perversity, illegality or mala fides.

The Court held that EFI’s criteria identified the relevant factors but did not prescribe a particular formula, weighting system or requirement that the lowest average penalty score must determine ranking.

The Committee’s decision to treat completed rounds involving not more than eight penalty points as qualifying performances was applied uniformly to all riders; consequently, respondent no. 3’s results involving 12 and 20 penalty points were not selectively excluded, and comparable non-qualifying results of other riders were also disregarded.

The Court further found that the Committee had removed the earlier preference for 135 cm results, given equal weight to 130 cm and 135 cm performances, and uniformly assessed the riders during the period from 8 May to 25 July 2026.

The petitioner’s average-penalty method was considered a possible method of assessment, but not one mandated by the notified criteria.

The Court reasoned that consistency could reasonably be assessed by reference to the number and spread of qualifying performances, the level of events, repeated completion of qualifying rounds, recency, course height and the horse–rider combination.

Determining the relative importance of these factors required sporting expertise and did not justify judicial substitution of the Court’s view for that of the Selection Committee.

Since the petitioner failed to establish unequal treatment, irrelevant considerations, mala fides, perversity or manifest arbitrariness, the Selection Decision-II did not warrant interference.

It held that EFI had applied the notified selection criteria uniformly, was not required to use the petitioner’s proposed average-penalty formula, and had acted within the permissible domain of expert sporting assessment.

The Court found no mala fides, arbitrariness, perversity, illegality or violation of the notified criteria warranting judicial interference under Article 226.

Pending applications were also disposed of.