Interim Orders Deferring Substantive Relief Pending Affidavits Do Not Constitute Appealable Judgments Under Letters Patent

The Appellant, an Indian Karate athlete, filed a Writ Petition seeking a fair and transparent selection mechanism for the 2026 Asian Games and the 22nd Asian Senior Karate Championship

The grievance arose from the absence of a recognized National Sports Federation (NSF) for Karate in India due to governance disputes

Although the Ministry of Youth Affairs and Sports directed the Indian Olympic Association (IOA/Respondent No. 2) on 23.02.2026 to form an Ad-Hoc Committee for selections, the World Karate Federation (WKF) opposed such a committee, stating it would not recognize athletes selected by it

On 29.05.2026, a learned Single Judge declined to issue urgent protective directions after being informed that the entry deadline for the Asian Games had expired and no names had been sent. The Appellant challenged this inaction via the present Letters Patent Appeal (LPA)

The Court primarily applied Clause 10 of the Letters Patent of the High Court of Delhi, which governs the maintainability of intra-court appeals against a "judgment" of a Single Judge

It also relied on the National Sports Development Code of India and the administrative principle that the interests of athletes must remain paramount over governance disputes

The court examined the doctrine of "judgment" in the context of appealability, determining whether an interim order that merely seeks affidavits and fixes a date qualifies as an appealable decision

The Court analyzed the correspondence between the IOA and the WKF (dated 26.02.2026 and 27.02.2026), observing that the IOA had indeed attempted to comply with the Ministry’s order to form an Ad-Hoc Committee

However, the WKF's express refusal to recognize any selection made through such a body created a regulatory deadlock

Regarding maintainability, the Bench reasoned that the Impugned Order dated 29.05.2026 was merely a procedural direction requiring the Respondents to file affidavits; it did not decide any substantive rights or liabilities of the parties

Thus, the order did not satisfy the criteria of a "judgment" under Clause 10 of the Letters Patent

Furthermore, the Court noted that the Single Judge had already directed the Respondents to endeavor to provide a selection mechanism in a previous order dated 19.05.2026, which remains the presiding directive

The Court observed that athletes should not suffer due to administrative inaction or unresolved governance issues [p. 6]. It directed the Respondents to continue efforts to provide an appropriate selection mechanism for international entries in Karate until a recognized NSF is constituted, in line with the Single Judge's earlier directions [p. 6]. The Appeal and all pending applications were dismissed without costs