Scope of Judicial Review is Limited to Decision-Making Process in National Sports Selection.

The petitioners, two Dressage riders, challenged the selection list dated 16th June, 2026, issued by the Ad-hoc Committee of the Equestrian Federation of India (EFI) for the 20th Asian Games.

Both petitioners were placed in the "Reserve List" (Reserve 1 and 2) rather than the final four-member team.

Petitioner Agarwalla contended that a score from Hagen, Germany, should have been used for his Minimum Eligibility Requirement (MER) calculation instead of a score from Lier, Belgium, and alleged bias due to the presence of Mr. Kapil Modi in the selection team.

Petitioner Hajela challenged the merit calculation process, arguing that "Team MERs" (based on Prix St. Georges scores) should have been the primary ranking criteria rather than individual cumulative scores across three tests.

Both sought inclusion in the final team.

1. Whether the EFI's selection process and merit calculation, based on cumulative scores across three tests, was arbitrary or contrary to the Selection Criteria.

2. Whether the EFI was mandated to conduct additional inter-se trials among the six probables under Clause 15(b) of the Selection Criteria.

3. Whether the selection process was vitiated by bias or conflict of interest involving a member of the Selection Committee.

The court applied the principle of limited judicial review in sporting selections, holding that courts should not substitute their judgment for that of experts unless the decision is logically defiant or suffers from procedural impropriety, as established in Swastika Ghosh v. Table Tennis Federation of India.

It relied on Sushil Kumar v. Union of India and Karamjyoti v. Union of India, which mandate that National Sports Federations have discretion in selection unless exercised in an arbitrary or perverse manner.

Regarding bias and waiver, the court applied the doctrine from Manak Lal v. Dr. Prem Chand Singhvi, which holds that an objection to bias is waived if the party, despite knowing the facts, participates in the process without timely objection.

The court found that the EFI strictly followed Version 4.0 of its Selection Criteria. Regarding Agarwalla, the court noted that Clause 8(e) allows mixing scores from different events only if a single event lacks all three tests; since the Belgium event had all tests, the petitioner could not cherry-pick a higher score from Germany.

Regarding Hajela, the court interpreted Clauses 8(d) and 8(f), concluding that the EFI correctly used cumulative scores across all three tests (PSG, Intermediate I, and Freestyle) to ensure "complete competitive preparedness".

The court further reasoned that the failure to hold additional trials under Clause 15(b) was justified by the fact that all athletes were stationed across Europe and recent MERs already demonstrated their current form and fitness.

Finally, the court rejected the bias claim, noting that Agarwalla continued with the selection process for months after his initial informal objection via WhatsApp, thereby acquiescing to the Committee's composition.

The court answered that: 1) The merit calculation was rational and aimed at maximizing medal prospects; 2) The absence of inter-se trials did not vitiate the selection as the EFI exercised its power to address unforeseen logistical hurdles under Clause 15(e); and 3) The allegation of bias was precluded by the principle of waiver.

The final selection list dated 16th June, 2026, was upheld.