Delhi High Court
Administrative and Public LawSports Law

Vacant quota slots do not confer participation rights absent satisfaction of notified selection criteria.

Prashant Sudarshan Arkal & Ors. vs Union Of India & Ors.

Delhi High CourtJUDGMENT: October 13, 20262 MIN READSOURCE JUDGMENT
Vacant quota slots do not confer participation rights absent satisfaction of notified selection criteria.. Prashant Sudarshan Arkal & Ors. vs Union Of India & Ors.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, five para-cyclists, challenged the Union’s sanction order dated 1 October 2026, which approved only one para-cyclist for the Indian contingent at the 2026 Asian Para Games, despite their unanimous selection by a Selection Committee.

Source reference: p. 1–4, paras. 1–7

They contended that they met the relevant eligibility requirements, that vacant quota slots remained, and that they should be permitted to compete at their own expense.

Source reference: p. 1–4, paras. 1–7

The respondents relied on the Ministry’s selection criteria, including performance benchmarks for measurable sports, and argued that the petitioners did not qualify.

Source reference: p. 1–4, paras. 1–7

The Court considered the applicable criteria and the petitioners’ performances at relevant competitions.

Source reference: p. 4–7, paras. 8–15
02

Issues

1. Whether the exclusion of the petitioners from the sanctioned contingent, despite available quota slots, was arbitrary or otherwise warranted interference under Article 226.

Source reference: p. 7–8, paras. 15–16

2. Whether the petitioners could participate in the event at their own expense despite not being cleared as part of the government-funded contingent.

Source reference: p. 8, para. 17
03

Law Applied

Article 226 permits judicial review of decisions concerning athlete selection, but the Court will not direct authorities to alter a finalised contingent or substitute its assessment for that of the responsible authorities and subject experts unless their decision is arbitrary.

Source reference: p. 8, para. 16

Under the Ministry’s circular dated 24 September 2025, athletes in measurable sports must satisfy the prescribed performance benchmarks; where participation in the Asian Championship is limited, the applicable ranking cut-offs are determined by the number of competing countries.

Source reference: p. 4–6, paras. 9–13

A quota slot sets the maximum number of permitted entries and does not itself confer a right to participate.

Source reference: p. 8, para. 15

Clause 12 of the circular provides that only athletes cleared at government expense may form part of the Indian contingent.

Source reference: p. 8, para. 17
04

Reasoning

The Court accepted the respondents’ explanation that the petitioners’ performances did not satisfy the applicable selection criteria and that the authorities had assessed their results against the prescribed benchmarks.

Source reference: p. 6–8, paras. 14–16

It held that the availability of unfilled quota slots could not cure ineligibility or create an entitlement to selection. The Court found no basis to treat the authorities’ assessment as arbitrary and declined to substitute its own view of the petitioners’ medal prospects.

Source reference: p. 6–8, paras. 14–16

It also rejected participation at private expense because Clause 12 restricted membership of the Indian contingent to athletes cleared at government expense; further, the contingent had already been finalised and acted upon.

Source reference: p. 8, paras. 15–18
05

Holding

The Court held that no ground for interference under Article 226 had been established.

It declined to set aside the sanction order or permit the petitioners to participate at their own expense, and dismissed the petition and pending applications.

Source reference: p. 8, paras. 19–20
Delhi High Court

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Prashant Sudarshan Arkal & Ors.vsUnion Of India & Ors.

Delhi High Court · October 13, 2026

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