Supreme Court declines interim relief to riders challenging India's Dressage team selection for Asian Games

The Supreme Court of India recently declined to grant interim relief to two prominent dressage riders, Anush Agarwalla and Sudipti Hajela, who challenged their exclusion from India's Dressage team for the 2026 Asian Games. This decision upheld the Delhi High Court's refusal to interfere with the selection, despite both courts acknowledging procedural lapses and "undue haste" by the Equestrian Federation of India (EFI). While dismissing the individual pleas, the Supreme Court signaled a significant shift, stating it would examine the broader issue of institutionalising the selection process for national sports federations (NSFs) to ensure transparency and fairness, rather than adjudicating individual selection disputes at the eleventh hour. This development underscores the judiciary's evolving approach to sports governance in India, balancing judicial restraint with the imperative for systemic reform.

In a recent and significant development for sports law in India, the Supreme Court has opted for systemic reform over individual intervention in a challenge to the national Dressage team selection for the 2026 Asian Games. On Monday, a Bench of Justices P.S. Narasimha and Alok Aradhe declined interim relief to two aggrieved riders, Anush Agarwalla and Sudipti Hajela, who sought to overturn their exclusion from the final squad. This decision affirmed the Delhi High Court's earlier stance, which, despite identifying procedural irregularities by the Equestrian Federation of India (EFI), had also refrained from disrupting the team composition due to practical considerations.

The case highlights a recurring tension in Indian sports jurisprudence: the judiciary's traditional reluctance to interfere with the technical decisions of expert sporting bodies versus the constitutional imperative to ensure fairness, transparency, and adherence to established procedures. While the immediate outcome means no change for the individual petitioners, the Supreme Court's commitment to examining the "larger issue of institutionalising the selection process" marks a pivotal moment. This article will delve into the Court’s rationale, the underlying legal framework governing sports selections, and the broader implications for national sports federations and athletes in India.

The selection of national teams in India is primarily governed by the National Sports Development Code of India, 2011 (NSDC 2011), which provides a framework for the functioning of National Sports Federations (NSFs). The NSDC 2011 mandates NSFs to adopt impartial and transparent selection procedures, ensure good governance, and promote accountability to maintain their recognition and eligibility for government funding. While NSFs are considered autonomous bodies, the Supreme Court of India and various High Courts have consistently held that they fall within the writ jurisdiction under Article 226 of the Constitution, as they perform "state-like functions" such as selecting national teams and representing the country internationally.

The present dispute arose from the EFI's selection process for the 2026 Asian Games Dressage team. Dressage, an equestrian discipline, requires horse-rider combinations to perform precise, predetermined movements. The EFI's selection criteria typically involve Minimum Eligibility Requirements (MERs) and specific scores in designated trials. Petitioners Anush Agarwalla and Sudipti Hajela, both gold medalists from the 2022 Asian Games, challenged their placement on the reserve list, alleging that the EFI had failed to comply with its own selection criteria and acted with "undue haste" in finalising the team. The Delhi High Court, in its July 6 judgment, acknowledged these procedural lapses but declined to interfere with the final selection, citing the imminent July 15 deadline for submitting the team to the Asian Games authorities and the impracticality of conducting fresh trials.

The Supreme Court's decision to deny interim relief, while seemingly a setback for the individual riders, reflects a long-standing judicial principle of restraint in interfering with the technical aspects of sports selections. The Bench explicitly stated its reluctance to "keep interfering in sports," particularly when individual challenges are brought at the "last stage" before major international events. This approach aligns with previous judicial pronouncements that courts are not equipped to act as appellate authorities over expert sporting bodies and should not substitute their judgment for that of technically qualified selectors, absent clear illegality, irrationality, or procedural unfairness.

However, the Court's decision is not an endorsement of the EFI's conduct. Both the Delhi High Court and the Supreme Court acknowledged the procedural irregularities. The Delhi High Court had found that the EFI "failed to duly comply with certain clauses of the selection criteria" and acted with "undue haste." Its refusal to intervene was primarily driven by the practical exigencies of the impending Asian Games deadline, fearing that a fresh selection process could jeopardise India's participation. This highlights a critical dilemma: how to enforce procedural fairness without undermining national sporting interests.

The Supreme Court's directive to examine the "larger issue of institutionalising the selection process" is a crucial development. This indicates a shift from *ex post facto* individual adjudication to *ex ante* systemic reform. The Court's focus on institutionalisation aligns with the objectives of the NSDC 2011, which mandates NSFs to adopt transparent selection procedures. Furthermore, the Ministry of Youth Affairs and Sports (MYAS) has recently reinforced these requirements, directing all recognised NSFs to publish their selection criteria and processes for major events, including the Asian Games, at least two years in advance to promote transparency and accountability. The Court's intervention, therefore, seeks to strengthen the foundational governance mechanisms, aiming to prevent such disputes from arising in the first place by ensuring robust, transparent, and consistently applied selection policies across all NSFs.

For practising attorneys and legal professionals in India, this Supreme Court ruling offers a nuanced perspective on judicial intervention in sports. While individual challenges to team selections, especially close to major events, face a high bar for interim relief, the judiciary remains committed to ensuring the integrity of the selection process itself. The Court's clear pronouncement that "the individual cases chapter is closed" but the "institutionalisation" aspect will be examined, signals a strategic pivot towards systemic reform.

This development places a renewed onus on National Sports Federations to meticulously review and adhere to their selection criteria, ensuring transparency, objectivity, and compliance with the National Sports Development Code of India, 2011, and MYAS guidelines. Practitioners advising NSFs should emphasise proactive measures, including timely publication of detailed selection policies and robust internal grievance mechanisms, to mitigate future legal challenges. Conversely, athletes and their representatives should focus on advocating for and participating in the institutional reform process, as the Supreme Court's eventual guidance on this "larger issue" could significantly reshape the landscape of sports governance and athlete rights in India.