The Delhi High Court has refused to disturb the Asian Games Dressage Selection List after holding that a fresh competition among Probables could not practically be conducted before the entry deadline, particularly when riders and horses were located in different places across the globe.

The Court was hearing appeals filed by international Dressage riders Anush Agarwalla and Sudipti Hajela, challenging the dismissal of their writ petitions against the selection list issued by the Ad-Hoc Committee of the Equestrian Federation of India for the Dressage Event at the 20th Asian Games in Japan.

A Bench of Chief Justice Devendra Kumar Upadhyaya and Justice Tejas Karia held: “Having regard to the deadline of 15.07.2026, it is logistically impracticable to conduct a further competition within the time available, particularly since the riders and horses are located at different places across the globe and transporting horses from different locations to a common venue for conducting a competition amongst all six (6) Probables would not be possible in such a short span of time.”

The Court further added: “Having regard to the peculiar facts and circumstances of the present case and considering the limited time available before the deadline of 15.07.2026, we are constrained to refrain from interfering with the Impugned Judgment. Such restraint is warranted in the larger interest of the sport and to avoid any adverse impact on the prospects of the Indian Team participating in the Dressage Event at the Asian Games.”

Senior Advocate Rahul Mehra appeared for Anush Agarwalla, while Advocate Tanmay Mehta appeared for the Ad-Hoc Committee.

Background

The dispute arose from the selection process adopted for India’s Equestrian Dressage Team for the Asian Games. EFI had issued Selection Criteria prescribing qualifying requirements, Minimum Eligibility Requirements, ranking of horse-rider combinations, and preparation of a list of six Probables.

Under the Selection Criteria, Dressage involved Team and Individual competitions. Riders were to be assessed on valid MER-level results, with the best two valid results considered for comparative merit. The Selection Criteria also contemplated that selected combinations would remain Probables until EFI, in consultation with the Selection Committee and coaches, reviewed the process before final entries.

Anush Agarwalla and Sudipti Hajela were included in the Selection List as reserves. They challenged the selection, contending that EFI had failed to publish the provisional merit list, had not conducted competitions during the Training Period as contemplated under Clause 15(b), and had submitted final entries without following the final-stage process prescribed by the Selection Criteria.

The Single Judge declined to interfere with the Selection List. The riders then preferred appeals before the Division Bench.

Court’s Observation

The Court examined the Selection Criteria, particularly Clauses 8, 13 and 15, the ranking of horse-rider combinations on valid MERs, the requirement of further review and competitions during the Training Period, and the limited scope of judicial interference in selection for international sporting events.

The Court first clarified that courts do not sit in appeal over decisions of expert selection bodies in sporting matters and do not reassess relative merit unless the decision is arbitrary, irrational, perverse or contrary to law.

The Court observed: “It is well settled that Courts do not sit in appeal over the decisions of selection committees, nor do they reassess the relative merits of candidates. The determination as to who should represent the country in an international sporting event is ordinarily best left to experts in the field. In matters concerning selection for international competitive events, the Court would not ordinarily interfere with the selection criteria framed by the concerned expert body, or with the manner in which relative merit is evaluated, unless the decision is shown to be arbitrary, irrational, perverse or contrary to law.”

The Court found that after preparation of the order of merit of Probables, the Selection Criteria contemplated a subsequent stage for final team selection under Clause 15(b).

The Bench noted: “The aforesaid provisions of the Selection Criteria make it evident that, upon preparation of the order of merit of the Probables, the subsequent stage is the selection of the Final Team in the manner contemplated under Clause 15(b) thereof. In the present case, it is apparent that the Selection Committee did not undertake the process prescribed for selection of the Final Team in terms of the provision contained in Clause 15(b).”

The Court further remarked: “Under this circumstance, EFI appears to have acted with undue haste without complying with the procedure required to be followed for preparation of the Selection List. The reasons advanced by EFI for non-compliance with the mandatory requirements of the Selection Criteria are, firstly, paucity of time, having regard to the limited window available for participation in qualifying events and selection of the Probables, and secondly, the futility of conducting an inter se competition amongst the six (6) Probables, since the Amendment to the Selection Criteria had introduced validation of recent performance by requiring at least one (1) MER during the Peak-window between 17.04.2026 and 15.06.2026 thereby objective of assessing the current fitness and form of the Probables stood substantially achieved.”

The Bench added: “The aforesaid reasons do not inspire confidence as when the Amendment was introduced, EFI was fully aware of the existing requirements under Clauses 15(a) and 15(b) of the Selection Criteria; nevertheless, those provisions were not modified. Further, when the list of Probables was prepared on 16.06.2026, the Ad-Hoc Committee was also aware of Clause 15(f), which empowered EFI to amend the Selection Criteria in compelling circumstances. However, the said power was not invoked. In any event, Clause 15(f) merely confers a power to amend the Selection Criteria and does not empower EFI to dispense with compliance therewith.”

Although the Court found non-compliance with Clauses 15(a) and 15(b), it did not find infirmity in the preparation of the list of Probables under Clause 13. It noted that selected candidates placed at Rank Nos. 1, 2 and 3 had attained Individual MERs, which were placed higher in merit than Team MERs under the Selection Criteria.

The Court rejected Anush Agarwalla’s contention that only the PSG score was relevant for Team selection.

The Court stated: “Further, the submission of Mr. Anush Agarwalla that only PSG score was relevant as per the Selection Criteria for the selection in the Team as minimum 66% score was required to be achieved for the PSG test and participation in Intermediate-I and Intermediate-I Freestyle, is not in consonance with the Selection Criteria, which provided that all three (3) tests have to be taken into consideration for determining the MER. Therefore, consideration of only the PSG score for the Team selection cannot be accepted.”

The Court also rejected the argument that scores from different events could be selectively combined. It accepted EFI’s stand that a valid MER could be considered only where the rider had participated in all three tests in a single event, unless the event itself did not include any of the required tests.

The Bench underscored: “We also find merit in the submission of EFI that the rider cannot pick and choose the scores from different events, and a valid MER can be considered only if the rider has participated in all the three (3) tests in a single event unless that event did not have any of the tests contemplated fulfillment of MER. As CDI Hagen Trial had all three (3) tests available and it is only because Mr. Anush Agarwalla could not participate due to cut near the mouth of his horse, the same cannot be considered for determining valid MER.”

The Court held that ideally the list of Probables ought to have been prepared sufficiently in advance to allow competitions during the Training Period and permit the Selection Committee to take a final call in terms of Clauses 15(a) and 15(b). However, since the list was finalised only after the window for participating in eligible competitions had closed, there was insufficient time to conduct another competition.

Conclusion

The High Court disposed of the appeals without interfering with the judgment of the Single Judge or the Selection List. However, it directed EFI to strictly comply with the Selection Criteria henceforth.

Cause Title: Anush Agarwalla v. Ad-Hoc Committee For Governance Of Equestrian Federation Of India And Ors. (Neutral Citation: 2026:DHC:5375-DB)

Appearances

Appellants: Senior Advocate Rahul Mehra with Advocates Astha Sharma, Anju Thomas, Mantika Haryani, Pratibha Yadav, Bhanu Mishra, Jyotika, Chaitanya Gosain and H. Chimthanawala; Senior Advocate Kirtiman Singh with Advocates Kritika Gupta, Mohit Kumar Sharma, Ritwik Saha and M. Khurana

Respondents: Advocates Tanmay Mehta, Kapil Modi, Niyati Kohli and Rishabh Parikh; Additional Solicitor General Chetan Sharma with Senior Panel Counsel Udit Dedhiya and Advocates Amit Gupta, R.V. Prabhat, Shubham Sharma, Yash Wardhan Sharma, Apurva Sachdev and Priyansh Gupta; Advocates Kumudavalli Seetharaman and Geetika Vyas with George Mathew, Director IOA; Advocate Shiv Verma; Advocates Kirat Singh Nagra, Kartik Yadav and Sumedha Chadha

Click here to read/download Judgment

Tags: