Consistency Can't Be Reduced To Arithmetic Average Of Few Results Submitted By Rider: Delhi High Court Upholds YOG 2026 Equestrian Selection
The Court warned Equestrian Federation of India (EFI) that ambiguous selection criteria and procedural disputes adversely affect athletes' mental fortitude and preparation.
The Delhi High Court has held that consistency of sporting performance cannot be reduced to a mere arithmetical average derived from a few self-selected results, upholding the Equestrian Federation of India's methodology of ranking riders by total qualifying performances. The Bench, accordingly, dismissed an intra-court appeal by minor show-jumper Master Shubh Chowdhari against a Single Judge order, which had upheld his ranking for the 2026 Youth Olympic Games in Dakar.
Holding that the selection methodology was rational and uniformly applied, the Bench directed the EFI to frame future criteria with precision to avoid disputes. The Court remarked that selection ambiguity creates unnecessary uncertainty, adversely impacting an athlete's mental fortitude and event preparation.
A Division Bench of Chief Justice Devendra Kumar Upadhyaya and Justice Tejas Karia observed, “The central contention of the Appellant is that the riders ought to have been ranked by average penalties rather than by the number of qualifying performances. We are unable to accept this contention. Consistency ordinarily denotes the repetition of a prescribed standard of performance across a body of results; it cannot be reduced to an arithmetical average derived from however few results a rider elects to submit. An average based on a limited sample may unduly favour a rider who competes less frequently. We also note that the Appellant’s own computation has not remained consistent…This variation reinforces our conclusion that the average urged by the Appellant is not an objective standard emanating from the Selection Criteria, but a construct advanced to support a particular outcome”.
Advocate Manini Brar appeared for the appellant and Advocate Niyati Kohli appeared for the respondent.
“An athlete representing the country at an international sporting event must possess not only physical ability but also mental and emotional fortitude. It is, therefore, incumbent upon the selecting body to ensure that the selection process does not create avoidable uncertainty for the athletes concerned. Disputes arising from ambiguity in that process may themselves adversely affect an athlete’s preparation for the event. EFI shall, accordingly, ensure that future selection criteria and timelines are framed and implemented with sufficient clarity and precision to obviate disputes of this nature”, the Bench also observed.
Seven riders had obtained valid Certificates of Capability for the Show Jumping event, triggering a comparative selection process under criteria notified by the Federation, based on technical difficulty, consistency, recency of results, and overall merit. An initial selection decision ranking the appellant third, by giving priority to results achieved at a greater jump height, was challenged before the Single Judge and subsequently reconsidered by an enlarged Selection Committee.
A second selection decision, according equal weightage to jump heights, placed the appellant at Rank 2, behind another rider who recorded a greater number of qualifying performances within the assessment period. The appellant contended that rankings ought instead to have been based on average penalties across submitted results, under which he claimed to stand first.
The Single Judge dismissed the challenge, holding the second selection decision was neither mala fide, arbitrary, nor contrary to the notified criteria, prompting the present appeal.
The Division Bench held that the Selection Committee's methodology, comprising a fixed assessment period, equal weightage to jump heights, exclusion of incomplete rounds, and an eight-penalty qualifying threshold drawn from the FEI's own eligibility standard, was a permissible operationalisation of the notified criteria rather than an impermissible new criterion, and had been applied uniformly to all seven riders.
The Court found the appellant's own penalty computations had varied across his pleadings, undermining his claim that an average-based method was an objective standard. It further held that the selection minutes disclosed adequate contemporaneous reasons, and reaffirmed that courts do not sit in appeal over the comparative sporting assessments of expert selection committees, interference being warranted only where a decision is shown to be mala fide, perverse, or contrary to binding criteria.
Accordingly, the Court dismissed the appeal, affirming the selection decision, while directing the Federation to frame clearer criteria for future selections.
Cause Title: Master Shubh Chowdhari (through his father) v. Equestrian Federation of India & Ors. (Neutral Citation: 2026:DHC:8241-DB)
Appearances:
Appellant: Manini Brar, O.P. Harsh Singh Munday, Siddhant Chhabra, Advocates.
Respondent: Tanmaya Mehta, Niyati Kohli, Rishabh Parikh, Pinank Mehra, Isha Kakkar, Kartik Yadav, Sumedha Chadha, Duvva Pawan Kumar, Sai Krishna Kumar, Shradha Gupta, Kapil Modi, Shiv Verma, Shorya Goel, Advocates.