The Delhi High Court has dismissed a batch of Letters Patent Appeals filed by the Chandigarh Horse Riders Society, affirming the Single Judge’s decision that exemptions granted by the Ministry of Youth Affairs and Sports (MYAS) to the Equestrian Federation of India (EFI) were arbitrary and contrary to the National Sports Development Code, 2011.
A Division Bench of Justice Anil Kshetarpal and JusticeHarish Vaidyanathan Shankar held that the Sports Code mandates a pyramidal governance structure, where voting and decision-making at the national federation level vest exclusively in recognised State and Union Territory Associations, and “club does not possess any statutory or legal entitlement to interfere with, participate in, or seek to influence the governance and administration of the sport at the national level.”
The appeals arose from challenges to two orders of a Single Judge, one quashing the MYAS communication dated 9 November 2021, granting temporary exemptions to EFI from key provisions of the Sports Code, and another staying the convening of an Extraordinary General Meeting (EOGM) of EFI.
A single-judge bench had held that while the Relaxation Clause under the Sports Code is neither arbitrary nor unreasonable, the specific exemptions granted to EFI were arbitrary and unsupported by any substantive factual foundation. The Court also directed the appointment of a five-member Fact Finding Committee. Via a separate order, the single judge bench had also stated that the notice purported to convene the Extra-Ordinary General Meeting (EOGM), and directed that the Appellant is restrained from holding the said EOGM.
This led to the filing of Letters Patent Appeals by the Chandigarh Horse Riders Society, before the Division Bench of the Delhi High Court, challenging both orders.
The Division Bench upheld the Single Judge’s stance that the exemptions granted to EFI were arbitrary and unsupported by any substantive factual foundation, holding that under the Sports Code, only recognised State and Union Territory Associations can participate in the governance of a National Sports Federation, and not club-level bodies.
The Bench rejected the justification advanced for granting exemptions to the EFI, holding that the capital-intensive nature of equestrian sport and the lack of equine infrastructure have no nexus with the exemptions granted. The Court noted that the relaxations related exclusively to the composition of the Electoral College, which are “matters of governance, not of sporting peculiarities.”
The Bench further dismissed the contention that horses should be treated as “athletes”, observing that such an assertion “stands negated by the Sports Code,” which classifies horses as equipment.
Turning to the broader framework of the Sports Code, the Division Bench held that the exemptions failed to address the central question of whether they conformed to the principles of transparency, accountability, and representation embedded in the Code. It observed that while each sport may have its own particularities, such differences do not warrant dilution of the uniform governance standards mandated by the Sports Code.
The Division Bench also upheld the Single Judge’s stay on the convening of the Extraordinary General Meeting of the EFI, holding that in view of the serious disputes surrounding the federation’s functioning and membership, and with the fact-finding inquiry still underway, permitting such a meeting would only aggravate the already unsettled situation.
Concluding that the appeals lacked merit, the Court dismissed them.
Appearances
Appellant- Mr. Amit Sibal and Mr. Vivek Chib, Sr. Advs. along with Mr. T. Singhdev, Mr. Bhanu Gulati, Mr. Pratham Mehrotra, Mr. Tanishq Srivastava, Mr. Abhijit Chakravarty, Ms. Yamini Singh, Ms. Anum Hussain, Ms. Ramanpreet Kaur, Mr. Sourabh Kumar, Mr. Vedant Sood, Mr. Siddharth Sunil and Mr. Zeeshan Thomas, Advs.
Respondents- Mr. Rajiv Dutta, Sr. Adv. along with Mr. Ashish Kothari, Mr. Pratha Pant and Mr. Pratyush Singh, Advocates for R-1. Mr. Sudhir Nandrajog, Sr. Adv. with Mr. Vinayak Bhandari, Mr. Ishaan Phukan, Ms. Ankita Singh, Mr. Asjad Hussain and Mr. Anunay Chowdhary, Advocates for R-3/EFI. Mr. Arti Bansal CGSC along with Mr. Rudra Paliwal, GP. Mr. Ishan Roy Chowdhury and Mr. Samar Bansal, Advocates for Observer. Mr. Satyajit Sarna and Mr. Aman Goyal, Advocates for applicant/intervenor.
