“Delhi High Court Dismisses Appeal, Holds Selection Trials ‘Irrational and Unfair’ Where Quota Already Earned by Ranking”
Kiran Raj
In a significant judgement delivered on March 27, 2025, the Division Bench of the High Court of Delhi at New Delhi, comprising Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela, dismissed an appeal filed by the Roller-Skating Federation of India. The appeal challenged a previous judgment restraining the Federation from conducting selection trials for the Speed Slalom - Senior Ranked Men category for the World Games 2025 scheduled to be held in Chengdu, China.
The Bench upheld the single judge's decision which had granted relief to the respondent, an athlete, and directed that no further selection trials be held for the specified event category.
The Roller-Skating Federation of India, a recognized National Sports Federation (NSF) for roller skating, issued a notification dated January 24, 2025, calling for selection trials for Indian participation in the Speed Slalom - Senior Ranked Men category in the World Games 2025, scheduled between August 7 and August 17, 2025, in Chengdu, China.
The respondent, Sanchit Bhandari, approached the court through a writ petition (W.P.(C) No.1413/2025), seeking to quash the notification on the grounds of prejudice. He contended that his 10th-place ranking in the Italy Games 2024 in the said category had already secured India's qualification and that he should not be subjected to another selection trial.
The Single Judge cited in Bhandari's favor, prompting the NSF to file the current Letters Patent Appeal (LPA 219/2025).
Counsel for the appellant, Mr. Dhruv Gautam, argued that a considerable time had elapsed since the Italy Games 2024, and fresh trials were necessary to assess current performance. He submitted that another skater, Mr. Nanal Jinesh Satyam, held a better current ranking (10th) compared to respondent no.1 (63rd) as per the 2024 World Skate Body rankings.
It was further argued that respondent no.1 would not suffer prejudice by participating in a fresh trial. Counsel pointed to the communication dated October 1, 2024, from the World Skate Body, arguing that the quota earned through the Italy Games 2024 was allocated to the NSF, not to an individual athlete. The Federation thus retained the discretion to select the athlete through trials.
The Federation also submitted that it had conducted similar selection trials for other events and that the process, usually video graphed, ensured transparency. Referring to the Italy Games 2024 results, counsel argued that respondent no.1 and Mr. Satyam were ranked 10 and 13 respectively at that time. However, subsequent rankings placed respondent no.1 at 63rd, while Mr. Satyam remained in the top 10.
Counsel for the respondent, Mr. Utsav Jain, defended the Single Judge's judgement. He argued that India’s qualification for the Chengdu Games 2025 in the Speed Slalom - Senior Ranked Men category was a direct result of respondent no.1’s 10th-place ranking at the Italy Games 2024. He contended that the quota earned must benefit the athlete who secured it and that subjecting the respondent to re-selection would be unjust and demotivating.
The respondent's counsel argued that the ranking should ensure to the benefit of the athlete personally, not to the NSF generally. He submitted that requiring respondent no.1 to undergo further trials was irrational and contrary to the selection criteria.
The Division Bench examined the materials and concluded that the Single Judge’s findings required no interference. It stated: "the facts propel the decision that asking respondent no.1 to undergo the trials for selection in his particular sports events would be irrational, arbitrary and unfair."
The court referred extensively to the qualification bulletin issued by the World Skate Body. Quoting from the bulletin, it noted:
"The World Skate Games - Italy 2024 will grant twenty-four (24) quotas in September 2024... The obtained quotas are allocated to National Federations, which shall select and register athletes by March 30th 2025."
However, the court observed that this general rule is subject to the specific provisions of paragraph A, which explicitly states:
"Speed Slalom - six (6) best Senior ranked men" and "In case a National Federation has already completed its country quota, the next skater in the ranking from a different country will earn the slot."
Interpreting these clauses, the Bench stated: "The aforesaid specifications leave no manner of doubt that the six (6) best senior ranked men participants are to be preferred in the manner of ranking. It appears to be that the quota specified would enure to the benefit of such participants."
The court rejected the appellant’s contention that the NSF retained unqualified discretion in the selection. It observed:
"The submissions of the learned counsel for the appellant that the quotas are allocated to NSF who shall select and register athlete’s may be applicable to sportsperson/participants other than those falling within the aforesaid six (6) best senior ranked men."
The court drew a comparison with paragraph B of the bulletin dealing with the Hong Kong Games 2024. It stated:
"It is manifest that the quota in para-B attaches to the participant who is a winner and is not merged with the NSF of a particular country."
Consequently, it held the appellant's reading of the bulletin as "fallacious" and "unmerited."
The Division Bench upheld the Single Judge’s decision and dismissed the appeal. The concluding paragraph of the judgment stated:
"Accordingly, in view of the above the appeal is dismissed, along with the pending application, however, without any order as to costs."
The court clarified that it was interpreting the specific contents of the qualification bulletin and was not making a general pronouncement on the powers of NSFs to conduct trials. It noted:
"We are only interpreting the contents of the aforesaid bulletin and not rendering any opinion on the argument of the learned counsel for the appellant that the NSF are the repository of authority to hold trials... The said issue is left open to be decided in an appropriate case."
Advocates Representing the Parties:
For the Appellant: Mr. Dhruv Gautam and Mr. Abhishek Tongar
For the Respondents: Mr. Utsav Jain, Ms. Amrita Kameshwar Srivastava and Mr. Kameshwar Srivastava, Mr. Ruchir Mishra, Mr. Devvrat Yadav, Mr. Sanjiv Kr. Saxena, Mr. Mukesh Kr. Tiwari, Ms. Poonam Shukla, Ms. Reba Jena Mishra, and Ms. Harshita Sharma
Case Title: Roller Skating Federation of India vs Sanchit Bhandari & Anr.
Neutral Citation: 2025: DHC:2041-DB
Case Number: LPA 219/2025 & CM APPL. 17559/2025, CM APPL. 17560/2025
Bench: Chief Justice Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela
[Read/Download order]
