Sourabh Kumar, Mr. Vedant Sood, Mr. Siddharth Sunil and Mr. Zeeshan Thomas, Advs v. RAJASTHAN EQUESTRIAN ASSOCIATION ORS on 23 Dec 2025

Judgment

1. Through the present Letters Patent Appeals, the Appellant assails the correctness of the Judgment dated 07.01.2025 and Order dated 13.08.2025 [hereinafter referred “Impugned Judgment/Order”] passed by the learned Single Judge in W.P. (C) Nos.5989/2022 and 10342/2019, respectively.

2. Vide Impugned Judgment dated 07.01.2025, the learned Single Judge has inter alia held that the Relaxation Clause under the National Sports Development Code of India, 2011 [hereinafter referred to as “Sports Code”] is neither arbitrary nor unreasonable. The Court further held that the exemptions granted to the Equestrian Federation of India [hereinafter referred to as “EFI”] by the Ministry of Youth Affairs & Sports, Department of Sports, Government of India [hereinafter referred to as “MYAS”] are arbitrary and lack any substantive factual foundation. The Court also directed appointment of a five-member Fact Finding Committee [hereinafter referred to as “the Committee”]. Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 3 of 28

3. Further, vide Impugned Order dated 13.08.2025, learned Single Judge stayed the notice bearing No.072/EFI/EOGA/2025 dated

02.08.2025, purported to convene the Extra-Ordinary General Meeting [hereinafter referred to as “EOGM”] on 17.08.2025 and directed that the Appellant is restrained from holding the said EOGM.

4. In these circumstances, the question that arises determination is whether the exemptions granted to the EFI are in conformity with the principles and objectives underlying the Sports Code, and whether the learned Single Judge was justified in staying the convening of the EOGM.

5. With the consent of learned Senior counsel for the parties, both Appeals are heard together and are being disposed of by this common order.

6. In order to contextualize the present dispute, it is important to first chart out the description of the parties and the broad facts. DESCRIPTION OF THE PARTIES:

7. The Appellant in both the Appeals is alleged to be a member of the EFI (which is disputed by the learned Counsel representing the EFI), arrayed as Respondent No.3 in LPA No.135/2025 and Respondent No.1 in LPA No.578/2025. The Appellant is also one of the requisitionists for convening the EOGM dated 17.08.2025.

8. The EFI, constituted in 1967, is the recognized National Sports Federation [hereinafter referred to as “NSF”] entrusted with the management and coordination of the sport of Equestrian in India. Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 4 of 28 MYAS is arrayed as Respondent No.2 in both the appeals. The Sports Authority of India [hereinafter referred to as “SAI”] and the Indian Olympic Association are arrayed as Respondent No.3 and Respondent No.4 in LPA No.578/2025, respectively. The Rajasthan Equestrian Association [hereinafter referred to as “REA”], arrayed as Respondent No.1 in LPA No.135/2025 and Respondent No.5 in LPA No.578/2025, is the Petitioner in W.P.(C) No.10342/2019 and the Applicant in CM Appl. No.49192/2025, which stands allowed by the Impugned Order dated 13.08.2025. Mr. S.Y. Qureshi, arrayed as Respondent No.4 in LPA No.135/2025 and Respondent No.6 in LPA No.578/2025, is the Observer appointed by the learned Single Judge vide order dated 15.11.2019 in W.P.(C) No.10342/2019. BRIEF FACTUAL MATRIX:

9. The MYAS, vide letter dated 04.08.2017, granted the EFI two years’ time to comply with the Sports Code. The EFI thereafter sought reconsideration of the requirement of compliance on account of the peculiar nature of the sport. On 15.07.2019, the EFI requested the MYAS to exempt it from such compliance, stating inter alia that: i. ii. the sport has a peculiar nature; the pyramidical structure requiring at least 50% District Associations [hereinafter referred to as “DAs”] at the grassroots level is unfeasible; iii. the sport requires substantial infrastructure, availability, and year-round maintenance of equines; and Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 5 of 28 iv. the State Associations [hereinafter referred to as “SAs”] and Union Territory Associations [hereinafter referred to as “UTAs”] do not possess the requisite capacity to conduct Equestrian activities.

10. In furtherance of the above, the REA filed W.P.(C) No.10342/2019 seeking, withdrawal of the recognition granted to the EFI as the NSF for the Equestrian Sport on account of its non- compliance with the Sports Code and for replacement of the then Executive Committee [hereinafter referred to as “EC”] with an ad-hoc committee to ensure compliance.

11. Thereafter, MYAS issued Notification/Communication No. 12- 2/2021-SP-III by which the Sports Code was amended to incorporate a Relaxation Clause, empowering the Minister-in-charge, MYAS, to relax any provision of the Sports Code wherever considered necessary for the promotion of a sport or sportsperson, or for removing difficulties in giving true effect to the provisions of the Sports Code.

12. Thereafter, vide letter dated 09.11.2021, the MYAS granted temporary exemptions requirement of having affiliation to SAs / UTAs in 2/3rd States and the EFI from complying with their representative requirements in elections as per the Sports Code, noting special requirements of the Equestrian sport. Pertinently, the exemptions were granted only till such time the requisites of SAs/ UTAs in 2/3rd of States and UTs with 50% DAs come into existence. Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 6 of 28

13. It is also pertinent that during the period from March 2022 to April 2022, similar exemptions were granted by the MYAS to other sporting associations, including the Indian Golf Union, Indian Polo Association, Rowing Federation of India, Squash Rackets Federation of India, and the Yachting Association of India.

14. The REA thereafter filed W.P.(C) No.5989/2022, seeking, inter alia, quashing of the MYAS decision dated 09.11.2021 granting relaxation to the EFI from key provisions of the Sports Code, as well as quashing of Notification No.12-2/2021-SP-III dated 01.02.2021 incorporating the Relaxation Clause into the Sports Code.

15. On 09.06.2023, the EFI issued a notice to conduct its Annual General Meeting [hereinafter referred to as “AGM”], which the REA challenged seeking restraint, however, this Court permitted the said AGM vide Order dated 07.07.2023, subject to directions. Thereafter, on 26.08.2023, the EFI issued a notice convening an EOGM based on requisitions from its members, which the REA again challenged. Vide Order dated 15.09.2023, this Court allowed the EOGM to proceed and appointed Hon’ble Mr. Justice Najmi Waziri (Retd.) to chair it.

16. This Court, vide Order dated 21.05.2024 in W.P.(C) No.10342/2019, having considered the issue pertaining to the aforesaid EOGM, arrived at a finding that, concededly there was no unanimous decision of the house in the EOGM to extend the office bearers elected in 2019 and thus, EFI is functioning without a legitimate official body. The Court then proceeded to appoint an ad- hoc Committee to supervise the administration of EFI. Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 7 of 28

17. The Appellant and the EFI preferred LPA Nos.449/2024 and 453/2024, respectively, before this Court, seeking the setting aside of the Order dated 21.05.2024. This Court, vide Judgment dated

29.05.2024, modified the Order dated 21.05.2024 and reinstated the EC constituted pursuant to the elections held in December 2019.

18. It is stated that following the resignation of Lt. Gen. Gopal R., the President of the Reinstated EC, on 05.08.2024, the 62nd AGM nominated Col. Jagat Singh as President on 17.08.2024. However, on

18.08.2024, Mr. H.S. Khokkar was nominated as President of the EFI.

19. Thereafter, the learned Single Judge vide Impugned Judgment dated 07.01.2025, disposed of W.P.(C) No.5989/2022, thereby directing the following: i. The Relaxation Clause is neither arbitrary nor unreasonable; ii. The exemptions granted to the EFI are arbitrary and lack a substantive factual foundation; iii. Appointed a Committee to conduct a detailed investigation into the ground-level realities of the Equestrian Sport in India and furnish a report to that effect within 3 months; iv. Pending the report of the Committee and review by the MYAS, the exemptions granted to EFI shall remain operational.

20. Aggrieved by the aforesaid Judgment, the Appellant on

06.02.2025 preferred LPA No.135/2025 against the same. Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 8 of 28

21. Further,

26.05.2025, the REA preferred C.M. No.35446/2025 in disposed of W.P.(C) No.5989/2022, seeking extension of time on behalf of the Committee to prepare the comprehensive and efficacious report as directed by this Court.

22. It is alleged by the Appellant that pursuant to the Observer’s report dated 17.07.2025, several members of the EFI submitted requisitions to Col. Jaiveer Singh seeking an EOGM, with the Appellant’s requisition dated 01.08.2025. It is further alleged that upon obtaining the Observer’s consent to attend the meeting, Col. Jaiveer Singh accordingly issued a Notice dated 02.08.2025, convening the EOGM for 17.08.2025.

23. Thereafter, on 06.08.2025, the REA preferred CM No.49192/2025 in W.P.(C) No.10342/2019 seeking suspension of the EOGM Notice dated 02.08.2025. By the Impugned Order dated

13.08.2025, the learned Single Judge stayed the operation of the said EOGM Notice. Aggrieved thereby, the Appellant has preferred LPA No.578/2025. CONTENTION OF THE PARTIES in LPA NO.135/2025:

24. Heard learned Senior Counsel for the parties at length and, with their able assistance, perused the paper book. Learned Senior Counsel have also filed their written submissions, which are on record.

25. Learned Senior Counsel for the Appellant has submitted that: Signature Not Verified Signed By:SAVITA PASRICHA Signing Date:23.12.2025 12:49:48 LPA 135/2025 & connected matter Page 9 of 28 i. the learned Single Judge exceeded the limits of judicial review by interfering with a purely executive policy decision. The Courts may interfere only when such decisions are shown to be mala fide, arbitrary, or unreasonable. Reliance is placed upon Peerless General Finance and Investment Co Ltd. & Anr. v. Reserve Bank of India1; Jacob Puliyel v. Union of India & Ors.2; Directorate of Film Festivals v. Gaurav Ashwin Jain3; and Parminder Singh v. Union of India4. ii. similar exemptions were also extended by the MYAS to other sports as well, for similar reasons. iii. the Sports Code cannot be read in the manner of a statute. Reliance is placed upon the judgment of the Supreme Court in All India Football Federation v. Rahul Mehra & Ors.5. the MYAS, in its Letter dated 09.11.2021, has recorded clear reasons for invoking the Relaxation Clause. Equestrian is a unique club-based sport requiring two athletes, specialised infrastructure, and quarantine facilities. It has a limited district- level presence. v. the insistence on strict compliance with the Sports Code would enable the creation of shell DAs, thereby diverting governance away from the stakeholders who truly represent the sport.