Manjeet v. Indian Olympic Association and Ors.

SUBMISSIONS ON BEHALF OF THE PETITIONER

13. Ms. Neha Singh, learned Counsel for the petitioner, states that the Qualification System for XXV Olympic Winter Games, Milano Cortina 2026 prescribes objective and exhaustive criteria for eligibility and assessment, leaving no scope for change in eligibility criteria. She draws my attention to Section C and E of the above mentioned qualification document which sets out the eligibility criteria. She states that the respondent Nos. 1 and 2’s retrospective reliance on a World Championship through which India secured a quota to the Winter Olympics, 2026 is contrary to the FIS framework.

14. Further as per the timeline the assessment period for XXV Winter Olympics, 2026 was from 01.07.2024 – 18.01.2026. It was during this period that the FIS points were to be achieved. The timeline reads as under:

15. Additionally, she states that the long list which was prepared on 26.09.2025 was only a probable list of candidates and is different from the final qualification list. Therefore, even though the petitioner’s name is not on the long list, it shall not act as a bar to the qualification list prepared for Winter Olympics, 2026. She also states that by not considering the FIS scores of the entire period, the whole point of the assessment period has been brought to a nought.

16. She further submits that, as per Rule 5 of the FIS Cross Country Ski Rules 2025-2026 (issued in September 2025), a competitor’s FIS points are calculated as the average of his/her last five best results in distance competitions over the preceding 12 months. Even under the said Rules, the governing criterion is the improvement of FIS points, leaving no scope for any other eligibility criteria. Further, the MYAS Notification dated 05.03.2025 mandates transparency, discipline-specific criteria, and recording of reasons in athlete selection. She states that the respondent Nos. 1 and 2’s failure to publish selection criteria, disclose performance matrices, or furnish reasons constitutes a clear violation of the instruction of MYAS and undermines the integrity of the selection process.

17. It is also stated, that the selection process is further tainted by the constitution of an Ad-hoc Committee which lacks ratification by the IOA Executive Committee and suffers from an apparent conflict of interest. Two of its three members are active athletes who have participated in, and benefited from, the selection process, rendering the process biased and arbitrary. Reliance is placed on Bihar Olympic Association v. President, IOA (judgment dated 24.02.2025), reiterated in W.P.(C) NO. 3418 of 2025 (order dated 23.05.2025), that unilateral appointment of Ad-hoc Committees by the IOA President is impermissible.

18. It is also submitted that the petitioner was never informed of any change in selection criteria nor afforded an opportunity of representation. The retrospective application of undisclosed criteria violates the principles of natural justice and audi alteram partem.

SUBMISSIONS ON BEHALF OF RESPONDENT NOS. 1AND 2

19. Per Contra, Mr. Gopal Jain, learned senior counsel for respondent Nos. 1 and 2states that that preparation of a long list is an essential and mandatory step in the Olympic accreditation and selection framework. It is further submitted that the rules, eligibility criteria, and qualification systems prescribed by the International Federations and the International Olympic Committee are binding upon Respondent No. 1 and 2 and govern the entire process.

20. He has further stated that, as per the Qualification System issued by the FIS, the World Championship constitutes a qualifying event for the Winter Olympic Games under Section D of the said Qualification System, and that non-participation therein would result in non-fulfilment of the essential qualification requirement. He relies on Clause C.[3] and D.1.1.

21. With regard to selection process, it is his submission that India’s sole male quota was earned by Mr. Stanzing Lundup through his performance at the FIS Nordic World Championship 2025 where he earned 269.58 FIS points. On the other hand the petitioner did not participate in the World Championship which was a mandatory requirement at the time of preparing the long list and therefore, even though he has the highest score, he is not eligible for the XXV Winter Olympics, 2026.

22. It is further submitted that even in cases of medical exigency or exceptional circumstances, the Late Athlete Replacement (“LAR”) mechanism permits substitution only from within the long list. The petitioner, having never been included in the long list, is barred from consideration for both emergency replacement as well as standard entry. Permitting a standard entry after the deadline would amount to bypassing a higher statutory threshold expressly prohibited under the Olympic regulations.

23. It is also submitted that inclusion in the long list is a mandatory precondition for ITA/WADA anti-doping oversight and integrity monitoring. By remaining outside of this long list, the petitioner did not go through mandatory pre-competition safeguards, rendering any post facto inclusion incompatible with the Olympic Charter and the NOC Accreditation and Sport Entries Manual.

24. Finally, all relevant Olympic timelines have long since expired, including submission of the Conditions of Participation, confirmation of quota allocation, and reallocation by the Organising Committee. At this advanced stage, he states there exists neither legal discretion nor technical feasibility to accede to the reliefs sought by the petitioner. He relies on 3.3.[2] of the NOC Accreditation and Sports Entry Manual which reads as under: “3.2.2. Accreditation Application Deadline 26 September 2025 Accreditation applications for all potential athletes must be completed using the Milano Cortina 2026 Accreditation System no later than 26 September 2025. These accreditation application forms, otherwise known as the Long List, should include details of all athletes who may potentially participate in the Games, regardless of their qualification status at the time of the accreditation application deadline. The Long List should also include the details of all alternate athletes ("Ap" category) or athletes that may be considered for potential late athlete replacement.”

25. Relying on the same he states that respondent Nos. 1 and 2 were bound to issue the long list on 26.09.2025 and even the names of athletes for LAR should form part of the long list.

26. He further states that the entire controversy in the present matter boils down to interpretation of the NOC Accreditation and Sports Entries Manual along with the FIS Qualification document. He states that respondent No. 1 is an expert body and comprising of experts in the field and is the sole agency to interpret the terms of Competitions. Further, he submits that it is a settled law that a Constitutional Court in its limited jurisdiction will refrain from interfering in matters which lie squarely in the domain of subject experts. Reliance is placed on Karamjyoti v. Union of India, 2016 SCC OnLine Del 6766. The relevant paragraph reads as under:

27. In view of the above submissions, he seeks that the petition be dismissed.

SUBMISSIONS ON BEHALF OF RESPONDENT NO. 3

28. Mr. Ruchir Mishra, learned senior panel counsel for respondent No. 3 has relied on the Order dated 23.01.2026 to state that a response was sought from Respondent No. 1 and 2. Further when MYAS was apprised of the matter, it sent a communication on 22.01.26 asking about how the quota seat was being filled.

29. On instructions, Mr. Mishra, states that the Ministry has no role in the Selection criteria and has no communication with the Federation conducting the Winter Olympics, 2026. It is only the IOA which is the concerned body.

ANALYSIS AND FINDINGS

30. I have heard the learned counsel/ senior counsel for the parties and perused the material on record.

31. The scope of judicial scrutiny in matters involving expert or statutory bodies is well settled and limited. While Constitutional Courts are dutybound to protect fundamental and legal rights, they must, in appropriate situations, exercise judicial restraint, as a matter of prudence, particularly in matters of policy or those involving specialised expertise. Interference is warranted only where the decision-making process is arbitrary, unfair, or contrary to law. In Paralympic Committee of India v. Naresh Kumar Sharma, 2018 SCC OnLine Del 8443 it was held as under:

broad, prima facie view, without getting into the intricacies of the policy decision, there is manifest arbitrariness or mala fides in the decision making of the Committee.” (Emphasis added)

32. Keeping these principles in mind, I shall examine the facts of the present case.

33. The Olympic Games represent the pinnacle of international sport. It is not merely a sports competition but a culmination of years of discipline, sacrifice, and hard work. The process by which athletes are selected to represent the country should reflect the highest standards of procedural fairness. For most athletes, there may be only one, at best two, Olympic Games in an entire lifetime where they have the opportunity to compete; an opportunity earned through years of relentless discipline, sacrifice, and unwavering commitment. A sporting career is fleeting by nature, where the athlete’s peak performance is confined to a narrow and irreplaceable window of time.

34. The present writ petition raises serious concerns regarding the exclusion of a meritorious athlete from Olympic consideration, compelling this Court to examine whether the exclusion of the petitioner, who specialises in Cross Country Skiing 10 kms distance category, from selection for the Winter Olympic Games, Milano Cortina 2026, on the ground of nonparticipation in the World Championship, is sustainable in light of the governing eligibility framework prescribed by the FIS.

35. The relevant sections of the Qualification System – XXV Olympic Winter Games – Milano Cortina 2026 are reproduced as under:

36. Relevant Rules of FIS rules read as under: “5.[2] FIS Points 5.2.[1] Distance (longer than Sprint) A competitor’s points will be the average of his or her best five results in distance competitions over the period of the last twelve months.” The Ski Event rules read as under: “Winter Olympic Games: Only notified SSI WOG athletes are eligible to participate in these events. Athletes must be members of the National Team. Must have the required FIS Points.”

37. At the outset, it is necessary to note that the learned senior counsel for respondent No. 1 and 2 seeks to justify the selection on the basis of an affidavit asserting that participation in the World Championship constitutes an essential requirement. The same is based on a reading of Section D of the FIS Qualification System for the XXV Olympic Winter Games Milano Cortina 2026.

38. A perusal of the FIS Qualification System for the XXV Olympic Winter Games Milano Cortina 2026, clearly delineates the eligibility criteria for participation. The framework mandates compliance with the Olympic Charter, the World Anti-Doping Code, and the applicable FIS Rules. The eligibility conditions are exhaustively set out under Section C.

39. Under Clause C.1, the age requirement prescribes that all athletes must be born prior to 01.01.2011.Under Clause C.2, athletes are required to satisfy the medical requirements under the International Ski Competition Rules (“ICR”).Under Clause C.3, additional eligibility criteria are prescribed, primarily in the form of FIS points threshold.

40. The qualification criteria for distance unequivocally stipulate that athletes having thresholds of 350.00 FIS points are prescribed for participation in specific distance, sprint, and team events. It is clarified the lower the points the higher is the ranking of the athlete.

41. It is not in dispute that the petitioner as per the list published by FIS on 19.01.2026 is the most meritorious and is at two places above Mr. Stanzin Lundup.

42. Significantly, nowhere in Section C, which governs athlete eligibility, is participation in the World Championship prescribed as a mandatory condition. The eligibility framework is objective, points-based, and exhaustive. Once an athlete satisfies the age, medical, and FIS points criteria, he becomes eligible for selection by the NOC.

43. The reliance placed by respondent No. 1 and 2 on Section D of the Qualification System is misplaced. A plain reading of Section D demonstrates that it deals exclusively with the allocation and utilisation of quota places, that is, the manner in which quotas are distributed among National Olympic Committees. Section D does not introduce any additional athlete-level eligibility condition, nor does it override or supplement the criteria laid down under Section C.

44. Quota allocation operates at the level of the country, whereas eligibility operates at the level of the athlete. Conflating the two amounts to a fundamental misreading of the Qualification System. The respondent NO. 1 and 2 cannot import an additional condition not prescribed by the International Federation. Once the International Federation has chosen FIS points as on 19.01.2026, the determinant of eligibility, it is not open to the respondents to introduce an additional requirement through executive interpretation. Such an approach would defeat the uniformity and certainty that the qualification system seeks to achieve.

45. Selection to represent the country at the Olympic Games is not an internal administrative exercise; it is a matter of national representation. Processes that disregard merit and transparency not only cause grave prejudice to individual athletes, who invest years of discipline and sacrifice, but also place the credibility of the nation’s sporting institutions at stake. The IOA along with its committees cannot start acting as a Super Selector and go beyond the four corners of its authority and create criteria for selection which do not exist in the Qualification System which is binding upon the respondents.

46. Further, the respondent No. 1 and 2 contention that the 5th FIS points were considered for preparation of the long list is wholly misconceived and untenable. The FSI by its publication dated 16.04.2025, clearly demarcated the assessment period from 01.07.2024 to 18.01.2026 into eight distinct phases, with the final score scheduled to be released only on 19.01.2026. The 5th FIS points criterion was exclusively prescribed for the World Championship 2025 and, therefore, cannot be retrospectively or erroneously applied as a determinant of eligibility for the Winter Olympic Games, 2026 particularly when a separate eligibility framework has already been notified by the Federation.

47. By restricting selection for the 25th Winter Olympic Games solely to participation in the World Championships, the respondent Nos. 1 and 2 have effectively rewritten the governing qualification framework. The qualification timeline prescribed under Clause G, spanning from 01.07.2024 to 18.01.2026, has been modified at the whims and fancies of respondent Nos. 1 and 2 to March 2025. In doing so, the respondent Nos. 1 and 2 have failed to consider the results validly achieved by the petitioner up to 18.01.2026, in clear disregard of the notified qualification system. The list published on 19.01.2025 is as follows:

48. When a pointed query was put the learned counsel as to the specific basis on which the petitioner was excluded from the long list, and whether participation in the Nordic World Championship constituted a mandatory eligibility requirement for being put on the long list, he placed reliance on Clause 3.3.[2] of the NOC Accreditation and Sports Entry Manual and stated that the final list had to be sent by 26.09.2025.

49. The said submission is also faulty. No document has been produced to demonstrate that participation in the World Championship constituted a determinative criterion for preparation of the long list. In any event, a plain reading of the Qualification System along with the NOC Accreditation and Sports Entry Manual makes it abundantly clear that the preparation of the long list cannot override or prejudge the Final List, which is required to be drawn strictly on the basis of FIS points accumulated over the prescribed 18-month assessment period. Clause 3.2.[2] merely stipulates that the Long List shall include details of all athletes who may potentially participate in the Games, irrespective of their qualification status as on the accreditation application deadline. Notably, the said clause does not prescribe participation in the World Championship as a pre-requisite in any manner.

50. The Ad-hoc Committee proceeded to apply selection criteria that are not traceable to any provision of the governing international qualification documents. The record reveals that athletes were assessed and excluded on the basis of conditions i.e., participation in World championship, which do not find mention in the FIS Qualification System. Such an approach strikes at the very foundation of a rule-based selection process.

51. Further, during the course of hearing, a stand has been taken by the respondents that the relief sought in the present petition has become infructuous on the ground that the last date for forwarding the list of athletes was 26.01.2026. Reliance has also been placed on Clause 2.7.[6] of the NOC Accreditation & Sport Entries Manual, relating to arrival in Italy and PVC validation.

52. A copy of the said manual was handed over in Court. It is pertinent to note that the said document is admittedly not available in the public domain and, more importantly, was never communicated to the athletes. The respondent Nos. 1 and 2 contend that since the petitioner’s name does not figure in the long list, no further steps can now be taken. The stand of respondent Nos. 1 and 2 clearly shows that by their conduct they have deprived the petitioner of his valuable to represent the country at the pinnacle of Sports namely the Olympics. To say the least the conduct of respondent No. 1 is casual, callous, arbitrary, malafide and shows disrespect to fair competition.

53. Equally disheartening is the casual and cavalier manner in which the respondents have responded to the directions of this Court. Despite the acknowledged urgency of the matter, and notwithstanding the fact that Olympic selection directly implicates national representation in the international arena, the respondents appear oblivious to the gravity of their responsibility and irresponsibility of their actions.

54. At this juncture it becomes necessary to observe that Athletes competing at international fora do not represent themselves alone; they represent our nation. The manner in which the respondents have conducted themselves conveys an impression of institutional indifference to merit and excellence, as though mediocrity in international competition were an acceptable outcome. Talent, no matter how exceptional, can only flourish when supported by transparent, fair, and accountable institutions. In global sporting events, it is not merely the athlete but the country itself that is under observation.

55. The approach adopted in the present case, if allowed to stand, risks eroding public confidence in sports governance and tarnishing the credibility of India’s sporting institutions on the international stage. Such a consequence cannot be accepted by this Court.

CONCLUSION

56. In view of the above, it is held that the selection process is manifestly arbitrary and unfair, and respondent Nos. 1 and 2 have failed in their duty as the Supervisory body. Hence, the prayer A and B are allowed.

57. Although this Court has taken note of the respondents’ submission that the impugned selection process has culminated and that consequential arrangements have already been acted upon, however, since respondent Nos. 1 and 2 have failed in their duty towards the petitioner, respondent No. 3 is directed to try and make all reasonable efforts to ensure that the petitioner is permitted to participate in the XXV Olympic Winter Games, Milano Cortina 2026. Respondent Nos. 1 and 2 are also directed that they shall take immediate steps to provide full support to respondent NO. 3 in making necessary arrangements.

58. This Court is of the view that inaction, arbitrariness, or unfair treatment on the part of administrative authorities cannot be permitted to operate as an impediment to the recognition of merit of Indian athletes, nor can it be allowed to deprive them of a legitimate opportunity to represent the nation at the XXV Olympic Winter Games, Milano Cortina 2026.

59. This Court also expresses its displeasure at the stand adopted by Respondent No. 3, the Ministry. As the repository of public trust and the nodal authority overseeing sports administration, respondent No. 3 is duty-bound to ensure that the selection process is fair, transparent, and merit-based. The Ministry cannot act as a mute spectator or distance itself from the legitimate grievances and hardships faced by athletes, whose careers and once-in-a-lifetime opportunities depend upon institutional accountability and adherence to rules and regulations. The State and its instrumentalities are expected to act fairly, reasonably and ensure transparency at all levels.

60. Hence, prayer A and B are disposed of in the above terms. As regards prayer C is concerned the respondents shall file a detailed reply within 4 weeks from today.

61. List on 13.04.2026 for adjudication of Prayer C.

62. The documents handed over in Court are taken on record.

63. Pending applications, if any, stand disposed of.

JASMEET SINGH, J