$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment reserved on: 02.09.2026 Judgment pronounced on: 07.09.2026 Judgment uploaded on: 08.09.2026 # CNR No. DLHC010410172026 + W.P.(C) 12670/2026 SANJANA .....Petitioner Through: Mr. Vibhas Kumar Jha and Mr. Azad Singh, Advocates, with petitioner in person. versus UNION OF INDIA & ORS. .....Respondents Through: Ms. Puja S. Kalra, CGSC for UOI. Ms. Kumudavalli Seetharaman and Ms. Geetika Vyas, Advs. for R-2. Mr. Rajneesh Bhaskar and Mr. Siddharth Makkar, Advs. for R-3. CORAM: HON'BLE DR. JUSTICE SWARANA KANTA SHARMA JUDGMENT DR. SWARANA KANTA SHARMA, J 1. By way of the present writ petition, the petitioner seeks quashing the notification dated 22.08.2026 [hereafter ‘impugned notification’] issued by respondent no. 1, Union of India through the Ministry of Youth Affairs & Sports [hereafter ‘Ministry’], and a direction to the Ministry to forthwith forward her name to the relevant respondents for participation in the Women’s 77 kg Weightlifting event at the 20th Asian Games, Aichi-Nagoya 2026, and to include her name in the final list of athletes for the said Games. FACTUAL BACKGROUND 2. The case set out by the petitioner is that she is an Indian weightlifter who competes in the Senior Women’s 77 kg category and has represented the country at international competitions. Respondent no. 1 is the Union of India through the Ministry, respondent no. 2 is the Indian Olympic Association (IOA), respondent no. 3 is the Indian Weightlifting Federation (IWF), being the National Sports Federation recognised for the sport, respondent no. 4 is the Sports Authority of India (SAI), and respondent no. 5 is the Chief Executive Officer, Target Olympic Podium Scheme. It is stated that the criteria governing selection of the Indian contingent for multi-sport events, including the 20th Asian Games, Aichi-Nagoya 2026, scheduled to be held in Japan from 19.09.2026 to 04.10.2026, was notified by the Ministry vide letter dated 24.09.2025 [hereafter ‘Ministry’s Selection Criteria’]. The IWF thereafter framed its own Selection Policy for the said Games, updated as on 20.05.2026 [hereafter ‘Selection Policy of IWF’], prescribing a benchmark total of 214 kg for the Women’s 77 kg category. 3. The petitioner participated in the 2026 AWF Asian Senior Weightlifting Championships, held at Gandhinagar from 11.05.2026 to 17.05.2026, which was one of the mandatory evaluation events under the aforesaid policy/criteria. She secured the third position in the Women’s 77 kg category with a total lift of 220 kg, comprising 96 kg in Snatch and 124 kg in Clean & Jerk, and won Bronze Medals in the Snatch, Clean & Jerk and Total events. The Selection Committee of the IWF, in its meeting held on 22.06.2026, recommended five men and five women, including the petitioner, for the Games. Thereafter, by communication dated 03.07.2026, the IWF confirmed to the SAI and the IOA that all the athletes so nominated satisfied the prescribed criteria, the petitioner being shown therein as ‘Qualified’. The IWF also issued a certificate dated 25.08.2026 certifying her performance at the Championships and commending her candidature. 4. In the meanwhile, the Ministry, by order dated 22.08.2026 addressed to the IOA, accorded approval for the participation of 492 athletes, comprising 265 male and 227 female athletes, in 35 disciplines at the said Games, the name-wise list whereof was annexed thereto. In the discipline of weightlifting, one male and four female athletes came to be approved, and the name of the petitioner was not included. It is this exclusion of the petitioner which has given rise to the present petition. SUBMISSIONS BEFORE THE COURT 5. The learned counsel appearing for the petitioner argues that the petitioner satisfies the eligibility and performance requirements prescribed under the applicable framework, but her candidature has nonetheless not been considered. It is argued that Clause 4(c) of the Selection Policy of the IWF provides for the selection of five athletes each in the male and female sections for the Asian Games. It is further argued that, where more than five athletes achieve the qualifying total, the Selection Committee may finalise the team having regard to the relevant weight category, medal potential and overall competition prospects. It is argued that, notwithstanding the said Policy, the impugned notification dated 22.08.2026 approved only four female weightlifters and one male weightlifter, thereby leaving the fifth female slot unfilled. It is argued that the benchmark total prescribed for the Women’s 77 kg category is 214 kg, which the petitioner bettered by 6 kg, having achieved a total lift of 220 kg at one of the mandatory evaluation events recognised under the Policy. It is further argued that the petitioner satisfies the criteria contained in the Ministry’s Selection Criteria dated 24.09.2025, under which a National Sports Federation is eligible to nominate an athlete who has matched or bettered the sixth-place performance at the last Senior Asian Championships. The Selection Policy of the IWF itself adopted the corresponding sixth-place performance for the Women’s 77 kg category as the benchmark of 214 kg. It is argued that the Selection Committee, in its meeting held on 22.06.2026, considered and recommended the petitioner; that the IWF, by its communication dated 03.07.2026, expressly recorded her status as ‘Qualified’; and that it commended her candidature by certificate dated 25.08.2026. It is argued that, despite her performance, eligibility and recommendation by the IWF, the petitioner’s name did not find place in the approved list dated 22.08.2026, i.e., the impugned notification, and no reason for her exclusion has been communicated to her. It is argued that, having framed a selection policy, the respondents are bound to apply it fairly and uniformly to all eligible athletes and cannot adopt different standards for similarly situated athletes without disclosing rational reasons. Therefore, it is prayed that the present petition be allowed 6. The learned CGSC appearing for respondent no. 1/Ministry, on the other hand, opposes the petition and argues that the selection for the 20th Asian Games, 2026, is governed by the Ministry’s Selection Criteria, notified on 24.09.2025, which prescribe uniform benchmarks to ensure that only likely medal probables represent the country. It is argued that, since the Women’s 77 kg category was not contested at the last Asian Games, the applicable benchmark was required to be determined under Clause 4.1(I)(b) of the said Criteria, by reference to the last Senior Asian Championships. It is further argued that, as only five athletes from less than six countries competed in that category at the 2026 AWF Asian Senior Weightlifting Championships at Gandhinagar, the ‘Top 2’ cut-off prescribed under Clause 6 of the Criteria stood attracted, resulting in a benchmark of 260 kg, as against the petitioner’s total of 220 kg. It is argued that securing third position in a field of five athletes neither establishes competitive depth nor creates a right to nomination; that a vacant quota slot cannot render an otherwise ineligible athlete eligible; and that no athlete was approved in the said category, which negates any allegation of discrimination. It is further argued that relaxing a uniformly applied benchmark would set an unworkable precedent and prejudice athletes of other disciplines excluded under the same Criteria. It is also argued that a writ court does not sit in appeal over the decisions of experts, and that no case for interference under Article 226 of the Constitution of India is made out. 7. The learned counsel appearing for respondent no. 3/IWF, however, supports the petitioner and argues that its nine-member Selection Committee had, on 22.06.2026, unanimously recommended five men and five women, including the petitioner, for the Asian Games 2026. It is argued that the Selection Policy of the IWF fixes the benchmark for the Women’s 77 kg category at 214 kg, which the petitioner has bettered by 6 kg. It is further argued that Clause 6 of the Ministry’s Selection Criteria, being only a ranking cut-off provision, cannot operate as a standalone bar divorced from Clause 4.1(I)(b), Clause 7 and the sport-specific policy, particularly when the number of countries entering a category depends upon the entry choices of foreign federations, a matter beyond the athlete’s control. It is further contended that the possibility of relaxation under Clause 5 of the Ministry’s Selection Criteria remained unconsidered, and that the petitioner’s inclusion would only fill the fifth female slot permissible under the Games framework, which was left vacant by the impugned notification dated 22.08.2026. 8. This Court has heard arguments addressed on behalf of the petitioner as well as the respondent no. 1 and respondent no. 3, and has perused the material available on record. ANALYSIS & FINDINGS 9. The principal issue that arises for consideration is whether – notwithstanding the petitioner’s having secured a total of 220 kg in the Women’s 77 kg category at the 2026 Senior Asian Weightlifting Championships and having been recommended by the IWF Selection Committee on the basis of its own Selection Policy – she satisfied the eligibility requirements prescribed under the Ministry’s Selection Criteria dated 24.09.2025 for being nominated to represent India at the 20th Asian Games, Aichi-Nagoya 2026. 10. At the outset, it is apposite to note that the Ministry’s Selection Criteria was notified on 24.09.2025, well before the commencement of the selection process for the 20th Asian Games, Aichi-Nagoya 2026. Clause 4 of the said criteria prescribe objective performance benchmarks for measurable individual sports and events. The same reads as under: “4. Benchmarks for individual sports and events and team sports and events 4.1 The benchmarks are being prescribed so that likely medal probable are representing India and quality of the participation is ensured in multidisciplinary sports events such as Asian Games, Para-Asian Games, Commonwealth Games, Asian Indoor games, Asian Beach Games, Youth Olympics, Asian Youth Games, Commonwealth Youth Games, similar events in para-sports as also the winter editions of such games. (I) Measurable Individual Sports and Events: a. Where the sport or event was contested at the last Asian GamesThe NSF will be eligible to nominate an athlete if the athlete has matched or bettered the 6th-place performance from the last Asian Games at a competition recognized by the international sports federation for that sport, held within the 12 months preceding the upcoming Asian Games. b. Where the sport or event was not contested at the last Asian Games but Senior Asian Championships was conducted for the sport or event within 12 months preceding the upcoming Asian Games - The NSF will be eligible to nominate an athlete if the athlete has matched or bettered the 6th-place performance from the last Senior Asian Championships at a competition recognized by the international sports federation for that sport, held within the 12 months preceding the upcoming Asian Games.” 11. Clearly, Clause 4.1(I)(a) applies where the relevant sport or event was contested at the last Asian Games, in which case the benchmark is the sixth-place performance at those Games. Clause 4.1(I)(b) applies where the sport or event was not contested at the last Asian Games but a Senior Asian Championships was conducted within the preceding twelve months, in which case the benchmark is the sixth-place performance at the last Senior Asian Championships. The Ministry has, therefore, prescribed a specific mechanism for determining the benchmark in respect of events which were not part of the preceding Asian Games. 12. Clause 6 deals with the determination of the ranking cut-off in cases where there is low participation in the Asian Championships. The same reads as under: 6. Determination of ranking cut off in cases where there is low participation in Asian Championships Number of participating countries at Asian Championships • If number of competing countries are less than 12 in an event, then the following shall be considered: No. of participating countries in a particular event at Asian Championships Position required to secure Asian Games eligibility 6-12 Top 4 Less than 6 Top 2 13. It provides that where the number of competing countries in an event is less than twelve, the following cut-offs would apply – (i) where the number of participating countries is between 06 and 12, an athlete must finish within the top four; and (ii) where the number of participating countries is less than 06, an athlete must finish within the top two. Apparently, the object of Clause 6 is to ensure that a high position obtained in an event with limited participation is not, by itself, sufficient to ensure eligibility, and it consequently prescribes a stricter ranking cut-off in such cases. 14. The Selection Policy of IWF has to be understood in this background. As evident from a perusal of the said policy, the same was framed for the selection of athletes in view of the change in bodyweight categories with effect from 01.08.2026, and the fact that the Asian Games 2026 would be the first major event to be conducted in the new categories. Clause 4(c) of the IWF Policy proposes selection of five male and five female athletes for the Asian Games. Clause 4(d) of the IWF Policy provides that, for the purpose of selection, the total performance in the respective bodyweight category during the preceding one year would be considered. It also prescribes a benchmark total for each weight category. 15. In the present case, the relevant weight category is the Women’s 77 kg category. The Selection Policy of IWF prescribes a benchmark total of 214 kg for this category. The petitioner admittedly achieved a total of 220 kg at the 2026 AWF Asian Senior Weightlifting Championships held at Gandhinagar. She, therefore, exceeded the benchmark prescribed by the IWF by 6 kg. The petitioner also secured the third position in the Women’s 77 kg category at the said Championships, with a total of 220 kg, comprising 96 kg in Snatch and 124 kg in Clean & Jerk. Her performance was recognised by the IWF, and the IWF Selection Committee recommended her name along with the names of four other female athletes. The IWF thereafter communicated to SAI and IOA that the nominated athletes had satisfied the criteria under the IWF Selection Policy, and the petitioner was marked as “Qualified”. 16. However, the fact that the petitioner achieved the benchmark prescribed by the IWF and was recommended by the IWF Selection Committee does not, by itself, conclude the issue of her eligibility for nomination to the Asian Games, inasmuch as the final selection for a multidisciplinary event is subject not only to the sport-specific policy of the concerned NSF, but also to the Ministry’s Selection Criteria. 17. It is also not in dispute that the Women’s 77 kg category was not contested at the preceding Asian Games held at Hangzhou in 2023. Consequently, Clause 4.1(I)(a) of the Ministry’s Selection Criteria, which applies where the sport or event was contested at the last Asian Games, could not apply to the petitioner’s case. The applicable provision was Clause 4.1(I)(b), since the relevant event had not been contested at the last Asian Games and a Senior Asian Championships had been conducted within twelve months preceding the forthcoming Asian Games. Accordingly, the benchmark for the petitioner’s eligibility had to be determined with reference to the performance at the 2026 Senior Asian Weightlifting Championships held at Gandhinagar. The petitioner herein had participated in the said Championships and secured the third position in the Women’s 77 kg category. The relevant field, however, consisted of only five athletes, thus, representing fewer than six participating countries. 18. Therefore, in view of the limited participation in the said Women’s 77 kg category, Clause 6 of the Ministry’s Selection Criteria would be attracted. Since the number of participating countries in the relevant event was less than six, the prescribed ranking cut-off was the top two. As per record, the performance of the top two athletes in the Women’s 77 kg category at the Gandhinagar Championships was 265 kg and 260 kg respectively. Thus, in terms of the Ministry’s Selection Criteria, the relevant benchmark was required to be assessed with reference to the top-two performance in the event. The petitioner’s performance of 220 kg was lower than the second-place performance by 40 kg and was consequently below the benchmark applicable under the notified criteria. 19. In view of the above discussion, the petitioner’s contention that she had exceeded the IWF benchmark of 214 kg cannot come to her rescue. The IWF benchmark appears to have been relevant to the sport-specific selection process undertaken by the IWF, whereas the Ministry’s criteria prescribe the conditions governing the eligibility of an athlete for nomination to the Asian Games. The two requirements, therefore, operate at different stages of the selection process. Consequently, the petitioner’s satisfaction of the IWF benchmark could not be treated as dispensing with the separate requirement of satisfying the Ministry’s notified criteria. Likewise, the recommendation made by the IWF, on the basis of its Selection Policy, may not by itself be construed as a determination that the petitioner had fulfilled every condition prescribed by the Ministry. The recommendation was undoubtedly a relevant consideration, but the ultimate decision regarding nomination was required to be taken within the framework of the Ministry’s applicable criteria. 20. Insofar as the submission of the IWF that Clause 6 of the Ministry’s Selection Criteria cannot be read in isolation, divorced from Clause 4.1(I)(b), is concerned, this Court is of the view that a harmonious reading of the two provisions would indicate that Clause 4.1(I)(b) lays down the general performance benchmark applicable where the relevant sport or event was not contested at the last Asian Games, whereas Clause 6 specifically addresses the additional situation of low participation in the relevant Asian Championships. Clause 6, therefore, operates as a specific provision within the broader framework of Clause 4.1(I)(b), and cannot be disregarded merely because the athlete has satisfied the prescribed performance benchmark. 21. The petitioner has also relied upon the fact that the IWF Selection Committee recommended five female athletes and that the fifth female slot was not filled in the Ministry’s notification dated 22.08.2026. However, the existence of a vacant slot cannot create eligibility where the applicable performance and ranking criteria have not been satisfied. A vacant slot may permit the competent authority to consider whether any eligible athlete can be nominated or whether relaxation under Clause 5 of the Ministry’s Selection Criteria is warranted, but it does not confer an automatic right upon an athlete who does not meet the prescribed criteria. In this regard, the petitioner has also not demonstrated that the competent authority was under a mandatory obligation to fill every available slot, irrespective of the eligibility criteria. The mere fact that the approved number of female weightlifters was four, although the IWF had recommended five, cannot render the Ministry’s decision arbitrary when the petitioner did not satisfy the benchmark applicable under the Ministry’s criteria. 22. Furthermore, the Ministry’s Selection Criteria has neither been challenged in the present writ petition, nor has been shown to have been applied selectively against her. The requirement of satisfying the applicable performance benchmark, read with the prescribed top-four or top-two ranking cut-off in cases of low participation, forms part of a general policy governing measurable sports and events. The petitioner has not shown that any similarly situated athlete, who had not satisfied the applicable criteria, was nevertheless nominated for the Asian Games. Her plea of discrimination, therefore, cannot be accepted merely because she had achieved the IWF benchmark or had been recommended by the IWF. In the absence of any material showing arbitrary, discriminatory or inconsistent application of the Ministry’s Selection Criteria, the petitioner cannot claim a right to nomination merely because a slot remained available. 23. The Court is also of the considered view that it cannot substitute its own assessment of the petitioner’s medal prospects for the assessment reflected in the notified criteria. The policy decision to insist upon the top-two cut-off where participation is below six countries is within the domain of the Executive and the competent sporting and administrative authorities. The Court’s jurisdiction under Article 226 of the Constitution is not to undertake a fresh evaluation of athletes or to determine which athlete ought to represent the country, unless the decision is shown to be arbitrary, irrational, discriminatory, mala fide or contrary to the governing rules or policies. In this regard, reliance can also be placed on the following observations of the Coordinate Bench of this Court in Yamini Mourya v. Indian Olympic Association: 2023 SCC OnLine Del 6213: “18. The selection criteria has been evolved by experts and this Court is of the opinion that the criteria which has been evolved by the Respondent No.2 on 10.07.2023, is not perverse. The writ court must only see whether the criteria which have been arrived at is in good faith and whether the decision is reasonable. The writ court must not sit as an Appellate Authority over the decisions arrived at by experts if the same is reasonable and has been taken in good faith. *** 22. The criteria adopted by the Respondents by ranking the players in their respective weight categories, keeping in mind their world rankings and arriving at their respective Asia ranking and to restrict only those players who have achieved 8th rank in their respective category to be sent to represent the country in Asian Games, cannot be said to be arbitrary or perverse. There is nothing on record which shows that the criteria has been evolved to oust the Petitioners herein. It has been found that only three athletes in women category in -70 kg, -78 kg and +78kg category and one male athlete in -100 kg category alone satisfy the criteria evolved by the Respondents and they have been selected to represent the country in the Asian Games. 23. Even if two opinions are possible, the Court while exercising its jurisdiction under Article 226 of the Constitution of India must restrain itself from substituting its opinion to the decision arrived at by the authorities. This Court, therefore, does not find any merit in the writ petition.” 24. In the present case, the Ministry has explained that the Women’s 77 kg category at the 2026 Senior Asian Weightlifting Championships had only five participating countries. Consequently, the top-two cut-off under Clause 6 was applied. The top-two performances were 265 kg and 260 kg, whereas the petitioner’s performance was 220 kg and that she had secured third position. The petitioner, therefore, did not satisfy the applicable benchmark under the Ministry’s Selection Criteria. The explanation furnished by the Ministry is, therefore, consistent with the language and purpose of the notified criteria and does not suffer from any apparent infirmity. 25. This Court appreciates the petitioner’s achievement and acknowledges her distinction in representing the country. However, at the same time, the Court is conscious that the Ministry’s Selection Criteria constitutes a uniform policy applicable to all athletes across the country. That criteria, therefore, has to be applied strictly and consistently, and any relaxation beyond what is expressly permitted under the policy would not only dilute the prescribed standards but also be unfair to other athletes who are governed by the same criteria. 26. This Court accordingly finds that the petitioner’s exclusion from the final list cannot be held to be arbitrary and the petitioner has failed to establish any enforceable right to a direction requiring the Ministry to forward or include her name in the final list of athletes for the Women’s 77 kg weightlifting event at the Asian Games. The relief sought would, in substance, require this Court to disregard or dilute the Ministry’s notified criteria and to direct selection of an athlete who does not satisfy the applicable eligibility requirement. Such a direction cannot be issued in exercise of writ jurisdiction. 27. For the foregoing reasons, this Court finds no infirmity in the application of the Ministry’s Selection Criteria to the petitioner’s case. 28. The writ petition is, accordingly, dismissed. 29. The judgment be uploaded on the website forthwith. DR. SWARANA KANTA SHARMA, J SEPTEMBER 07, 2026/zp W.P.(C) 12670/2026 Page 1 of 17