Judicial Deference to Racing Regulators and Deemed Approval of Race Conditions: Commentary on Ravinder Pal Singh Chauhan v. Delhi Race Club (1940) Ltd.

Judicial Deference to Racing Regulators and Deemed Approval of Race Conditions: Commentary on Ravinder Pal Singh Chauhan v. Delhi Race Club (1940) Ltd. & Ors.

I. Introduction

This commentary examines the decision of the Delhi High Court (Justice Amit Bansal) dated 26 November 2025 in CS(OS) 804/2025, on the plaintiff’s interim application (I.A. 28038/2025) under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure.

The dispute arises from regulatory changes in the conduct of horse racing at the Delhi Race Club (“DRC”), particularly the introduction of:

  • a “family unit / group” concept for ownership of race horses; and
  • caps on:
    • the total number of horses a family unit can stable with the Club; and
    • the number of horses a family unit can start in a single race.

The plaintiff, a prominent horse owner and breeder, challenged these measures as arbitrary and ultra vires the rules of the apex horse racing body, Royal Western India Turf Club Ltd. (“RWITC”, defendant no.3).

The judgment is significant for two interlinked reasons:

  • It reinforces judicial deference to specialist sporting regulators where an internal appellate mechanism is available and efficacious; and
  • It recognises, at least prima facie, the concept of “deemed approval” of race programmes and conditions by the apex body when it remains silent after receiving the prospectus from an affiliated club.

While the order deals only with interim relief, the reasoning has broader implications for sports regulation, internal remedies in private associations, and the limits of civil court intervention in technical regulatory choices (like anti-rigging safeguards in horse racing).

II. Factual and Procedural Background

1. Parties and regulatory structure

  • Plaintiff – Ravinder Pal Singh Chauhan, a horse breeder and race horse owner. His wife and daughter are also registered owners. Collectively, they own about 70 horses, of which 45 are stationed at DRC’s stables (para 8).
  • Defendant No.3 – RWITC – the principal governing and regulatory body for horse racing in Western and Northern India (para 3). It frames the Rules of Racing of Royal Western India Turf Club Ltd. (“Rules”), applicable to races run in North India, including Delhi.
  • Defendant No.1 – Delhi Race Club (1940) Ltd. – an affiliated race club of RWITC which conducts horse races in Delhi under RWITC’s Rules (para 4). It publishes a Prospectus for each racing season, setting out race dates and general conditions.
  • Defendant No.2 – an office-bearer of DRC who signed the relevant circular (para 5, 11).

It is common ground that RWITC is the central regulator and that DRC is bound to conduct races in conformity with RWITC’s Rules (para 33, 37).

2. The regulatory measures challenged

(a) RWITC’s “family unit” concept and stable cap

On 1 August 2025, RWITC issued its Racing Calendar for the 2025 season (para 6). Two important features noted in the judgment:

  • Overall limited stabling capacity: total stables for allocation = 1300.
  • Each “owner” was capped at a maximum of 80 stables.

Crucially, RWITC introduced the concept of a “family unit”:

  • Spouses and children (son/daughter) are treated as a single unit for the purpose of allocation;
  • Each such family unit is entitled to a maximum of 80 stables in total (para 7).

(b) DRC’s General Condition No. 12 for Delhi Meeting 2025–26

For the Delhi Meeting 2025–26 (16 September – 30 December 2025), DRC issued its Prospectus (para 9). It included the impugned General Condition No.12 (para 29):

“12. An Owner (family unit/group) is allowed to keep a maximum of 40 horses only including 2 year old. An owner is permitted to run maximum three horses in a race except Classics/ Sweepstakes races. An owner can train his horses with maximum three Trainers. Horses participating in Classics/Sweepstakes races are exempted.”

Thus, DRC effectively halved the RWITC 80-stable cap for its own location and, more importantly, restricted the number of runners from a family unit in any race (other than Classics/Sweepstakes) to three.

(c) DRC’s implementing circular of 11 October 2025

DRC issued an undated notice/circular (the judgment records it as 11 October 2025 – para 30), signed by defendant no.2, detailing how General Condition 12 would be implemented where a family unit made entries for more than three horses in a single race. The circular provided that:

  • “Owner” includes the family unit/group (in line with RWITC notification); and
  • if entries exceed three:
    • the connections (owner/trainer) may themselves choose any three horses; but
    • if they do not or cannot, a ballot (draw of lots) will be conducted to determine which horses will be accepted (para 30).

This “balloting out” process is central to the plaintiff’s grievance, as several of his horses were excluded in this manner.

3. Plaintiff’s grievance and alleged harms

  • On 14 October 2025, the plaintiff sought to enter three of his horses and one horse of his wife in a race. In applying the three-horse cap to the “family unit”, DRC balloted out one of the plaintiff’s horses (para 12), allegedly causing monetary and reputational loss.
  • The plaintiff protested via email (12 October 2025) and a legal notice (13 October 2025), but received no response (para 13).
  • On 5 November 2025, three more of the plaintiff’s horses were balloted out under General Condition 12 (para 14).

Consequently, the plaintiff filed a civil suit challenging:

  • the “family unit” concept as applied in General Condition 12; and
  • the circular providing for balloting out of horses beyond the three-horse cap.

The present judgment addresses only the interim injunction application under Order XXXIX Rules 1 and 2 CPC (para 1).

III. Summary of the Judgment

1. Reliefs sought at the interim stage

The plaintiff sought ex parte/interim orders (para 1):
  • restraining DRC from enforcing the “family unit” concept in relation to:
    • the number of horses that can be owned and stabled (cap of 40); and
    • the number of horses that can participate in a race (cap of three);
  • staying the operation of:
    • General Condition 12 of the Delhi Meeting 2025–26 Prospectus; and
    • the implementing circular issued by defendant no.2.

2. Core arguments

By the plaintiff (paras 16–17, 26–27)

  • Arbitrariness and discrimination: the “family unit” classification is arbitrary, irrational and discriminatory; clubbing family members as a single unit violates principles of equality among owners.
  • Ultra vires Rules of RWITC: the Prospectus amendment introducing General Condition 12 allegedly violates Rules 7 and 11 of RWITC’s Rules, as DRC lacked authority or prior approval to impose such a restriction.
  • Availability of appeal not a bar: since the plaintiff challenges the validity of General Condition 12 itself and DRC’s jurisdiction to issue it, the alternative remedy of appeal under Rule 41(h) of RWITC’s Rules is claimed to be inapplicable.
  • No proof of rigging/betting misuse: DRC’s justification of preventing rigging and abuse of betting markets was said to be unsupported by any concrete instance (para 27).

By the defendants (paras 18–25)

  • Purpose: prevent monopolisation and rigging – the three-horse cap for a family unit in a race is aimed at preventing monopolisation of fields and eliminating the potential mischief of race-rigging in the backdrop of heavy betting (para 18).
  • Existing discretionary power – Condition 1(j) of the Prospectus (unchallenged) authorises Stewards to refuse or cancel entries without reasons; this undercuts the claim of plaintiff’s absolute right to field any number of horses (para 19).
  • Deemed approval by RWITC – DRC sent the 2025–26 Prospectus, including General Condition 12, to RWITC on 16 September 2025; it was published on 19 September 2025. RWITC raised no objection, and several Race Meetings were already held under it (para 20). This, defendants argue, amounts to “deemed approval”.
  • Acquiescence / approbation and reprobation – plaintiff participated in races under the Prospectus and won prize money; he cannot now challenge one of its conditions (para 21).
  • Alternative remedy under RWITC Rules – plaintiff has a clear right of appeal to RWITC’s Stewards and then to the Board of Appeal (Rules 36(b), 41(h), 46, 49(c) – paras 34–36). On that basis, defendants contend the civil suit and injunction are not maintainable, citing:
  • No direct approach to RWITC – plaintiff did not raise his grievance before RWITC at all (para 24). RWITC (defendant no.3) expressly offers to adjudicate any appeal filed by the plaintiff (para 25, 38).

3. Key findings

The Court’s central conclusions can be summarised as follows:
  1. Prima facie rationality of the “family unit” three-horse cap – At the interim stage, the Court accepts that limiting a family unit to three runners per race is a rational measure to prevent monopolisation and potential rigging, given heavy betting on races (paras 31–32). The Court notes a concrete instance where, for a race on 14 November 2025, six out of eight entries belonged to the plaintiff and his family (para 31).
  2. Existence of a detailed internal appellate mechanism – The RWITC Rules provide an elaborate appellate structure:
    • Appeal from Stewards of the Meeting (DRC) to Stewards of the Club (RWITC) – Rule 36(b);
    • Powers of RWITC Stewards to decide all matters relating to racing – Rule 41(h), (i);
    • Further appeal to Board of Appeal – Rule 46(a);
    • Expeditious disposal within 15 days and power to grant stay – Rule 49(c).
    The Court emphasises that such appeals are to expert bodies familiar with the intricacies of horse racing and therefore more suitable to adjudicate such disputes (paras 36, 39).
  3. Grievance is fully amenable to the internal appellate mechanism – Based on the plaintiff’s own pleadings acknowledging RWITC’s central regulatory role (para 37), the Court finds nothing that would prevent the appellate authorities from considering the validity or propriety of General Condition 12 and the 11 October circular (para 38, 42). RWITC’s expressed willingness to entertain an appeal strengthens this conclusion (para 38).
  4. Deemed approval of the Prospectus by RWITC – Interpreting Rules 7 and 11 of the RWITC Rules, the Court holds that:
    • Rule 7, requiring that programmes and race conditions be “approved” by RWITC’s Stewards, does not insist on “written” approval (para 47); and
    • Rule 11 empowers RWITC Stewards to prohibit, modify or rescind conditions even after publication; their failure to do so, despite receiving the Prospectus on 16 September 2025 and races being conducted under it, amounts prima facie to deemed approval (paras 44–48).
    The plaintiff’s ultra vires contention is, therefore, not accepted at this stage (para 48).
  5. Equally efficacious remedy bars interim injunction – Applying Section 41(h) of the Specific Relief Act (via reliance on Barfo Devi) and the general principle that courts decline injunctions where an equally efficacious alternative remedy exists, the Court holds that the plaintiff’s remedy lies in the internal appellate mechanism, not in civil court injunctions (paras 40–42, 49–50).
  6. Classical injunction tests not satisfied – The Court finds:
    • No prima facie case warranting interim interference (para 49);
    • No balance of convenience in favour of the plaintiff (para 50);
    • No irreparable harm demonstrated that cannot be addressed through the appellate process (para 50).
    The interim application is therefore dismissed (para 51).
  7. Limited scope of findings – The Court expressly clarifies that all observations are prima facie and will not prejudice the final adjudication of the suit or any appeal that may be filed before RWITC (para 52).

IV. Detailed Analysis

A. Precedents and the Principle of “Equally Efficacious Remedy”

1. Barfo Devi v. DDA, 2009 SCC OnLine Del 2235 (para 40)

In Barfo Devi, a Division Bench of the Delhi High Court held that an injunction could not be granted where a statutory alternative remedy (appeal to the Deputy Commissioner under the Delhi Land Reforms Act) was available and efficacious. The Court directly relied on Section 41(h) of the Specific Relief Act, which states that:

“An injunction cannot be granted … when equally efficacious relief can certainly be obtained by any other usual mode of proceeding except in case of breach of trust.”

The relevant passage reproduced in the present judgment (para 40) underscores two points:

  • The availability of an effective remedy in another forum “takes away the right of injunction”; and
  • A litigant cannot bypass an available appeal mechanism and rush to civil court for interim relief.

Justice Bansal uses this principle to reason that the plaintiff, who has a full appellate route under RWITC Rules, cannot insist on a civil court injunction to dismantle a regulatory condition when he has not even attempted to use the specialist forum.

2. Pesi Shroff v. State Of Maharashtra (Bombay High Court, 1992) (para 22, 41)

Although only briefly mentioned, Pesi Shroff is particularly relevant because it also concerned horse racing regulation and RWITC. There, the Bombay High Court declined to entertain a writ petition (public law remedy) on the ground that RWITC’s internal appellate provisions provided an adequate alternative remedy.

In the present case, Justice Bansal extends similar reasoning to a civil suit context: where a private sports regulator has a built-in, structured appellate process, a civil court should ordinarily decline to intervene at the interim stage, especially when that process can grant both merits relief and interim stay (Rule 49(c)).

B. The Court’s Legal Reasoning

1. Prima facie validity of the “family unit” cap

The plaintiff characterises the “family unit” concept as discriminatory and irrational. The Court’s response (paras 31–32) is measured and tailored to the interim stage:

  • Horse racing is heavily intertwined with betting; field composition can affect odds, market behaviour, and susceptibility to “rigging”.
  • If a single owner/family controls a large portion of the field, the potential for collusive tactics (e.g., pace manipulation to assist a particular horse, team tactics) becomes significant.
  • DRC produced an instance where 6 out of 8 horses in a race slated for 14 November 2025 were from the plaintiff’s family unit (para 31). This concrete data point supports the concern about monopolisation rather than a hypothetical fear.

Against this factual backdrop, the Court holds that it cannot, at this stage, fault the regulatory choice to impose a three-horse cap per family unit:

“As a regulatory body, it is the responsibility of the defendants to ensure that races are conducted in a free and fair manner. Therefore, on the face of it, there appears to be a rational nexus with the objective sought to be achieved, i.e. the elimination of rigging in a horse race.” (para 32)

Thus, the classification between: (i) family units that seek to run more than three horses in one race, and (ii) all other owners, is prima facie found to have a:

  • legitimate objective – fair racing and protecting integrity of the sport; and
  • rational nexus – limiting the numerical dominance of a single economic interest in any race.

The Court does not undertake a full Article 14–style scrutiny (this is a dispute involving a private regulator, and the order is interlocutory), but the reasoning implicitly aligns with “reasonable classification” analysis: the measure is neither manifestly arbitrary nor lacking in rational connection to its stated goal.

2. Central role of the internal appellate mechanism

The heart of the judgment lies in paras 34–39, where the Court sets out RWITC’s appellate scheme and measures its adequacy.

(a) Structure of the appellate scheme
  • First appeal – Rule 36(b):
    “An appeal shall lie to the Stewards of the Club from every decision or order of the Stewards of the Meeting…”
    Here, “Stewards of the Meeting” refers to DRC (the local club), while “Stewards of the Club” refers to RWITC (the apex body).
  • Jurisdictional breadth – Rule 41(h), (i):
    • Rule 41(h): RWITC Stewards may decide appeals from decisions/orders of the Stewards of the Meeting “on every matter” (subject to a narrow exception about objections on race placings).
    • Rule 41(i): They can “make enquiry into, finally decide and deal with all matters relating to racing … whether or not referred to them by the Stewards of the Meeting.”
    These provisions are very wide – covering virtually all racing-related issues.
  • Second appeal – Rule 46(a):
    “An Appeal shall lie to the Board of Appeal from any decision or order of the Stewards of the Club…”
  • Procedural safeguards – Rule 49(c):
    • Appeals to be “as far as possible” disposed of within 15 days from filing.
    • Power to grant stay of the Stewards’ decision during pendency of appeal.

Collectively, these rules establish a quasi-judicial, layered mechanism within the sport’s own governance framework, promising both speed and expertise.

(b) Applicability to the plaintiff’s grievance

The plaintiff argues that since he challenges the “jurisdiction” of DRC to impose General Condition 12 and the very “validity” of that condition, the appellate mechanism is inapplicable. Justice Bansal rejects this distinction, noting (paras 37–38) that:

  • The plaintiff himself pleads that RWITC is the central authority analogous to a “national regulator”, and its Rules govern all races at DRC;
  • He acknowledges that:
    • Stewards of DRC handle day-to-day conduct and supervision of races; but
    • Stewards of RWITC retain ultimate authority over rule-making, approval of programmes and general conditions.
  • On this very reading, RWITC is precisely the body that can examine whether DRC was within its authority under the Rules and whether General Condition 12 should stand.

The Court thus concludes that the plaintiff’s challenges (including ultra vires arguments and allegations of arbitrariness) are well within the competence of the RWITC appellate process (para 38, 42). There is no doctrinal or textual barrier in the Rules to prevent RWITC or its Board of Appeal from:

  • striking down, modifying, or clarifying General Condition 12;
  • disapproving DRC’s circular; or
  • granting tailored relief vis-à-vis the plaintiff’s entries and participation.

3. Deemed approval under Rules 7 and 11

A central legal attack by the plaintiff is that DRC could not unilaterally introduce General Condition 12 without explicit prior approval from RWITC, making the condition ultra vires Rules 7 and 11.

(a) Text of Rules 7 and 11
  • Rule 7:
    “The full programme of every Race Meeting and the conditions of every race shall be approved by the Stewards of the Club before they are published in the Racing Calendar.”
  • Rule 11:
    “The Stewards of the Club may, at their discretion, refuse to sanction any Race Meeting and may prohibit the advertisement of any race or Race Meeting in the Racing Calendar. They may also call upon the Stewards of the Meeting to alter or modify or rescind any conditions even after the publication of the Racing Calendar. Further, the Stewards of the Club shall also have the power, suo moto, to alter or modify or rescind any conditions even after the publication of the Racing Calendar.”
(b) Practice and inference of deemed approval

Defendants asserted a 30-year practice: DRC sends its Prospectus each season to RWITC; no formal written sanction is issued; RWITC raises objections only if it disagrees; otherwise, silence is treated as approval (para 44).

In 2025–26:

  • Prospectus containing General Condition 12 was sent to RWITC on 16 September 2025;
  • It was published on 19 September 2025 (para 45);
  • RWITC raised no objection; instead, several race meetings were conducted under it; the plaintiff’s horses participated and even won prize money (paras 21, 45).

Justice Bansal makes two interpretive moves (paras 47–48):

  1. Rule 7 does not stipulate form of “approval” – it does not require an express or written order. Therefore, long-standing regulatory practice of deemed approval by silence is not excluded by the text.
  2. Rule 11 contemplates RWITC’s power to require changes “even after publication” or to act suo motu. The fact that RWITC did not call upon DRC to modify or rescind any condition, despite receiving the Prospectus and seeing races conducted under it, reinforces an inference that RWITC considered the Prospectus acceptable.

On this basis, the Court reaches a prima facie finding of “deemed approval”:

“I am of the prima facie view that since no objection has been raised by 'Stewards of Club' in respect of the aforesaid Prospectus and races are being conducted in terms thereof, this would amount to a deemed approval.” (para 48)

This is an important doctrinal development within sports regulation: silence by an apex body, in a framework where it has both prior approval and post-publication modification powers, can be treated as tacit approval at least for interim purposes.

4. Application of the three classic injunction tests

(a) Prima facie case

A “prima facie case” does not mean the plaintiff must show he is certain to succeed; rather, he must present a serious question, not frivolous or vexatious, warranting trial. However, where:

  • the measure (three-horse cap) appears rationally connected to legitimate regulatory goals;
  • the appellate mechanism is available and adequate; and
  • the ultra vires argument is undercut by deemed approval,

the Court finds that no prima facie right to immediate injunctive relief is established (para 49). The plaintiff’s arguments might still be examined at trial or in the internal appeals, but they do not justify urgent disruption of the regulatory scheme.

(b) Balance of convenience

The balance of convenience asks: which side would suffer more if the injunction is granted or refused?

  • If injunction is granted – DRC’s anti-monopolisation safeguards would be suspended. The integrity of race outcomes, and public confidence (including betting markets), could be affected. Races might once again be dominated numerically by single family units.
  • If injunction is refused – the plaintiff’s family unit remains constrained to three runners per race, but he can still:
    • race horses in multiple races;
    • use the appellate mechanism for bespoke relief or modification of conditions; and
    • obtain compensation or corrective orders if he ultimately prevails.

Given these competing harms, and the fact that an expert appellate forum exists and is willing to act expeditiously, the Court holds that the balance of convenience does not favour granting injunction (para 50).

(c) Irreparable injury

“Irreparable injury” is harm which cannot be adequately compensated in money or cured later through remedial orders. The Court is not convinced that:

  • balloting out of some horses in a few races, while the appellate process remains available; or
  • reputational concerns regarding race participation,

meet this threshold, especially when:

  • the plaintiff has already participated and won prize money under the same Prospectus; and
  • Rule 49(c) allows RWITC’s Board of Appeal to grant interim stay in appropriate cases.

Thus, no irreparable injury justifying an extraordinary injunction is found (para 50).

5. Limiting the precedential impact: prima facie observations

Importantly, the Court emphasises (para 52):

“Needless to state, any observations made hereinabove would have no bearing on the final adjudication of the case or on the outcome of the appeal that may be filed by the plaintiff under the Rules of the defendant no.3.”

This caveat performs two functions:

  • It preserves the jurisdiction of the trial court to reach a different conclusion at final adjudication based on fuller evidence; and
  • It preserves the autonomy and discretion of RWITC’s appellate bodies to independently judge the legality and desirability of General Condition 12 and the circular.

V. Impact and Implications

1. Strengthening the autonomy of sports regulators

The judgment reinforces a broader trend in Indian jurisprudence: judicial reluctance to interfere prematurely with specialist regulatory frameworks in sports, especially where:

  • the regulator has an internal quasi-judicial mechanism; and
  • disputes concern the technical design of competition rules (here, race field limits and anti-rigging safeguards).

By directing the plaintiff towards RWITC’s appeals, the Court signals that civil courts should be slow to grant injunctions that effectively override policy choices of expert bodies, unless those choices are demonstrably illegal, mala fide, or constitutionally infirm in a clear and immediate way.

2. Recognition of “deemed approval” in self-regulatory sports structures

The Court’s acceptance of “deemed approval” (paras 44–48) has practical consequences for:

  • Affiliated clubs – They can rely on a long-standing administrative practice of sending prospectuses/programmes to the apex body and proceeding in the absence of objections, rather than waiting indefinitely for express clearance.
  • Apex bodies – RWITC, and similar entities in other sports, must be conscious that their silence may be read as acquiescence or approval. If they intend to withhold approval or modify a condition, they should act and record their position promptly.

This concept fits naturally with Rule 11’s design, which envisages continuous supervisory jurisdiction by the apex body, before and after publication.

3. Guidance for litigants in sports disputes

For owners, trainers, and other stakeholders in horse racing (and by analogy, other sports):

  • Internal appeals are not merely formalities; courts may insist that they be exhausted before approaching civil or writ courts, especially for interim relief.
  • Where internal rules provide for:
    • multi-tier appeals,
    • time-bound disposal, and
    • interim stay powers,
    a plea of “inefficacy” of that remedy will be hard to sustain.
  • Challenging the validity of rules or conditions may not be enough, by itself, to bypass the regulatory appellate structure, where those very bodies have power to examine, amend, or rescind the conditions.

4. Substantive fairness in private regulatory regimes

Although the Court does not conclusively adjudicate on discrimination or equality, it sends a signal that private regulators (like RWITC and DRC) must ground their conditions in:

  • legitimate policy goals (e.g., integrity of competitions, fair play); and
  • measures reasonably connected to those goals (e.g., caps on number of starters per owner/family).

Regulators that can demonstrate a clear rationale – as DRC did with betting and monopolisation concerns – are more likely to withstand challenges of arbitrariness, at least at the interim stage.

5. Limited but noteworthy precedent

Formally, this is an order on an interim application; it does not settle the underlying legal issues finally. Nonetheless, two principles of continuing importance can be distilled:

  1. Where a specialist sports regulator provides a structured, expert appellate mechanism, civil courts will be disinclined to grant injunctions under Section 41(h) of the Specific Relief Act, absent compelling reasons.
  2. Within such regulatory frameworks, “approval” of race conditions can, in appropriate circumstances and consistent with established practice, be inferred from the apex body’s silence and continued conduct, amounting to deemed approval.

VI. Complex Concepts Simplified

1. Prima facie case, balance of convenience, and irreparable injury

  • Prima facie case – The plaintiff must show that there is a serious question to be tried; his claim is not frivolous; and there is some supporting material. It does not require certainty of winning, but it does require more than mere allegation.
  • Balance of convenience – The court compares the likely harm to each side if the injunction is granted or refused. If refusing the injunction would harm the plaintiff far more than granting it would harm the defendant, the balance may favour the plaintiff (and vice versa).
  • Irreparable injury – Injury that cannot be adequately compensated by money or future remedial orders. For example, permanent loss of opportunity or rights; destruction of core business; or damage that cannot be reversed later. In this case, the Court held that being temporarily limited to three starters per race does not meet this standard, particularly with an effective internal appeal available.

2. “Equally efficacious remedy” and Section 41(h) of the Specific Relief Act

Section 41(h) prohibits granting an injunction where the plaintiff has an equally efficacious alternative remedy available by another usual mode of proceeding (except breach of trust).

Here, the RWITC appellate mechanism is:

  • Equally efficacious – it can:
    • entertain appeals on all racing matters,
    • grant stays, and
    • decide disputes on merits.
  • More appropriate – as it is made up of domain experts in horse racing and can consider operational and technical aspects better than a generalist civil court, especially at the interim stage.

3. “Deemed approval”

“Deemed approval” is a legal concept where approval is inferred not from an explicit act (like a written order), but from circumstances such as:

  • the duty-holder (here, RWITC) being informed of a proposal (the Prospectus);
  • rules allowing it to object or modify; and
  • its decision to remain silent and allow implementation without objection.

In regulatory practice, this can be justified where:

  • there is a consistent long-term practice of treating silence as approval; and
  • the regulator retains power to step in later if needed (as under Rule 11).

4. “Family unit” classification in horse racing

The “family unit” concept aggregates spouses and children as a single ownership unit for regulatory purposes. Its goals are typically:

  • preventing dilution of caps by splitting ownership among related persons;
  • ensuring that regulatory limits (like stabling caps or starter caps) have real effect; and
  • curbing potential conflict-of-interest or collusive tactics when multiple related owners control many horses in a race.

Here, both RWITC (at the stable allocation level) and DRC (at the race-entry level) used the “family unit” notion to prevent concentration of horses – first at the stabling stage (80 horses per family unit in RWITC’s calendar) and then at the starter stage (40 horses stabled and maximum three runners per race in DRC’s Prospectus).

5. “Stewards of the Meeting” vs “Stewards of the Club”

  • Stewards of the Meeting – Officials responsible for the conduct of individual race meetings at a specific venue (e.g., DRC). They oversee race-day operations and immediate regulatory decisions (like accepting or rejecting entries).
  • Stewards of the Club – Officials of the apex club (RWITC) who:
    • approve racing programmes and conditions (Rule 7);
    • exercise supervisory powers (Rule 11); and
    • hear appeals from decisions of Stewards of the Meeting (Rule 36(b), Rule 41).

This dual structure allows local flexibility with central oversight and appellate correction.

6. “Balloting out” of horses

“Balloting out” is a neutral allocation mechanism used when the number of eligible entries exceeds the permitted starters. A draw of lots is conducted to decide which horses will participate, thus avoiding subjective or biased exclusion.

In this case, balloting is triggered only when a family unit tries to enter more than three horses in a race and the connections do not themselves choose which three should run. It is a method of enforcing the three-horse cap while minimising allegations of partiality.

VII. Conclusion

The interim order in Ravinder Pal Singh Chauhan v. Delhi Race Club (1940) Ltd. & Ors. is a measured assertion of judicial restraint in the face of specialised sports regulation. Without foreclosing the plaintiff’s substantive challenge, the Court:

  • upholds, prima facie, the rationality of the “family unit” three-horse cap as an anti-rigging measure;
  • affirms the importance and adequacy of RWITC’s internal appellate structure, treating it as an “equally efficacious remedy” that precludes civil court injunctions at this stage;
  • recognises “deemed approval” of race conditions by the apex body in the absence of objection, harmonising Rule 7 and Rule 11 with long-standing regulatory practice; and
  • applies orthodox injunction principles (prima facie case, balance of convenience, irreparable injury) to decline interference with existing race conditions mid-season.

In the broader legal context, the judgment underscores that:

  1. Where well-designed internal appeal mechanisms exist in sports governance, courts will increasingly insist that they be used and respected before judicial intervention is sought.
  2. Private regulators exercising quasi-public functions must nevertheless ground their rules in clear policy objectives and defensible classifications to survive scrutiny, even if that scrutiny is initially light-touch at the interim stage.

The final outcome of the suit and any appeals before RWITC remain open. Yet, this decision already contributes meaningfully to Indian sports law by articulating a principled balance between regulatory autonomy and judicial oversight, and by clarifying how approval and appellate review operate within the specific context of horse racing regulation.

Case Details

Year: 2025
Court: Delhi High Court

Judge(s)

Justice Amit Bansal

Advocates

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