We are hence unable to agree with the conclusion of the learned Judge that the use of the term ‘athlete’ in clause 4(a) would not stand attracted in the case of participants in team sports
- [21/02, 08:00] sekarreporter1: 2025:MHC:2384
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
RESERVED ON : 09.09.2025
PRONOUNCED ON : 26.09.2025
CORAM:
THE HONOURABLE DR.JUSTICE ANITA SUMANTH AND
THE HONOURABLE MR.JUSTICE C.KUMARAPPAN
W.A.(MD)No.2419 and 2320 of 2025 and
C.M.P.(MD)No.13771, 13131 & 14176 of 2025
W.A.(MD)No.2419 of 2025:
The Member Secretary/Chief Executive Officer,
Sports Development Authority of Tamil Nadu,
Jawaharlal Nehru Stadium,
Raja Muthiah Road, Periymet, Chennai. …Appellant
/Vs./
1. Sivakumar
2. The Additional Chief Secretary to Government of Tamil Nadu, Department of Sports, Development and Youth Welfare, Secretariat, Chennai.
3. The Secretary, The Selection Committee,
Directorate of Medical Education and Research,
No.162, Periyar EVR High Road,
Kilpauk, Chennai – 600 010. …Respondents
PRAYER:- Writ Appeal – filed under Clause 15 of Letters Patent Act, to set aside the order made in W.P.(MD)No20012 of 2025 dated 30.07.2025 on the file of this Court.
For Appellant : Ms.N.S.Tanvi
For Respondent : Mr.P.Ganapathi Subramanian (R1)
Mr.J.Ashok (R2)
Additional Government Pleader
Ms.Sneha Muddha (R3)
Special Counsel
W.A.(MD)No.2419 of 2025:
1. The Secretary,
The Selection Committee,
Directorate of Medical Education and Research, No.162, Periyar EVR High Road, Kilpauk, Chennai – 600 010.
2. The Additional Chief Secretary to Government of Tamil Nadu,
Department of Sports,
Development and Youth Welfare, Secretariat, Chennai. …Appellants
/Vs./
1. Sivakumar
2. The Member Secretary/Chief Executive Officer,
Sports Development Authority of Tamil Nadu,
Jawaharlal Nehru Stadium,
Raja Muthiah Road,
Periymet,
Chennai. …Respondents
PRAYER:- Writ Appeal – filed under Clause 15 of Letters Patent Act, to set aside the order made in W.P.(MD)No20012 of 2025 dated 30.07.2025 on the file of this Court and allow the writ appeal.
For Appellants : Ms.Sneha Muddha
For Respondent : Mr.P.Ganapathi Subramanian (R1)
Ms.N.S.Tanvi (R2)
COMMON JUDGMENT
(Judgment of the Court was made by DR.ANITA SUMANTH, J.)
These appeals challenge an order of the writ Court dated 30.07.2025. The facts in brief premised on which the writ petition was filed are as follows. Sivakumar, R1, is the father of Harini (‘candidate’), who has achieved laurels in the event of shooting ball, in both national and international events.
2. The candidate had appeared for the NEET undergraduate examination for medical college admission for academic year 2025-26 under the sports persons category, seeking 900 marks for her participation in various competitive events. She had however been awarded only 200 marks for participation, which according to her is contrary to the stipulations under the prospectus. R1 had thus preferred a writ petition seeking a mandamus for awarding of 900 marks for her achievement in sports and for consideration of her candidature for medical college admission based on those marks.
3. The writ Court allowed the writ petition concluding that her participation in the Shooting Ball World Cup and Asian Shooting Ball Championship, entitled her to 900 points as claimed. In arriving at this conclusion, the prospectus was interpreted to state that the eligibility conditions in paragraph 4(a) of Annexure VII would apply only to individual sporting events and not team events such as shooting ball, volley ball, football, basket-ball and others.
4. Upon such interpretation, the Court held that there was nonecessity for participation of seven different countries in the tournaments in which the candidate had competed and hence that condition should not be imposed in her case to deny her 900 marks. The Court has also referred to the Indian Olympics Committee (IOC) Code of Ethics, emphasizing the importance of a quota for sportsmen and the encouragement to be extended to them.
5. The Writ Court has relied upon the judgments of the Hon’ble
Supreme Court in S.Krishna Sradha Vs. State of Andhra Pradesh and
Others (2020 (17) SCC 465) and Dev Gupta Vs. PEC University of Technology and Others (2023 (20) SCC 166) and of this Court in V.Periyadurai vs. The Principal Secretary, Health and Family Welfare and Others (WP(MD)No.5209 of 2017 dated 20.07.2017) .
6. As against that order, the Sports Development Authority of India
(SDAI) and the Department of Sports Development and Youth Welfare, State of Tamilnadu have preferred the present writ appeals.
7. The submissions of Ms.Sneha Muddha and Ms.N.S.Tanvi,
learned counsel for the appellants are to the effect that participation of the candidate in the first Shooting Ball World Cup and second Asian Shooting Ball Championship cannot be taken into account, as those events did not have the participation of seven countries as required under the prospectus. The purpose of imposition of the condition is to ensure that the recognition awarded by way of incentive marks has a proper basis and that there was sufficient international participation in that event.
8. Learned counsel appearing for the appellants would emphasize that there has to be a methodology by which recognition may be accorded. They would urge that all participants in sports events are ‘athletes’ and the exclusion of team players from the definition of ‘athlete’ is incorrect as seen from the IOC Code and the definitions under the National Anti-Doping Act, 2022 (‘NAD Act’).
9. We have heard learned counsel and studied the relevant papers.
10. The candidate had sought admission to medical colleges on the
basis of her exemplary performance in the sport of shooting ball, seeking
900 marks for securing a gold medal in the second Asian Shooting Ball Championship held at Nepal on 01.02.2025 and 02.02.2025 and bronze medal in the first World Cup Shooting Ball Championship held in New Delhi on 02.03.2024 and 03.03.2024.
11. She was denied the aforesaid mark and instead, awarded 100 marks for participating in the National tournaments held in Odisha and Ghaziabad, Uttar Pradesh between 07.01.2025 to 09.01.2025, and 29.03.2024 to 31.03.2024 respectively.
12. The denial was on the basis that International tournaments fall under category I in the prospectus, that required the candidate to have participated in a tournament with minimum participation of seven countries. In addition, the tournaments ought to have been approved by the Indian Olympics Association (IOA), Sports Authority of India (SAI) and Ministry of Youth Affairs and Sports (MYAS).
13. Admittedly, neither of the tournaments had participants from seven countries, both the Asian Shooting Ball Championship and World Cup Shooting Ball Championship having participation only from three
countries.
14. The procedure for admission to medical colleges includes counselling for special categories such as children of ex-service men, persons with benchmark disability and eminent sports persons and stringent verification of the original certificates produced in support of the claim by the candidates. Seven seats were reserved for MBBS and one in BDS course for eminent sports persons. The mode of selection is as per the guidelines set out in Annexure VII, extracted below:-
ANNEXURE-VII
ALLOTMENT OF SEATS FORCANDIDATES
UNDER QUOTA FOR EMINENT SPORTS PERSONS FOR 2025-2026 SESSION
1. The purpose of this quota is to recognise and give weightage to the sports eminence of the candidates and hence marks for sports achievements alone will be considered in ranking the candidates. The candidates are expected to continue good performance in sports, even admission.
2. The candidate shall submit all the sports certificates along with participation certificates and relevant forms issued by Association / Federation concerned, but only one highest achievement in a tournament (among the International, National, State, Regional and District) in an academic year will be considered for awarding marks. (Refre
recognized Association list is annexed)
3. Selection of the candidate will be based on the marks obtained by the candidate strictly following the guidelines, given in the tables.
Table (I) – Marks for Recognised International Achievement
Sl. No. Competition Gold Silver Bronz e Partic ipatio n
1. International (Representing India Category – IA, IB) -Once in 4 years 1000 850 650 400
2. International (Representing India Category – II) Once in 2 years 500 450 400 250
3. International (Representing
India Category – III) Once in Every year 400 350 300 200
Table (II) – Marks for Recognised National Achievement
Sl. No. Competitions Gold Silver Bronz e Partic ipatio n
1. National
Championships/National
Games-Organised by National
Federations/IOA 190 160 130 100
2. School Games Federation of
India (SGFI) National Level Competition 190 160 130 100
3. KHELO India Youth Games -National Level 190 160 130 100
Table (III) – Marks for Recognised State Championship and State Competition
Sl.No. Competitions Allocation of Marks
Gold Silver Bronz e Partici pation
1. State Championship
Revenue District-Organised by State Sports Associations 95 80 65 45
2. Bharathiyar day Sports Meet (State Level) 95 80 65 45
3. Republic days Sports Meet (State Level) 95 80 65 45
4. KVS/CBSE/CISCE (ICSE)
Board National Sports Meet 95 80 65 45
5. SDAT-State level Chief 95 80 65 45
Minister’s Trophy for Sports & Games
Table (IV) – Marks for Recognised Regional Level Achievements
Sl. No. Competitions Allocation of Marks
Gold Silver Bronze Participati on
1. KVS/CBSE/CISC
E (ICSE) Board
National Sports
Meet (Regional
Level) 60 45 30 10
Table (V) – Marks for Recognised District Level Achievements
Sl
.
N
o. Competitions Allocation of Marks
Gold Silver Bronze Partici pation
1. District Tournaments / Sports Meet /
Championships conducted by
District Associations (Recognised by
SDAT/TNOA) 45 30 15 5
2. District / Education District Inter School Competition (District Level) 45 30 15 5
3. SDAT – District Level Chief
Minister’s Trophy for Sports & Games 45 30 15 5
Table (V-A) – Marks for University Level Competitions only for PG Admission
Sl.
N
o. Competitions Allocation of Marks
Gold Silver Bronz e Partici pation
1. Inter Collegiate Competitions (Zonal & Inter Zonal Level)(Recognized by concerned University) 45 30 15 5
2. South Zone Inter University Competitions conducted by
Association of Indian Universities. 95 80 65 45
3. All India Inter University competitions conducted by Association of Indian Universities. 190 160 130 100
4. Khelo India University Games 190 160 130 100
Gold (I Position) Silver (II Position) Bronze (III Position)
4. (a) Guidelines For International Tournaments:
Category-I : (1-A) Olympic Games (Summer/Winter), Youth Olympic Games (Summer/Winter Commonwealth Games and Asian Games (Games organized in 4 years frequency by the International Olympic Committee).
(1-B) World Championship, Commonwealth championship, World Cup- (organized in 4 Years frequency by the International Sports Federations).
Eligibility for athletes requires participation in an event involving at least seven different countries and such competitions should have been approved by Indian Olympics Association (IOA), Sports Authority of India (SAI) and Ministry of Youth Affairs and Sports (MYAS).
Category-II: World Championship, World cup, Asian Championship, SAF Games (South Asian Games).
Commonwealth championship Organized in 2 years frequency by the International Sports Federation.
Eligibility for athletes requires participation in an event involving at least seven different countries and such competitions should have been approved by Indian Olympics Association (IOA), Sports Authority of India (SAI) and Ministry of Youth Affairs and Sports (MYAS). Open or Invitational or Memorial or any indifferent nomenclature or title of tournaments or Championships at International level, not approved by any of the above authority will not he considered for marks.
Category-III: Asian Championships, Commonwealth Games,
World cup, World Championship, Grand Prix, Grand slam – Organized in Every year by the International Sports
Federation. Eligibility for athletes requires participation in an event involving at least seven different countries and such competitions should have been approved by Indian Olympics Association (IOA), Sports Authority of India (SAI) and Ministry of Youth Affairs and Sports (MYAS), Government of India.
1. Participation or achievement in International tournaments will be considered only with earlier achievements at National and State level tournaments. Direct participation / Selection trails / Camps any International or National tournaments will not be considered for award of marks.
2. The highest achievement in only one annual regular tournament, officially conducted in a regular manner by the member National Olympic Committee (NOCs) authorized by the International Olympic Committee (IOC) or International Sports Federations affiliated to the IOC will be considered for award of marks. The Players/ Sports person representing the Country in such tournaments through Indian Olympic Association (IOA) or respective National Sports Federations recognised by the Ministry of Youth Affairs and Sports, Government of India or IOA will be considered for award of marks in each year.
3. Only tournaments officially recognised by the Indian Olympic Association/respective official National Sports Federations recognized by MAYS will be considered for the award of marks (for each year) from 01.06.2021 to 31.05.2022, 01.06.2022 to 31.05.2023, 01.06.2023 to 31.05.2024 and
01.06.2024 to 31.05.2025.Certificates of Participation or Achievements in tournaments, submitted along with Form I alone are eligible for marks indicated in Table (I) above (should be submitted before the last date of submission of application).
15. Tables I to V-A set out the marks for according recognition for
International, National, State, Regional, District and University Level Competitions. Clause 4(a) thereof stipulates guidelines for international tournaments and the eligibility criteria are (i) participation in an event where at least seven countries have participated and (ii) the competitions should be approved by IOA, SAI and MYAS. Eligibility for tournaments in categories II and III are similar.
16. The learned Judge has concluded that the expression ‘athlete’ used in 4(a), applies only to persons who have participated in individual events such as running and jumping, also incidentally noting that any person associated with sports can be referred to as an athlete.
17. Section 2(d) of the NAD Act defines an ‘athlete’ as ‘any person
who competes in any sport at the national level or international level or participates in any competition or event to which this Act applies.’
18. We are hence unable to agree with the conclusion of the learned Judge that the use of the term ‘athlete’ in clause 4(a) would not stand attracted in the case of participants in team sports and that consequently the eligibility criteria prescribed in clause 4(a) does not apply to the candidate.
19. On the other hand, every participant in a sporting activity, be it an individual sport or a team event, is an ‘athlete’ and hence, eligibility criteria for an athlete (including those who have participated in team events) would require the participation of a minimum of seven countries in that event, to be entitled to the benefit of the quota.
20. The other point that has weighed with the writ Court, is that Shooting Ball is an indigenous Indian sport and ought to have been accorded preferential treatment in the prospectus. On this score, we agree. Our attention has been drawn to the prospectus issued by other States, where preferential treatment has been accorded to indigenous Indian sports. While we wish that the prospectus in question had, likewise, provided for some preference to indigenous sports, unfortunately, that is not to be, and the present prospectus does not provide for any such preferential treatment.
21. In such circumstances, unless there had been a challenge to the prospectus perse, we cannot read into the prospectus a preference that it does not contain. However, we recommend strongly, that this aspect of the matter be taken into account, and preference is accorded to participants in indigenous sports, going forward. The undertaking of Ms.Sneha Muddha on 30.07.2025 that a seat would be reserved for the candidate, as recorded in the interim order dated 30.07.2025 is hence recorded redundant.
22. In the light of the discussion as above, we intervene in the order of the writ Court and reverse the same. These writ appeals are allowed.
No costs. Consequently, connected Miscellaneous Petitions are closed.
[A.S.M.J.,] & [C.K.J.,]
26.09.2025
NCC :Yes/No
Index :Yes/No Internet :Yes sm
TO:-
1. The Additional Chief Secretary to Government of Tamil Nadu,
Department of Sports,
Development and Youth Welfare, Secretariat, Chennai. DR.ANITA SUMANTH, J.
AND C.KUMARAPPAN, J. sm
Pre-Delivery Judgment made in
W.A.(MD)No.2419 and 2320 of 2025
Dated: .2025
[21/02, 08:00] Meta AI: The Madras High Court has reversed the writ court’s decision, stating that the candidate’s participation in the Shooting Ball World Cup and Asian Shooting Ball Championship doesn’t qualify for 900 marks. The court held that the eligibility criteria for international tournaments require participation of at least seven countries, which wasn’t met in this case. The court also noted that the prospectus doesn’t provide preferential treatment for indigenous sports like Shooting Ball, and any such change would need to be addressed in the prospectus itself. ¹
Key points:
– The candidate participated in tournaments with only 3 countries.
– The prospectus requires 7 countries for Category I international tournaments.
– The term ‘athlete’ applies to both individual and team sports participants.
– The court recommends preferential treatment for indigenous sports in future prospectuses.
Would you like to know more about the implications of this ruling on sports quotas or similar cases in India?
