Delhi High Court: While hearing an application under Order 39, Rules 1 and 2 of the Civil Procedure Code, 1908, seeking a temporary injunction restraining the Delhi Race Club (‘DRC’) from enforcing the ‘family unit’ cap vis-à-vis horse racing, the Single Judge Bench of Amit Bansal, J, upheld the concept of family unit qua the number of horses that may be owned by a family. The Court held that the purpose of inclusion of such a condition is to prevent monopolization and potential rigging of horse races. Accordingly, the Court refused to grant an interim injunction and dismissed the application.
Background
The plaintiff, a long-time horse breeder and owner, challenged the introduction of a ‘family unit’ cap imposed by the Delhi Race Club (DRC) in its Prospectus for the Delhi Meeting 2025—2026. Under General Condition 12, a family unit comprising an owner, spouse, and children, could keep a maximum of 40 horses at the Club’s stables and enter no more than three horses in any race, with any excess entries subject to balloting. The plaintiff and his family collectively own about 70 horses, with 45 currently stabled at DRC.
The plaintiff contended that the family unit classification was arbitrary, discriminatory, and inconsistent with the Rules of Racing framed by the Royal Western India Turf Club (RWITC), the sport’s apex regulatory body for Northern and Western India. He had argued that DRC lacked authority to introduce such a restriction without RWITC’s approval and that his horses had already been balloted out on two occasions, causing monetary and reputational loss.
Per contra DRC had averred that the restrictions were necessary to prevent monopolisation and ensure the fairness and integrity of races, particularly given the scale of betting associated with each race. It cited recent instances where a majority of entries in a race were from the plaintiff’s family, which, according to the Club, heightened the risk of perceived or potential rigging. DRC and RWITC also pointed out that the plaintiff had not availed the appellate mechanism under the RWITC Rules which was an internal, expert-driven remedy intended precisely for such disputes.
Analysis, Law and Decision
The Court examined General Condition No. 12 and the accompanying circular, noting that they were introduced against the backdrop of concerns regarding race integrity and the potential influence of concentrated ownership on race outcomes. At the interim stage, the Court found no prima facie infirmity in the defendants’ stated justification. As regulatory bodies, both DRC and RWITC bear responsibility for ensuring fair conduct of races, and the impugned restrictions appeared rationally connected to that objective.
The Court further noted that the RWITC Rules provide for appeals from decisions of the Stewards of the Meeting (DRC) to the Stewards of the Club (RWITC), followed by a further appeal to the Board of Appeal, with provisions for interim relief and expedited disposal. The plaint itself acknowledged RWITC’s status as the governing authority and accepted that races are conducted in accordance with RWITC’s Rules. Given this, the Court held that the plaintiff’s objections, including the alleged absence of formal approval under Rules 7 and 11, could be effectively addressed within the specialised appellate structure.
The Court also accepted the defendants’ explanation that, under a 30-year practice, Prospectuses are sent to RWITC ahead of publication and deemed approved absent objection. In this case, the 2025—2026 Prospectus had been sent on 16-9-2025, published shortly thereafter, and used for several race meetings without objection from RWITC. The Court observed that this constituted a deemed approval and noted that the plaintiff’s horses had participated in races conducted under the same Prospectus.
Thus, the Court opined that the plaintiff had not demonstrated a prima facie case or that the balance of convenience favoured him, and refused to grant an interim injunction. Accordingly, the application was dismissed.
[Ravinder Pal Singh Chauhan v. Delhi Race Club Ltd., CS(OS) No. 804 of 2025, decided on 26-11-2025]
Advocates who appeared in this case:
For the Plaintiff: Sanjay Jain, Senior Advocate, Mridul Bakshi, Latika Malhotra, Amrender Chauhan, Vidur Mohan, Nishant Tripathi, Anant Gautam, Priya, Prachi Batra, Akaash Chatterjee, Advocates
For the Defendants: Suhail Dutt, Senior Advocate, Sankalp Goswami, Azhar Alam, Milan Popli, Pallavi Pratap, Sameer Tapia, Siddhi Doshi, Rohan Marathe, Advocates