Discuss the extent to which Indian courts can exercise judicial review over the selection and eligibility policies of autonomous sports federations. Illustrate with a recent example.

National Sports Federations such as the Wrestling Federation of India (WFI) are private, self-governing societies, yet they alone decide who represents India. This public character invites judicial review — but a review that is supervisory in nature, not substitutive.

Constitutional basis of review

• In Zee Telefilms Ltd. v. Union of India (2005), the Supreme Court held that the BCCI is not "State" under Article 12, so an Article 32 writ fails; however, since it discharges public functions like national team selection, relief lies under Article 226 [1].
• Government recognition, public funding and a monopoly over national representation give federation rulebooks a public flavour, making arbitrary criteria justiciable.

Extent of review — what courts examine

• Courts test selection norms for arbitrariness, exclusionary effect, non-application of mind and breach of natural justice, not sporting merit.
• Illustration: the Delhi High Court (22 May 2026) allowed Vinesh Phogat into the Asian Games 2026 trials, holding WFI's policy exclusionary for lacking any discretion to accommodate an iconic athlete returning from a maternity break; the Supreme Court permitted her participation and later disposed of WFI's plea as infructuous without endorsing the High Court's findings [2].

Limits and judicial self-restraint

• Judges do not sit as selectors; form, fitness and technical assessment remain the federation's domain.
• Interim orders on the eve of trials risk disrupting team composition — hence the apex court's reluctance to lay down general law in the WFI matter [2].

The emerging statutory channel

• The National Sports Governance Act, 2025, whose key provisions commenced on 1 January 2026 [3], creates a National Sports Tribunal with civil-court powers, appeals lying to the Supreme Court, plus mandatory safe-sport and grievance-redressal mechanisms [4] — narrowing routine writ recourse.

Judicial review thus polices the fairness of criteria, not the choice of athletes. As the Tribunal becomes operational, federations should embed gender-sensitive, discretion-enabled selection norms, so that autonomy in sport and the athlete's right to non-arbitrary treatment under Article 14 advance together.