Examine the scope of judicial review over administrative eligibility criteria framed by autonomous sports bodies in India.

National Sports Federations (NSFs) such as the Wrestling Federation of India are private societies, yet they hold monopoly control over an athlete's access to national and international competition. This dual character makes their eligibility circulars reviewable — but the review is supervisory, not appellate.

Basis of reviewability: the public function doctrine

• Zee Telefilms v. Union of India (2005) held the BCCI is not "State" under Article 12, foreclosing an Article 32 remedy [1].
• BCCI v. Cricket Association of Bihar (2015) held such bodies are nonetheless amenable to Article 226 writ jurisdiction because they discharge public functions [2].
• Ministry recognition and funding under the National Sports Development Code, 2011 deepens this public element [3].

Grounds on which criteria are examined

• Arbitrariness and unreasonableness — Article 14 standards apply to selection norms.
• Procedural fairness — criteria must be notified in advance and applied uniformly; the Delhi High Court sustained the WFI circular of 7 September 2026 on precisely this uniformity reasoning [4].
• Exclusion of legitimate categories — the same Court recorded that an athlete's maternity and post-partum circumstances must be weighed when the validity of the policy is tested on merits [4].

Limits of the scope

• Courts do not sit in appeal over selection merit or technical sporting judgment.
• Interim relief is sparingly granted: Vinesh Phogat was refused exemption from trial eligibility pending full adjudication [4].
• The usual remedy is remitting the matter to the federation, not judicially rewriting criteria.

Widening frontier

• The National Sports Governance Act, 2025 mandates ethics codes and grievance redressal within recognised federations, shifting many disputes to statutory scrutiny [5].

Judicial review thus operates as a calibrated check on autonomy rather than a substitute for it. The durable solution lies upstream: federations framing maternity return-to-play guidelines, as the Court itself suggested, and activating the 2025 Act's redressal machinery — advancing the substantive equality that Article 15(3) and SDG-5 envisage.