Delhi High Court Rejects Interim Injunction in Horse Racing Dispute

Court Dismisses Plea Against Restrictive Conditions on Horse Ownership; Cites Available Appellate Remedies

In a significant ruling, the Delhi High Court has dismissed an application filed by Ravinder Pal Singh Chauhan seeking an interim injunction against the Delhi Race Club (1940) Ltd. The judgment, delivered by Justice Amit Bansal, pertains to the introduction of restrictive conditions in horse racing, which the plaintiff argued were arbitrary and discriminatory.

The case arose when the Delhi Race Club, under the aegis of the Royal Western India Turf Club (RWITC), implemented a rule limiting the number of horses a 'family unit' can own and race. The plaintiff, Chauhan, who along with his family owns several racehorses, challenged this restriction, arguing that it violated principles of equality and was imposed without proper authority.

The court, however, found no merit in the plaintiff's claim for interim relief. Justice Bansal noted that the restrictions were aimed at preventing monopolization and potential rigging in horse races-a concern given the high stakes involved in betting on these events. The court recognized that the governing body's actions were not arbitrary and had a rational nexus with ensuring fair play in races.

Further, the court emphasized the existence of an efficacious appellate mechanism within the Rules of the RWITC, which the plaintiff failed to utilize. The judgment underscored that the plaintiff’s grievances could be adequately addressed through this established appeal process. The court referenced past judgments, including those of Barfo Devi v. DDA and Pesi Shroff v. State of Maharashtra, to highlight the importance of exhausting available remedies before seeking judicial intervention.

The plaintiff's contention that the conditions were introduced without formal approval from the RWITC was also addressed. The court noted that the absence of objections from the governing body effectively amounted to deemed approval, in line with longstanding practices.

In conclusion, the application for an interim injunction was dismissed, with the court stating that no prima facie case had been made for granting such relief. The court's decision underscores the judiciary's reluctance to intervene in regulatory matters where a structured appellate process is available.

The matter will next be listed for completion of pleadings on January 15, 2026.

Bottom Line:

Horse Racing - Interim injunction against implementation of restrictive conditions in horse racing dismissed - Appellate mechanism under the Rules of the governing body deemed to be an efficacious remedy.

Statutory provision(s):  

• - Civil Procedure Code, 1908 - Order XXXIX, Rule 1 & 2  
• - Specific Relief Act, 1963 - Section 41(h)  
• - Horse Racing Rules - Rule 7, Rule 11, Rule 36(b), Rule 41(h), Rule 46(a), Rule 49(c)

Ravinder Pal Singh Chauhan v. Delhi Race Club (1940) Ltd., (Delhi) : Law Finder Doc Id # 2812681