Delhi High Court on Booking of JLN Stadium for Ramlila: Sports Authority of India Must Act Fairly and Without Arbitrary Concessions.

The Delhi High Court dismissed a batch of Letters Patent Appeals arising out of a dispute between two Ramlila committees over booking of an open space at Jawaharlal Nehru Stadium, New Delhi. The Court held that the Sports Authority of India (SAI), being a public authority, is bound by the principles of fairness, transparency and non-arbitrariness. Grant of concessional rates to one party without any specific enabling power and without affording an opportunity to the other eligible applicant was held to be unfair. The Court affirmed the Single Judge’s direction requiring recovery of the full applicable rental charges from the beneficiary of the concession and refused to interfere with the impugned judgment.

• The dispute concerned booking of an open space near Gate No. 2, Jawaharlal Nehru Stadium, New Delhi, for staging Ramlila performances for 22 days (05.10.2023 to 27.10.2023).

• The venue is managed by the Sports Authority of India (SAI) and is frequently used for cultural events.

• Dakshinii Delhi Dharmik Ramlila Samiti (DDDRS) claimed it had been organising Ramlila at the venue for several years and applied for booking in January 2023.

• DDDRS was informed that booking could be made only through the online portal, available 120 days prior to the event.

• When DDDRS attempted online booking, it found that Shree Ram Dharmik Ramlila Samiti (SRDRS) had already booked the venue for an extended period at a nominal amount, far below the prescribed tariff.

• DDDRS challenged the booking and concession granted to SRDRS by filing W.P.(C) No. 10690/2023.

• The Single Judge directed SAI to recover the full rental charges (₹2,25,000 per day plus GST) from SRDRS and restrained grant of any discount.

• All three parties—DDDRS, SRDRS and SAI—filed Letters Patent Appeals against the said judgment.

• SAI, as a public authority, must ensure that its actions are fair, reasonable, transparent and non-arbitrary.

• There is no specific provision under Clause 34(a) of the Memorandum of Association of SAI empowering grant of concessions or discounts for non-sporting events.

• Allowing SRDRS to modify its initial long-duration booking and simultaneously granting concession effectively blocked DDDRS from accessing the venue through the prescribed online process.

• Once SRDRS sought modification of its booking, DDDRS ought to have been given a fair opportunity to apply afresh for the venue at applicable rates.

• Grant of concession without inviting competing offers or giving equal opportunity to similarly placed applicants violated principles of equality and fair play.

• The Court reiterated that State actions must rest on rational and discernible reasons and cannot be guided by individual discretion or favoritism.

• Since SRDRS had already deposited the full amount pursuant to the Single Judge’s directions, no question of refund arose.

• The High Court found no merit in any of the Letters Patent Appeals.

• The impugned judgment dated 04.10.2023 was upheld in full.

• All appeals were dismissed and the direction to recover full applicable charges from SRDRS was affirmed.

• All pending applications were closed.

• Doctrine of fairness and non-arbitrariness in State action.

• Equal opportunity in allocation of public resources.

• Limits on discretionary powers of public authorities.

• Requirement of transparency in grant of concessions by State instrumentalities.

Case: Dakshinii Delhi Dharmik Ramlila Samiti (Regd.) v. Sports Authority of India (SAI) & Ors.

(Connected matters: Sports Authority of India & Ors. v. Shree Ram Dharmik Ramlila Samiti (Regd.) & Anr.; Shree Ram Dharmik Ramlila Samiti (Regd.) v. Sports Authority of India & Ors.)

Court: High Court of Delhi at New Delhi

Coram: Justice Anil Kshetarpal & Justice Harish Vaidyanathan Shankar

Date of Decision: 18 December 2025

Letters Patent Appeals: LPA 683/2023, LPA 790/2023, LPA 206/2024