Delhi High Court Upholds Recovery of Full Venue Charges; Holds SAI Acted Unfairly In Granting Concession For Ramlila Booking.

Headnote:

The Delhi High Court dismissed a batch of Letters Patent Appeals arising from a dispute over booking of a venue at Jawaharlal Nehru Stadium for Ramlila performances, holding that the Sports Authority of India (SAI) acted unfairly and without enabling power in granting concessionary rates to one organiser. The Court upheld the Single Judge’s direction requiring recovery of full applicable charges with GST from the beneficiary organisation, observing that alteration of an initial booking without reopening the process deprived the rival applicant of a fair opportunity and violated principles of non-arbitrariness in State action.

Background:

• The dispute concerned booking of an open space near Gate No. 2, Jawaharlal Nehru Stadium, New Delhi, for staging Ramlila and Dussehra Mela performances between 05.10.2023 and 27.10.2023.

• The venue is managed by the Sports Authority of India (SAI) and is available for cultural events at prescribed tariffs.

• Dakshinii Delhi Dharmik Ramlila Samiti (DDDRS) claimed it had been organising Ramlila at the venue annually and sought booking for 22 days at applicable rates.

• Shree Ram Dharmik Ramlila Samiti (SRDRS) secured a provisional booking for a longer period at a nominal charge and later sought concession and modification of booking duration.

• DDDRS alleged arbitrariness and collusion, contending that SRDRS was granted an unfair advantage and that it was denied an opportunity to book the venue at full tariff.

• The Single Judge disposed of W.P.(C) 10690/2023 by directing SAI to recover full charges of ₹2,25,000 per day plus 18% GST and security deposit from SRDRS, without cancelling the already-conducted event.

• Aggrieved, DDDRS, SRDRS and SAI filed connected LPAs challenging different aspects of the decision.

Court’s Observations:

• The venue booking policy permitted online booking only 120 days prior to the event; SRDRS had effectively blocked availability by securing and later modifying a long-duration booking.

• Clause 34(a) of the Memorandum of Association of SAI conferred general administrative and financial powers but did not specifically empower grant of discounts or concessions for non-sporting events.

• Once SRDRS sought alteration of its initial booking, fairness demanded that the process be reopened and DDDRS be afforded an opportunity to apply afresh.

• Grant of concession to SRDRS without giving DDDRS a chance to book at full tariff amounted to unfairness and arbitrariness.

• State instrumentalities are bound by principles of fairness, transparency, reasonableness and non-arbitrariness in allocation of public resources.

• Since the amount as directed had already been deposited by SRDRS and the event had concluded, no interference with the Single Judge’s directions was warranted.

Decision:

• All the Letters Patent Appeals were dismissed.

• The Impugned Judgment dated 04.10.2023 was upheld.

• Recovery of full applicable charges with GST and security deposit from SRDRS was affirmed.

• All pending applications were closed.

Legal Provisions / Principles Discussed:

• Clause 34(a), Memorandum of Association of SAI – Scope of administrative and financial powers.

• Article 14, Constitution of India – Non-arbitrariness and fairness in State action.

• Principles governing allocation of public resources, transparency, and equal opportunity.

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

(with connected matters: LPA 790/2023; LPA 206/2024)

Court: High Court of Delhi at New Delhi

Coram: Justice Anil Kshetrapal & Justice Harish Vaidyanathan Shankar

Date of Decision: 18 December 2025

(Reserved on: 11 December 2025)

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