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SPORTS LAW AND TRANSGENDER RIGHTS IN INDIA: A COMPREHENSIVE LEGAL EXAMINATION BY: MERLIN JOHN

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MERLIN JOHN
Journal IJLRA
ISSN 2582-6433
Published 2025/03/24
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SPORTS LAW AND TRANSGENDER RIGHTS IN INDIA: A COMPREHENSIVE LEGAL EXAMINATION
 
AUTHORED BY: MERLIN JOHN
Christ University
 
 
Abstract:
While the legal framework in India has significantly progressed in recognizing and protecting the rights of transgender people, especially in areas like education, healthcare, and job opportunities, the field of athletics remains largely unexplored. This research provides a detailed examination of the legal frameworks influencing transgender athletes in India, analyzing relevant laws, court decisions, and policy initiatives. It highlights the gaps in existing legal protections and investigates the obstacles transgender individuals encounter in sports competitions, such as validation of gender identity, eligibility requirements, and ingrained biases. Additionally, this study looks into global legal standards and successful strategies that could serve as models for promoting inclusivity in Indian athletics. It also assesses the role of regulatory organizations, the effects of societal attitudes on transgender representation in sports, and the need for policy reforms to ensure fair chances. Through an extensive evaluation of legal and policy issues, this research aims to enhance ongoing discussions focused on creating a more inclusive and fair sporting environment for transgender individuals in India.
 
Introduction:
Sports law represents an evolving area where human rights, equity in gender representation, and regulatory structures come together, seeking to promote fairness, inclusivity, and sound governance in athletic activities. While India has made considerable progress in acknowledging transgender rights through significant legal milestones, such as the NALSA v. Union of India (2014) decision and the implementation of the Transgender Persons (Protection of Rights) Act, 2019[1], these laws do not specifically address transgender participation in sports. This lack of definitive legal guidance creates uncertainty, leaving transgender competitors confused about their rights to compete, access training, and participate fairly in sports.
The uncertainty in legal frameworks raises serious issues regarding the acknowledgment of gender identity, eligibility criteria, and systemic challenges, thus limiting the opportunities available to transgender persons in both professional and competitive sports. In addition, the absence of thorough policies from Indian sports governing bodies intensifies these problems, preventing transgender athletes from competing on equitable terms.
 
This research paper provides a critical examination of the challenges faced by transgender athletes within India's sports framework and highlights the pressing need for legislative and policy reforms. By comparing effective practices and legal measures from various countries, this study assesses how India can improve inclusivity in this field. The paper calls for the development of inclusive policies to guarantee fairness and equal chances for all athletes, regardless of their gender identity. Through this exploration, the research aspires to enrich the current conversation on gender diversity in sports and suggest concrete recommendations for fostering a more inclusive and equitable sporting landscape for transgender individuals in India.
 
Historical Development of Transgender Rights in India
Cultural Context
For centuries, transgender individuals have been a fundamental aspect of Indian culture, with historical accounts showcasing their involvement across diverse cultural, religious, and social areas. The hijra community, in particular, has been recognized for its prominent role in Indian history, often functioning as advisors to royalty, entertainers, and even spiritual figures. Ancient literature, including the Ramayana, Mahabharata, and a range of Puranic texts, references gender-fluid and third-gender identities, indicating a historical period where transgender individuals were embraced and honored in various circumstances.
 
Nonetheless, colonial laws from the past, especially the Criminal Tribes Act enacted in 1871, severely changed the perception of society by criminalizing and alienating the hijra community, deepening systemic exclusion that continued after independence. Despite their persistent presence within culture, transgender individuals, such as hijras, kinnars, and numerous other gender-diverse factions, have encountered ingrained discrimination in numerous fields, including job opportunities, education, healthcare, and sports. While certain communities continue to acknowledge their historical importance, contemporary prejudices and legal neglect have resulted in their marginalization, highlighting the need for targeted legal and policy measures to promote inclusivity and safeguard their rights, especially in areas like sports where they are often underrepresented.
 
Legal Milestones
The journey toward recognizing transgender rights in India has been influenced by a blend of challenges to the constitution, proactive judicial measures, and changing social attitudes. Although considerable progress has been achieved in affirming basic rights for transgender persons, the discussions surrounding their role in sports remain significantly lacking.
 
NALSA v. Union of India (2014):
The Supreme Court’s decision in National Legal Services Authority (NALSA) v. Union of India marked a pivotal turning point for the rights of transgender individuals[2]. This ruling officially acknowledged transgender people as a separate gender category in accordance with Articles 14 (Equality Rights), 15 (Anti-Discrimination), and 16 (Equality of Opportunity) of the Indian Constitution. It validated their right to self-identification and required proactive measures to support the community in terms of education and employment. Nevertheless, despite this progressive ruling, the court did not address the involvement of transgender individuals in sports. The absence of definitive policy guidance placed the onus of including transgender athletes on separate sports organizations, leading to varied and exclusionary practices in competitive sports.
 
Navtej Singh Johar v. Union of India (2018):
In another significant ruling, the Supreme Court removed the criminalization of homosexuality by abolishing Section 377 of the Indian Penal Code, thereby reinforcing constitutional safeguards for LGBTQ+ persons. This decision was crucial in upholding the dignity and rights of individuals from gender and sexual minority groups. However, although this verdict emphasized anti-discrimination norms, it did not lead to tangible policies regarding the engagement of transgender athletes in sports. The ruling concentrated mainly on individual liberties and the repeal of criminalization while neglecting the structural obstacles that transgender individuals encounter in professional and competitive sports.
 
Transgender Persons (Protection of Rights) Act, 2019:
This law was established to protect transgender individuals from discrimination and to guarantee their rights to education, healthcare, job opportunities, and access to public areas. While the legislation sought to create a thorough legal framework for safeguarding transgender rights, it notably failed to include provisions concerning participation in sports. The lack of clear directives for transgender athletes has led to uncertainty about their inclusion in both national and international events. Without well-defined policies from governing sports bodies, transgender athletes continue to encounter barriers, from ambiguous eligibility standards to complete exclusion from competitive sports.
 
Even with these legal improvements, a significant gap exists in providing equitable opportunities for transgender individuals in athletics. The lack of formulated guidelines has resulted in disparate policies among various sports organizations, perpetuating institutional barriers that hinder transgender athletes from competing on an equal basis. This absence of clear regulations highlights the pressing need for specific legislation and policy adjustments that directly address the participation and rights of transgender athletes within India’s sports landscape.
 
Legal Barriers Hindering Transgender Athletes in India
The participation of transgender athletes in sports faces obstacles due to significant legal deficiencies and prevailing social stigma. While there are progressive court rulings and legislative efforts aimed at safeguarding transgender individuals' rights, the lack of regulations specific to sports has led to ambiguity and exclusion. The absence of clear legal responsibilities for sports entities, combined with societal biases, generates a difficult landscape for transgender persons aiming to engage in competitive sports.
 
Policy Gaps
Absence of Sports-Specific Regulations
A major legal flaw is the lack of clear requirements mandating sports organizations to support transgender athletes. Although the Transgender Persons (Protection of Rights) Act, 2019 aims to combat discrimination across various areas, it does not require sports federations to create inclusive policies. This legislative void permits sports bodies to function without accountability, frequently resulting in arbitrary and exclusionary practices that harm transgender athletes.
 
Moreover, the Ministry of Youth Affairs and Sports has not yet established extensive regulations to ensure the involvement of transgender individuals in both professional and amateur sports. This lack of governmental guidance leaves transgender athletes with minimal legal options for addressing discrimination within sports federations, further entrenching their systemic exclusion from competitive opportunities.
 
National Sports Development Code (2011)
The National Sports Development Code[3] is intended to govern national sports federations in India. However, this policy framework fails to mention gender inclusivity or specifically address the participation of transgender athletes. Its omission regarding gender diversity highlights a wider systemic disregard for transgender representation in the governance of Indian sports.
 
Owing to the absence of standardized regulations, separate sports organizations create their own guidelines, which often lack consistency and fail to adequately cater to the needs of transgender athletes. Without clear national policies, these bodies may resort to arbitrary rules, allowing for discriminatory practices and subjective judgments. Many governing organizations do not possess the necessary expertise or dedication to implement inclusive policies, further sidelining transgender athletes and limiting their access to equitable competition.
 
Social Stigma
Beyond the shortcomings of laws and policies, individuals identifying as transgender encounter considerable societal bias, which further restricts their chances of pursuing athletic careers.
 
Exclusion from Training Academies
Numerous transgender athletes face denial from training academies and sports organizations owing to widespread biases. Negative perceptions from coaches, peers, and administrators frequently hinder transgender individuals from accessing essential coaching, facilities, and support. This exclusion poses significant obstacles to their skill enhancement and reduces their opportunities to compete at both national and global stages.
 
Lack of Standardized Eligibility Criteria
The lack of a cohesive eligibility system presents challenges for transgender athletes wishing to participate in sports. In the absence of explicit guidelines, these athletes often endure random and subjective assessments, complicating their efforts to assert their right to compete in gender-specific events. This vagueness not only fosters confusion but may also lead to biased decision-making by sporting authorities.
 
Cultural Biases and Grassroots-Level Exclusion
Social biases often dissuade transgender individuals from participating in sports from an early age. A shortage of understanding and acceptance in schools, local sports organizations, and community initiatives contributes to the minimal presence of transgender athletes at the grassroots level. Lacking early engagement and support, many transgender individuals do not view sports as a feasible career path, which continues to fuel their underrepresentation in the sports profession.
 
The interplay of legal gaps, policy deficiencies, and entrenched societal stigma establishes a challenging landscape for transgender athletes in India. In the absence of defined legal stipulations, organized eligibility systems, and active inclusion measures, transgender individuals persistently encounter systemic obstacles to their sports participation. To tackle these issues, it is essential to implement focused legislative changes, clear policy guidelines, and enhance societal understanding to ensure transgender athletes receive equal chances in competitive sports.
 
Globally, various nations and international bodies have embraced diverse strategies to promote transgender inclusion in sports. These policies vary from self-identification approaches to strict medical prerequisites, illustrating the ongoing international discourse on merging inclusivity with competitive integrity. Examining these frameworks offers valuable lessons for India as it works to develop its own policies for transgender athletes.
 
Canada: A Self-Identification Model
Canada has embraced one of the most advanced and inclusive models for transgender involvement in athletics. The Canadian Centre for Ethics in Sport (CCES) permits transgender competitors to participate based on their gender identity, without mandating medical steps like hormone treatment or surgical alterations[4]. This policy emphasizes self-identification, safeguarding transgender athletes from intrusive medical examinations or obstacles to their involvement. By eliminating medical requirements, Canada nurtures a more open and respectful sports atmosphere that honors principles of dignity and personal freedom. This framework illustrates a firm dedication to human rights and can provide a meaningful example for India in the development of a fair and inclusive sports policy.
 
United Kingdom: A Decentralized and Sport-Specific Approach
The United Kingdom employs a flexible strategy via the Sports Council Equality Group, which empowers individual sports organizations to create their distinct policies on transgender participation[5]. Instead of imposing a uniform, national guideline, this method acknowledges that various sports possess different physiological necessities and competitive frameworks. By allowing governing bodies in sports to formulate customized policies, the UK finds a balance between inclusivity and fairness in competition, permitting thoughtful decision-making. This strategy understands that while some sports may fully embrace inclusion based on gender identity, others might necessitate supplementary criteria to maintain competitive integrity. India's potential shift to a similar decentralized approach might provide adaptability while catering to the specific needs of diverse athletic disciplines.
 
United States: A Divided Landscape
The legal environment for transgender athletes in the United States is notably inconsistent, with regulations differing across various governmental levels. At the collegiate tier, the National Collegiate Athletic Association (NCAA) allows transgender women to take part in women's sports contingent upon completing a year of testosterone suppression therapy. Conversely, at the school and state levels, the policies are erratic, with some jurisdictions implementing laws that completely prohibit transgender students from joining sports teams in alignment with their gender identity. This disparity underscores the highly polarized state of transgender sports regulations in the U.S., mirroring wider political and social discussions surrounding gender identity. India has the opportunity to draw insights from both the NCAA's efforts at establishing a consistent framework and the challenges associated with erratic regional regulations on transgender sports policies.
International Olympic Committee (IOC): A Global Benchmark
The International Olympic Committee (IOC)[6] has notably been pivotal in establishing worldwide guidelines for the involvement of transgender athletes. Its framework from 2021 highlights three essential values: inclusion, non-discrimination, and equitable competition. Unlike earlier rules that required stringent testosterone level controls, the revised framework allows individual sports organizations the freedom to define eligibility standards pertinent to their distinct competitive environments. This change accepts the variety among sports while reaffirming a dedication to gender inclusiveness. The IOC’s approach offers a well-rounded model that India might explore when creating its own national policy for transgender sports, ensuring that inclusion is advanced without sacrificing fairness in competition.
 
India’s Lagging Position and the Need for Reform
In contrast to these global frameworks, India currently does not possess a national policy that addresses the participation of transgender individuals in sports. The lack of definitive guidelines places transgender athletes at risk of exclusion, inconsistent eligibility standards, and capricious choices by sporting organizations. Formulating a structured framework rooted in rights would align India with international trends and improve the representation of transgender athletes in both national and global events. By looking to international best practices, India can develop a thorough policy that supports equality, non-discrimination, and the integrity of competition.
 
A clearly articulated policy for transgender sports would not only align India with global human rights benchmarks but also strengthen its commitment to cultivating an inclusive and varied sporting environment. Establishing explicit guidelines would grant transgender athletes the legal safeguards and institutional endorsement they require to compete fairly, promoting a more equitable future for Indian sports.
 
Case Studies of Transgender Athletes
Examining individual instances of transgender and gender-diverse athletes sheds light on the legal, social, and regulatory hurdles they encounter. These case studies reveal the intricacies of gender identity within competitive sports and emphasize the need for inclusive, research-driven rules.
 
Dutee Chand v. Athletics Federation of India (2015): A Pivotal Case in Gender and Sports
While Dutee Chand does not identify as a transgender athlete, her legal fight against the International Association of Athletics Federations’ (IAAF) hyperandrogenism policy profoundly influenced the conversation about gender eligibility in sports. The IAAF (currently known as World Athletics)[7] had enforced restrictions on female athletes exhibiting naturally elevated androgen levels, raising doubts about their eligibility to compete in women’s divisions[8].
 
Chand's appeal to the Court of Arbitration for Sport (CAS) led to a groundbreaking decision, halting the hyperandrogenism policy due to a lack of adequate scientific backing for the imposed restrictions. This ruling highlighted the necessity for fairer, evidence-supported eligibility criteria in sports, steering clear of arbitrary bias based on gender identity or biological factors. Though the outcome primarily affected intersex athletes, it established a significant precedent for upcoming scenarios concerning transgender involvement in competitive athletics.
 
Laurel Hubbard (New Zealand): A Transgender Athlete in the Olympics
Laurel Hubbard made headlines as the first openly transgender woman to participate in weightlifting at the Tokyo 2020 Olympics. Her involvement sparked a significant discussion regarding the equilibrium between inclusivity and equity in elite sports. Proponents emphasized Hubbard’s entitlement to compete based on her gender identity, following the guidelines established by the International Olympic Committee (IOC). However, detractors raised concerns about whether transgender women who experienced male puberty might hold competitive advantages over cisgender women.
 
Hubbard's situation underscored the conflicts between policies on gender identity and fairness in competition, illustrating the difficulty in crafting regulations that respect both ideals. The discourse surrounding her involvement highlighted the need for sport-specific eligibility standards that account for differences in physical performance while supporting inclusion. This scenario acts as a guiding example for India in shaping policies that align the rights of transgender athletes with the ideals of equitable competition.
 
Hijra Athletes in India: Systemic Exclusion and Marginalization
Despite their rich historical and cultural heritage in India, hijras and other transgender individuals confront systemic obstacles to participating in sports. The lack of inclusive policies, combined with societal stigma, has led to significant exclusion from both competitive and recreational athletics. Numerous hijra athletes find themselves barred from accessing training resources, competitions, and professional coaching, severely limiting their prospects in sports.
Instances of hijra individuals engaging in athletics are infrequent, largely due to entrenched discrimination and a dearth of structured avenues for their involvement. In the absence of legal safeguards or proactive policies, their representation in Indian sports remains minimal. Tackling these issues demands focused efforts, including affirmative measures and community-level inclusion initiatives.
 
Suggestions for Transgender Inclusion in Indian Sports
In order to close the existing legal and policy gaps, India needs to adopt a thorough framework that promotes inclusivity while ensuring competitive integrity. The following actions are recommended:
1.      Creation of a National Transgender Sports Policy
The Ministry of Youth Affairs and Sports should craft a well-defined policy that establishes clear rules for transgender athlete involvement in both competitive and grassroots levels. This framework should be developed in partnership with transgender athletes, legal authorities, sports experts, and regulatory organizations to guarantee fairness and inclusiveness.
2.      Revisions to the National Sports Development Code (2011)
The current National Sports Development Code does not include provisions for transgender athletes. Changes should introduce specific protections that clarify their rights, eligibility standards, and pathways for addressing discrimination. These revisions must be in line with global best practices to ensure equal treatment.
3.      Creation of a National Grievance Resolution System
Transgender athletes often face discrimination during selection processes, competitions, and in training facilities. A targeted grievance resolution mechanism should be established to address issues of bias, exclusion, and unjust treatment. This autonomous entity should be responsible for ensuring accountability and providing legal options for affected athletes.
4.      Acknowledgment of Self-Identification with Competitive Protections
While it is essential to recognize self-identification legally, sports regulations must also incorporate suitable safeguards to assure fair competition. For instance:
?       Hormonal guidelines (similar to those used in some international frameworks) could apply to specific high-performance categories.
?       Eligibility evaluations that are specific to each sport should be performed, acknowledging the varying levels of regulation needed for different activities.
?       Alternative competitive formats (like open categories) should be considered where binary gender classifications create obstacles.
5.      Establishment of a National Database for Transgender Athletes
The absence of concrete statistics regarding the involvement of transgender athletes complicates the creation of effective policies. By launching an anonymous national database, we can monitor participation levels, document obstacles, and evaluate the success of inclusion strategies. This evidence-based approach to policy will enhance advocacy efforts and enable focused interventions.
6.      Execution of Gender Awareness Initiatives in Sports Organizations
To address discrimination within the sporting community, educational initiatives need to be implemented for:
?       Coaches and officials: Preparing them to support transgender athletes in a fair manner.
?       Athletes and teammates: Raising awareness of gender diversity and promoting inclusivity.
?       Sports administrators: Guaranteeing equitable selection practices and treatment without bias.
7.      Development of Gender-Inclusive Sports Divisions
An effective answer to the debates on transgender involvement may be the establishment of:
?       Open classifications that permit contestants of any gender identity to compete together.
?       Mixed-gender events in sports where physical differences are less pronounced.
?       Such frameworks, which are already being investigated in certain global sporting competitions, can offer alternatives to rigid gender classifications.
8.      Financial Assistance and Scholarships for Transgender Competitors
Financial barriers frequently hinder transgender individuals from accessing training and competitive experiences. Initiatives from both the government and private sectors should aim to provide scholarships, sponsorship opportunities, and training initiatives that assist transgender athletes in their pursuit of careers in professional sports.
9.      Inclusion Initiatives at the Grassroots Level in Educational Institutions
Early action is vital for cultivating an inclusive sports culture. Schools, colleges, and universities should be motivated to:
?       Implement policies that permit transgender students to join sports teams that correspond with their gender identity.
?       Offer gender-neutral accommodations, such as restrooms and locker facilities, to serve diverse athletes.
?       Ensure that competitions among schools and colleges incorporate explicit non-discrimination policies for transgender athletes.
Transgender athletes in India face marginalization due to legal gaps, unclear policies, and ingrained social prejudices. By adopting best practices from around the world, India must create a comprehensive, rights-based framework that safeguards transgender athletes against discrimination while ensuring equitable competition. Through the establishment of clear laws, promoting awareness, and encouraging grassroots involvement, India can progress towards a sporting landscape that values fairness, equality, and respect for all athletes.
 
By resolving these challenges through precise policies and strategic reforms, India has the potential to become a pioneer in inclusive sports governance, serving as a model for other countries to promote diversity and equality in athletics.
 
Conclusion
The convergence of sports law and transgender rights in India represents a vibrant and continually developing field that demands immediate legal and policy action. While there have been significant judicial decisions, including NALSA v. Union of India (2014) and the Transgender Persons (Protection of Rights) Act, 2019, the practical involvement of transgender athletes in competitive sports is still uncertain due to the lack of specific policies and guidelines.
The ambiguity found in national sports regulations presents obstacles for transgender athletes, resulting in inconsistencies regarding their participation in various sporting competitions. In contrast to international standards that define structured eligibility criteria, India has not yet created clear regulations to ensure both inclusivity and fairness in competition. Examples from countries such as Canada, the UK, and New Zealand illustrate that integrating gender identity acknowledgment with competitive fairness requires a sophisticated, evidence-driven method.
To address this issue, India must develop a comprehensive legal and policy framework that aligns with international best practices while honoring its constitutional principles of equality and non-discrimination. This framework should include defined eligibility standards, safeguards against discrimination, and proactive measures to establish a fair environment for transgender athletes. Additionally, effective implementation of these policies must be tracked to guarantee their success and accessibility.
 
Continued research and advocacy are vital for tackling the difficulties that transgender athletes encounter. A collaborative approach—uniting legal professionals, sports organizations, policymakers, and transgender individuals—is critical for fostering an inclusive sports setting. Collective initiatives should prioritize the creation of sport-specific guidelines, execution of awareness programs, and ensuring that transgender athletes have the support they need to engage and thrive in their chosen sports.
 
By promoting an inclusive and equitable sporting landscape, India has the potential to set a benchmark for progressive sports governance while reinforcing its dedication to human rights and diversity within athletics.
 
References:
  1. NALSA v. Union of India (2014)
     Nat’l Legal Servs. Auth. v. Union of India, (2014) 5 S.C.C. 438 (India).
  2. Transgender Persons (Protection of Rights) Act, 2019
    The Transgender Persons (Protection of Rights) Act, No. 40 of 2019, Acts of Parliament, 2019 (India).
  3. Dutee Chand v. Athletics Federation of India (2015)
     Dutee Chand v. Athletics Fed’n of India, CAS 2014/A/3759 (Ct. Arb. Sport 2015).
  4. National Sports Development Code of India (2011)
    Ministry of Youth Affairs & Sports, National Sports Development Code of India, 2011 (2011),
    https://yas.gov.in.
  5. International Olympic Committee (IOC) Framework (2021)
    Int’l Olympic Comm., Framework on Fairness, Inclusion and Non-Discrimination Based on Gender Identity and Sex Variations (2021),
    https://olympics.com/ioc.
  6. World Athletics (Formerly IAAF) Regulations on Hyperandrogenism
    World Athletics, Eligibility Regulations for Female Classification (2021),
    https://worldathletics.org.
  7. Canadian Centre for Ethics in Sport (CCES) Policy
    Canadian Ctr. for Ethics in Sport, Creating Inclusive Environments for Trans Participants in Canadian Sport (2016),
    https://cces.ca.
  8.  Sports Council Equality Group (UK Policy)
    Sports Council Equal. Grp., Guidance for Transgender Inclusion in Domestic Sport (2021),
    https://equalityinsport.org.
  9. New Zealand Olympic Committee (NZOC) on Transgender Athletes N.Z. Olympic Comm., Transgender Inclusion Policy (2020), https://olympic.org.nz.
  10. Academic Discussion on Gender and Sports Regulations
    Richard Pringle & Hakan Larsson, Transgender Inclusion and Sport: A Critical Analysis, 45 J. Sport & Soc. Issues 67 (2021).
  11. UNESCO Guidelines on Gender Equality in Sports
     UNESCO, International Charter of Physical Education, Physical Activity and Sport (2015),
    https://unesdoc.unesco.org.
  12. Case Study on Laurel Hubbard’s Participation in the Olympics
     Jon Pike, Fair Competition, Inclusion, and Transgender Athletes in Sport, 20 Sport, Ethics & Phil. 12 (2021).
  13. Hijra Community and Sports in India
     Arvind Narrain, Queer Rights and the Indian Legal System, 34 Indian J. Gender Stud. 201 (2020).
  14. Marginalization of Transgender Athletes in India
    Vrinda Bhandari, Beyond the Binary: Challenges of Gender Identity in Indian Sports, 27 Nat’l L. Sch. India Rev. 132 (2022).
  15. Financial Barriers for Transgender Athletes
    Megan Rapinoe & Jennifer Finney Boylan, The Economic Cost of Exclusion in Sports, 46 Harv. J. Sports & Ent. L. 87 (2021).



[1]  The Transgender Persons (Protection of Rights) Act, No. 40 of 2019, Acts of Parliament, 2019 (India).
[2]  Nat’l Legal Servs. Auth. v. Union of India, (2014) 5 S.C.C. 438 (India).
[3]  Ministry of Youth Affairs & Sports, National Sports Development Code of India, 2011 (2011), https://yas.gov.in.
[4]  Canadian Ctr. for Ethics in Sport, Creating Inclusive Environments for Trans Participants in Canadian Sport (2016), https://cces.ca.
[5]  Sports Council Equal. Grp., Guidance for Transgender Inclusion in Domestic Sport (2021), https://equalityinsport.org.
[6]  Int’l Olympic Comm., Framework on Fairness, Inclusion and Non-Discrimination Based on Gender Identity and Sex Variations (2021), https://olympics.com/ioc.
[7] World Athletics, Eligibility Regulations for Female Classification (2021), https://worldathletics.org.
[8]  Dutee Chand v. Athletics Fed’n of India, CAS 2014/A/3759 (Ct. Arb. Sport 2015).

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International Journal for Legal Research and Analysis

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