The case involves an appeal by the World Anti-Doping Agency (WADA) against wrestler Bhupender Singh and the National Anti-Doping Agency of India (NADA) regarding a doping violation. During the 32nd Junior Free-Style and Greco-Roman Male National Wrestling Championship in May 2013, Singh was randomly selected for a doping test but refused to sign the form and fled the venue. He later provided a sample the next day, which showed no adverse findings. NADA issued an anti-doping rule violation notice, and the Anti-Doping Disciplinary Panel imposed a one-year ineligibility period starting from October 2013, accepting Singh’s explanation that he evaded the test due to fear of failing after consuming Red Bull. WADA appealed to the Anti-Doping Appeal Panel, which upheld the one-year sanction, prompting WADA to further appeal to the Court of Arbitration for Sport (CAS), arguing for a stricter penalty under the applicable rules.
The case centered on whether WADA had the right to appeal and the appropriate sanction for evading a doping test. Under India’s Anti-Doping Rules (ADR), aligned with the World Anti-Doping Code (WADC), the standard penalty for evasion is a two-year ineligibility period, subject to mitigation if the athlete proves no significant fault or negligence. The Sole Arbitrator, Judge James Reid QC, ruled that Singh’s evasion based on unverified advice and without consulting medical professionals demonstrated significant fault, rejecting arguments related to his youth, inexperience, or rural background. The Arbitrator also addressed procedural delays, ruling the ineligibility period should commence from the date of the violation (May 2013) rather than the disciplinary decision (October 2013).
The CAS upheld WADA’s right to appeal under the ADR, which permits a second appeal to CAS if dissatisfied with the appellate body’s decision. Neither Singh nor NADA responded to WADA’s appeal, and the Arbitrator proceeded without a hearing, relying on written submissions. The CAS overturned the one-year sanction, imposing a two-year ineligibility period starting from the date of the violation. The decision reinforced the strict liability principle in anti-doping regulations, clarifying that athletes bear responsibility for their actions, even if based on misguided advice. The ruling affirmed WADA’s authority to challenge lenient sanctions to ensure consistent enforcement of anti-doping rules.
The case highlights the strict enforcement of anti-doping regulations and the limited circumstances under which penalties can be reduced. The CAS emphasized that athletes must understand and manage their anti-doping obligations, regardless of age or background. Singh’s claim of acting on wrong advice about Red Bull was deemed insufficient to justify mitigation, as he failed to consult his coach or a doctor. The Panel concluded his actions did not meet the "no significant fault or negligence" standard under Article 10.5.2 of the ADR.
Ultimately, the CAS annulled all competitive results obtained by Singh from May 2013 until the start of his ineligibility period, including forfeiture of titles, awards, medals, and prize money. The ruling underscores the principle of strict liability in anti-doping cases and the importance of upholding consistent penalties to maintain the integrity of sports. The decision serves as a reminder of the consequences of evading doping tests and the limited scope for reducing sanctions based on personal circumstances.