Introduction
Doping is the use of prohibited substances to enhance the endurance, strength and performance of sportspersons. It has become a substantial barrier to the integrity of sport. The National Anti-Doping (Amendment) Bill, 2025 signifies a crucial enhancement of India’s anti-doping framework, aligning the nation more closely with the international standards set out in the World Anti-Doping Code (the Code).1 A significant advancement is the establishment of a new Schedule, which grants selected provisions of the Code direct legal authority in India. This mechanism, together with the Government’s power to update the Schedule by notification, ensures that Indian law can remain in step with global anti-doping standards, avoiding the delays associated with parliamentary amendment whenever the Code is revised. The Bill also introduces specific measures to strengthen the institutional independence of the National Anti-Doping Agency (NADA)2 and the National Anti-Doping Appeal Panel,3 addressing enduring concerns about neutrality, credibility and potential executive interference.
The National Anti-Doping (Amendment) Bill, 2025 remains a bill and has not yet become law, as it has not completed the parliamentary process required for enactment. A bill attains legal status only after being approved by both Houses of Parliament, the Lok Sabha and the Rajya Sabha, and thereafter obtaining the assent of the President of India, as provided in Article 111 of the Constitution. The Bill was passed by the Lok Sabha on 11 August 2025 and by the Rajya Sabha on 12 August 2025; the assent of the President remains pending for the Bill to become law.
The Bill further establishes a uniform appellate framework, expressly acknowledging the jurisdiction of the Court of Arbitration for Sport (CAS)4 and reinforcing the direct authority of the World Anti-Doping Agency (WADA)5 to engage with CAS, a measure intended to resolve earlier procedural uncertainties. The amendment ensures that India’s statutory terminology is consistent with the Code and requires adherence to WADA’s International Standard for Laboratories, thereby enhancing the quality and acceptability of test results. In amending the National Anti-Doping Act, 2022, the Bill improves clarity, compliance and procedural efficiency. Nonetheless, consistent with settled constitutional principles, it refrains from imposing retrospective liability for substantive offences; only procedural adjustments, such as appeal pathways and panel composition, may apply to cases that are pending or ongoing.
Need for the amendment
India’s anti-doping laws have evolved over time, but they continue to move towards meeting international standards. The National Anti-Doping Bill, 2021 was first introduced as a means for the Government to support anti-doping efforts and to ensure that India honoured its commitments under the UNESCO International Convention against Doping in Sport, 2005.6 The Bill eventually became the National Anti-Doping Act, 2022. This made NADA a statutory body and established the National Board for Anti-Doping in Sports, which is responsible for formulating rules, providing policy direction and monitoring implementation. The 2022 Act was a significant step forward in giving India’s anti-doping efforts legal legitimacy, but its implementation revealed several operational difficulties. Owing to divergent interpretations of the World Anti-Doping Code, a lack of clarity in appellate procedures, concerns about the independence of disciplinary panels and the absence of a mechanism to update Indian law in line with WADA’s evolving standards, both domestic panels and the Court of Arbitration for Sport (CAS) had to contend with delays and disagreements. Moreover, the international anti-doping framework has been undergoing rapid change, as WADA has updated its Code and International Standards, necessitating prompt legal alignment. In this context, the National Anti-Doping (Amendment) Bill, 2025 was introduced as a remedial measure. It aims to address the operational deficiencies identified since 2022 while ensuring that India’s anti-doping framework consistently adheres to international standards, thereby enhancing the credibility of Indian sport and reinforcing the implementation of anti-doping measures.
Salient features of the Bill
The National Anti-Doping (Amendment) Bill, 2025 presents a comprehensive set of reforms aimed at addressing the deficiencies identified during the operation of the 2022 Act. That legislation represented India’s first attempt to establish a thorough statutory framework for anti-doping; however, its provisions frequently fell short of the evolving demands of the World Anti-Doping Code, resulting in ambiguities in both interpretation and enforcement. The 2025 Bill resolves these problems by creating a direct legal link between Indian law and the Code, clarifying the reach of appellate mechanisms and reinforcing institutional independence. The Bill also addresses technical and definitional problems that had complicated disciplinary hearings, and it improves laboratory procedures so that they meet international standards. In short, the amendment is a considered revision of the existing law rather than a complete rewrite. It is intended to sustain compliance, make procedures more efficient and render India’s anti-doping system more trustworthy to athletes, regulators and international sports organisations.
A. Code provisions acquire legal authority through dynamic alignment
A newly introduced Section 2A stipulates that the provisions of the Code set out in a Schedule have the force of law in India. It also empowers the Central Government to revise that Schedule to reflect future amendments to the Code, ensuring ongoing compliance without the need to enact a new law each time.7 The Schedule to the Bill sets out Article 2 of the Code (anti-doping rule violations), which includes matters such as presence, use, tampering, whereabouts failures, prohibited association and retaliation.8
B. Conceptual clarity and systematic cohesion
The Bill refines essential definitions, such as the in-competition window, marker, metabolite and out-of-competition, and specifies that terms not defined in the Act but set out in the Code will retain those meanings, thereby minimising interpretive discrepancies between Indian proceedings and international standards.9
C. Administration and independence of NADA
The Statement of Objects and Reasons highlights the importance of strengthening the institutional and operational independence of NADA and the National Anti-Doping Appeal Panel, particularly regarding their autonomy in investigation and enforcement. The Central Government is also authorised to make rules concerning the constitution, appointment and removal of Appeal Panel members, formalising the framework while expressly prioritising independence.
D. Appeals to CAS: eligibility and timing
The Bill amends Section 23 to clarify who is eligible to appeal to the Court of Arbitration for Sport (CAS). The provision expressly permits WADA, the IOC, the IPC and the relevant International Federation10 to challenge decisions of the Appeal Panel before CAS. In the case of international-level athletes or international events, it specifies the parties entitled to appeal decisions of the Disciplinary Panel directly to CAS, including the athlete, NADA, the International Federation, WADA and, where applicable, the IOC or IPC.11 Importantly, it acknowledges WADA’s authority to approach CAS directly, without exhausting domestic remedies, where the Code so permits, formalising a matter that has been contentious in recent disputes.
E. Laboratories and international guidelines
The Bill provides that laboratory procedures and standard operating protocols must adhere to the International Standard for Laboratories (ISL),12 and it facilitates rule-making to guarantee comprehensive compliance throughout the process, including collection, chain of custody and analysis. This is of significant value for ensuring data integrity and the worldwide acceptance of Indian test results.
Key improvements of the Bill
The 2025 Amendment Bill marks a notable advance on the 2022 Act, enhancing both the substantive and procedural aspects of India’s anti-doping framework. First, it ensures that the Act remains aligned with the World Anti-Doping Code by incorporating Article 2 directly into a new Schedule to the Act and permitting the Government to amend that Schedule by notification.13 This mechanism keeps the law current with any changes to WADA’s definitions or testing techniques, enhancing legal certainty and closing potential gaps in compliance. Second, the Bill creates a clearer appeals process by amending Section 23, which now states expressly who may appeal to the Court of Arbitration for Sport (CAS) and, most importantly, gives WADA a direct opportunity to challenge rulings. This change addresses the jurisdictional disagreements that arose in 2024 and 2025 and is expected to reduce procedural conflicts in future cases. Third, the Bill strengthens procedures and enhances institutional autonomy by empowering the Appeal Panel to make rules for its own functioning, and by ensuring that laboratories closely follow WADA’s International Standard for Laboratories (ISL). This makes disciplinary rulings more robust and less susceptible to challenge on procedural grounds, both domestically and internationally. Finally, the amendment achieves definitional consistency by aligning essential concepts, such as in-competition, prohibited association and retaliation, with their international equivalents. This alignment reduces the likelihood of Indian decisions being reversed abroad because of divergent interpretations and enhances the overall credibility of India’s anti-doping efforts.
Recent cases and the effect of the Bill
A. WADA v. NADA India
In 2024, the World Anti-Doping Agency (WADA) submitted appeals to the Court of Arbitration for Sport (CAS) contesting certain decisions of the National Anti-Doping Agency (NADA) India, which had chosen not to proceed with adverse analytical findings concerning athletes.14 The contention concerned not merely the validity of the findings but, crucially, the extent of WADA’s appellate rights within the existing legal structure. CAS had to determine whether WADA was entitled to appeal directly to it, or whether it was first required to exhaust domestic remedies, including proceedings before the National Anti-Doping Appeal Panel.15 This uncertainty underscored a fundamental flaw in the 2022 Act, which failed to define clearly the hierarchy of appeals and thereby allowed for procedural challenges.
The 2025 Amendment Bill addresses this issue by amending Section 23 of the Act to state clearly that WADA may appeal decisions of the Appeal Panel, or, in specific instances, even rulings of the Disciplinary Panel, directly to CAS, bypassing Indian appellate processes, provided that this pathway is permitted under Article 13 of the World Anti-Doping Code. By clarifying the direct right of appeal, the Bill removes the ambiguity that led to disputes such as WADA v. NADA India. It is anticipated that jurisdictional questions will in future be resolved more promptly, allowing disputes to concentrate on essential anti-doping matters rather than procedural obstacles. This reform is of considerable importance because it brings India’s appellate system into line with global standards, enhances confidence in the enforceability of Indian decisions and minimises the likelihood of conflicting rulings across forums.
B. Parvej Khan: a six-year suspension
In 2025, a significant doping case emerged in India involving Parvej Khan, a promising middle-distance runner regarded as one of the nation’s leading talents in international athletics. A six-year sanction was imposed by the Anti-Doping Disciplinary Panel (ADDP) following a finding of two distinct anti-doping rule violations.16 The first violation involved an adverse analytical finding for erythropoietin (EPO), a powerful blood-enhancing substance, while the second concerned multiple failures to comply with whereabouts requirements for out-of-competition testing.17 Consistent with the World Anti-Doping Code, the ADDP treated these as separate violations and increased the penalties, imposing a four-year suspension for the EPO infraction and an additional two-year sanction for the whereabouts failures, culminating in a total ban of six years.18
This case illustrates the practical utility of the amendments made by the 2025 Bill. The updated legal definitions of in-competition and out-of-competition enhance clarity in classifying violations such as whereabouts failures, ensuring that penalties for repeated offences are enforced with more robust legal support. Furthermore, by directly integrating Article 2 of the World Anti-Doping Code into Indian legislation through the new Schedule, the Bill reinforces the legal structure for imposing penalties in cases of multiple, intersecting violations.19 This limits the ability of athletes to contest sanctions on the basis of technical definitions.
In addition, the clarified appeal structure of the Bill ensures that, if Parvej Khan, NADA, WADA or an International Federation such as World Athletics wishes to contest or uphold the sanction before the Court of Arbitration for Sport (CAS), the jurisdictional pathway is significantly more transparent.20 In contrast to earlier instances, where uncertainty about WADA’s ability to bypass Indian appellate processes led to delays, the updated provisions clearly acknowledge WADA’s entitlement to appeal directly to CAS where permitted. Khan’s case therefore exemplifies the gravity of doping infractions in Indian athletics and demonstrates how the 2025 Bill enhances the legal framework’s capacity to address complex, multi-faceted doping cases with improved clarity, efficiency and global credibility.
Advantages of the new Bill
The National Anti-Doping (Amendment) Bill, 2025 has many beneficial features and could improve India’s standing in international sport. First, it ensures that national law follows international standards by introducing a Schedule mechanism that incorporates the World Anti-Doping Code’s rules into domestic law and allows for revision through government notification. This flexible method ensures that WADA’s evolving criteria are met promptly, an important signal of trust to international federations and multi-sport event organisers who have previously been concerned about India’s compliance record. Second, the Bill makes appeals clearer by providing that WADA, the IOC, the IPC and the relevant International Federations may appeal directly to the Court of Arbitration for Sport (CAS).
This aligns India’s practice with Article 13 of the Code21 and mitigates the risk of forum disputes, which have historically caused unnecessary delays and compromised enforcement. Third, the Bill improves procedural integrity by requiring laboratory procedures to adhere to the International Standard for Laboratories (ISL), which bolsters the admissibility of test results and guarantees a secure chain of custody. This approach not only minimises potential technical difficulties but also strengthens global confidence in the reliability of testing conducted in India. The amendment also underscores the importance of institutional independence, striving to protect NADA and the Appeal Panel from any perception of executive influence. By emphasising independence in investigation and decision-making, the Bill advances towards enhanced impartiality, which is crucial for preserving athlete confidence and supporting India’s positions in international arenas. Collectively, these measures represent progress towards a more credible, transparent and globally respected anti-doping framework.
Issues and challenges of the Bill
While the National Anti-Doping (Amendment) Bill, 2025 has several commendable features, it is not without criticism and possible shortcomings. A significant concern is the potential for excessive delegation to the executive. The Bill grants the Central Government the authority to amend the Schedule, which in turn modifies the legal standing of certain provisions of the World Anti-Doping Code.22 This effectively concentrates significant regulatory power within the executive branch while allowing only limited parliamentary oversight. Although the requirement to lay such notifications before both Houses of Parliament remains intact, it may be argued that this diminishes democratic oversight of a legal domain that directly affects the careers and reputations of athletes. The outcome will largely depend on the frequency and transparency with which the executive exercises this authority, and on its restraint in maintaining the Schedule in accordance with WADA updates rather than introducing further domestic modifications.
A second concern relates to practical independence. While the Bill clearly aims to strengthen the independence of NADA and the Appeal Panel, it simultaneously permits the Central Government to make rules concerning the constitution, appointment and removal of panel members. Without guarantees of transparency, security of tenure and well-defined conflict-of-interest safeguards, there is a risk that panels may be perceived as vulnerable to government influence, which would erode athlete confidence in their objectivity.
A significant deficiency concerns the due process afforded to athletes. The Bill delineates the appellate pathways for WADA, the IOC, the IPC and the International Federations, yet it restricts the ability of athletes to appeal directly to CAS, particularly those who do not qualify as international-level athletes or who do not participate in international events. This may be seen as limiting athlete access to the premier forum for sports arbitration, potentially disadvantaging those whose careers depend on prompt resolution. Clarifying the scope of domestic appeals, together with the availability of legal aid or institutional support for athletes facing complex proceedings, is essential to promoting fairness.
Finally, the Bill’s emphasis on rigorous adherence to the International Standard for Laboratories (ISL) imposes a significant operational burden on the National Dope Testing Laboratory (NDTL). Compliance with the ISL requires ongoing investment in infrastructure, sustained staff training and thorough quality-assurance audits. Insufficient funding and resources significantly heighten the risk of backlogs, variability in testing quality, or even temporary suspension of accreditation. Therefore, although adherence to the ISL is essential for international credibility, its effectiveness will largely depend on the Government’s commitment to sustained financial and operational support.
Retrospective consequences for adjudication
The 2025 Amendment Bill does not reopen previous doping rulings in India, as there is no express provision granting it retrospective application. Under the constitutional principle in Article 20(1), no legislation can retroactively create new offences or impose more severe penalties for acts committed in the past. The implication is that the newly recognised violations or revised sanctioning standards established by the Bill cannot be applied retrospectively to athletes whose cases have already been adjudicated. Nonetheless, procedural modifications, including the clarification of appeal pathways to the Court of Arbitration for Sport (CAS) and the reorganisation of the disciplinary and appellate panels, may apply to the pending or future stages of ongoing cases, provided they do not unfairly prejudice the athlete. Indian courts are expected to follow the criteria established in Hitendra Vishnu Thakur v. State of Maharashtra, which distinguishes between substantive provisions, which apply only prospectively, and procedural provisions, which may apply retrospectively where they are fair and non-prejudicial. In practice, this means that, although previous doping sanctions and acquittals are final, the newly established appellate and procedural framework will govern ongoing and future disputes, facilitating closer alignment with international anti-doping protocols while preserving vested rights.
Conclusion
The National Anti-Doping (Amendment) Bill, 2025 represents a significant advance in India’s efforts to combat doping in sport. The Bill integrates the World Anti-Doping Code into Indian law and allows for its periodic updating by notification, ensuring that India’s legal system aligns with international standards. This dynamic alignment addresses the compliance issues that had previously affected India’s credibility with foreign sports organisations. In WADA v. NADA India (2024), the Court of Arbitration for Sport (CAS) confronted issues that could have been mitigated by clearer rules on appellate rights. The new framework significantly reduces the likelihood of such issues arising, as the Bill formally empowers WADA to engage directly with CAS.
A significant advantage of the Bill is its effort to enhance the clarity of appeals and establish more definite procedures. By expressly defining the eligibility criteria for access to CAS, the legislation reduces the likelihood of forum shopping or jurisdictional delay. This is especially important in high-stakes cases such as that of Parvej Khan, who received a six-year ban in 2025 for multiple rule violations, including the use of erythropoietin (EPO) and failures to report his whereabouts. Because appeals in such cases often engage both national and international bodies, a clear appellate process is crucial to ensuring that issues are resolved promptly and to preventing a recurrence of the misunderstandings experienced in earlier disputes.
The Bill also addresses persistent issues concerning laboratory methods and emphasises the need for precise definitions. By ensuring adherence to the International Standard for Laboratories (ISL) and the accurate use of key terms such as in-competition, out-of-competition and prohibited association, it reduces the likelihood of Indian panel rulings being overturned internationally on technical grounds. This matters given India’s history of disputed sanctions, exemplified by the difficulties faced by Sunita Rani at the 2002 Asian Games, where definitions and procedures became points of contention. The updated regulations provide athletes and governing bodies with a more robust legal framework, ensuring that results management is conducted in a globally credible manner.
The overall effectiveness of the Bill will depend more on its implementation in practice than on the language used within it. Nominations to the Disciplinary and Appeal Panels should be made transparently, free from governmental influence and accompanied by secure tenure, in order to ensure independence and impartiality. Similarly, adherence to the ISL in laboratories demands significant resources, and without sustained financial support India may encounter operational challenges of the kind that led to the suspension of the National Dope Testing Laboratory’s WADA accreditation in 2019. Moreover, while the Bill enhances the authority of regulators such as WADA, it is crucial to advance athlete education and legal assistance in parallel. Many athletes, particularly those from rural or economically disadvantaged backgrounds, are unaware of their obligations under anti-doping regulations and lack the resources to mount a robust defence. In the absence of support mechanisms, the system risks being perceived as punitive rather than rehabilitative.
The 2025 Amendment Bill addresses numerous issues that have weakened India’s anti-doping system in recent years, enhancing clarity, consistency and alignment with international standards. Its full potential, however, can be realised only with transparent governance, athlete-centred reforms and sufficient funding for testing infrastructure. If implemented with integrity, the Bill has the potential to position India as a significant contributor to the global fight against doping while serving as a trustworthy guardian of fairness for athletes and of the integrity of sport.
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Footnotes
1. The World Anti-Doping Code is the core instrument that harmonises anti-doping policies, rules and regulations across sport organisations and public authorities worldwide; it operates in conjunction with eight International Standards designed to foster consistency among anti-doping organisations. See World Anti-Doping Agency, World Anti-Doping Code (2021).
2. The National Anti-Doping Agency (NADA), India, is an autonomous body under the Ministry of Youth Affairs and Sports, Government of India. It implements the anti-doping programme in India through sample collection, results management, anti-doping education and awareness, research, and intelligence and investigations, and is committed to fostering a dope-free sporting environment.
3. The National Anti-Doping Appeal Panel is an independent, quasi-judicial body responsible for hearing and deciding appeals concerning anti-doping rule violations, constituted under the National Anti-Doping Act, 2022. See The National Anti-Doping Act, 2022, No. 15, Acts of Parliament, 2022 (India).
4. The Court of Arbitration for Sport is an international body established in 1984 to resolve sport-related disputes through arbitration. It is headquartered in Lausanne, Switzerland, and maintains decentralised offices in New York and Sydney.
5. The World Anti-Doping Agency is an international organisation, co-founded by the International Olympic Committee and the governments of more than 140 nations and headquartered in Canada, that promotes, coordinates and monitors the fight against doping in sport.
6. The National Anti-Doping (Amendment) Bill, 2025, PRS Legislative Research, https://prsindia.org/billtrack/the-national-anti-doping-amendment-bill-2025 (last visited Aug. 16, 2025).
7. The National Anti-Doping (Amendment) Bill, 2025, inserting Section 2A(1): “Notwithstanding anything to the contrary contained in any other law, such of the provisions of the World Anti-Doping Code as are set out in the Schedule shall have the force of law in India.” Bill as passed by the Lok Sabha, https://prsindia.org/files/bills_acts/bills_parliament/2025/Bill_as_passed_by_LS_National_Anti_Doping_Bill.pdf (last visited Aug. 16, 2025).
8. In the National Anti-Doping Act, 2022, Section 2 sets out the definitions, establishing the meaning of the key terms used throughout the legislation and providing the Act’s foundational vocabulary. See The National Anti-Doping Act, 2022, No. 15, § 2, Acts of Parliament, 2022 (India).
9. These terms are defined in Section 2 of the National Anti-Doping Act, 2022; under the Bill, terms that are not defined in the Act but appear in the Code retain the meanings assigned to them by the Code. See The National Anti-Doping (Amendment) Bill, 2025.
10. An International Federation is an international organisation that unites national member bodies to govern and promote a particular sport or discipline on a global scale.
11. “IOC” and “IPC” refer to the International Olympic Committee and the International Paralympic Committee, respectively, the international bodies that partner to stage the Olympic and Paralympic Games in the same host city.
12. The International Standard for Laboratories (ISL) is a mandatory International Standard developed under the World Anti-Doping Programme. Its principal purpose is to ensure that WADA-accredited and WADA-approved laboratories report valid results based on reliable evidentiary data, and to promote harmonisation in the analytical testing of samples. See World Anti-Doping Agency, International Standard for Laboratories (2021).
13. The National Anti-Doping (Amendment) Bill, 2025, amending Section 23 of the principal Act to substitute “prescribed” for “specified by regulations” and to provide that the World Anti-Doping Agency, the International Olympic Committee, the International Paralympic Committee and the concerned International Federation may prefer an appeal against a decision of the Appeal Panel to the Court of Arbitration for Sport, in accordance with the rules of that Court and the Code.
14. World Anti-Doping Agency v. National Anti-Doping Agency of India & Priyanka, CAS 2024/A/10871; World Anti-Doping Agency v. National Anti-Doping Agency of India & Radhika, CAS 2024/A/10872 (Ct. Arb. Sport), https://www.tas-cas.org/fileadmin/user_upload/10871_Award__for_publ._.pdf (last visited Aug. 20, 2025).
15. An adverse analytical finding (AAF), commonly described as a positive test, occurs when a WADA-accredited laboratory identifies the presence of a prohibited substance, or its metabolites or markers, in a sample.
16. Parvej Khan is an Indian track athlete from Haryana. Competing collegiately in the United States, he won the 1500 metres at the 2024 SEC Outdoor Track and Field Championships in Florida, and had earlier taken gold in the 800 metres at the under-16 national championships in Mangalagiri. In August 2025 he was banned from competition for six years for anti-doping rule violations.
17. After NADA India serves a notice, where the athlete or other person charged does not waive the right to a hearing under Articles 8.3 and 10.8.1 of the National Anti-Doping Rules, 2021, the matter is referred to the Anti-Doping Disciplinary Panel (ADDP) for hearing and adjudication.
18. Erythropoietin (EPO) is a hormone, produced principally by the kidneys, that stimulates the bone marrow to produce red blood cells.
19. Article 2.1 of the World Anti-Doping Code defines an anti-doping rule violation as the “presence of a Prohibited Substance or its Metabolites or Markers in an Athlete’s Sample,” and establishes the principle of strict liability, under which athletes are solely responsible for what enters their bodies. See World Anti-Doping Agency, World Anti-Doping Code art. 2.1 (2021).
20. Legislative Brief on the National Anti-Doping (Amendment) Bill, 2025, Nation First Policy Research Centre, https://www.linkedin.com/pulse/legislative-brief-national-anti-doping-dz5ec/ (last visited Aug. 16, 2025).
21. Article 13 of the World Anti-Doping Code governs the appeals process for decisions on anti-doping rule violations, ensuring that athletes and anti-doping organisations may challenge rulings through a standardised, independent process. See World Anti-Doping Agency, World Anti-Doping Code art. 13 (2021).
22. Section 2A of the Bill provides that, “[n]otwithstanding anything to the contrary contained in any other law, such of the provisions of the World Anti-Doping Code as are set out in the Schedule shall have the force of law in India,” and empowers the Central Government, from time to time, by notification in the Official Gazette, to amend the Schedule in conformity with duly adopted amendments to the Code. See The National Anti-Doping (Amendment) Bill, 2025.