Mahalakshmi Case Update: Online Rummy Operators Get Some Respite

For the last few years the case of Mahalakshmi Cultural Association v. The Director, Inspector General of Police & Ors¹ ("Mahalakshmi Case"), before the Supreme Court of India ("SC"), had been causing the brick and mortar clubs and online gaming businesses much anxiety. In a dramatic turn of events, over the last week the SC has delivered two orders, which give operators organising skill based games some respite. A brief background on this matter and the relevant consequences of the orders are discussed below.

Background

The gambling laws in India are State specific. In most State enactments games of skill are excluded from the application of gambling laws. In the year 1968, the Supreme Court of India in State of Andhra Pradesh v. Satyanarayan² ("Satyanarayana Case") held that Rummy (a 13 card game) was a game of skill and therefore gambling law should not apply. Following this order, various courts held that games of skill fell outside the purview of the