Haryana’s Prevention of Public Gambling Act, 2025: A Game-Changer for Gaming Laws

The passing of the Haryana Prevention of Public Gambling Act, 2025 (“the HPPGA” or “the Act”) marks a significant development in the State’s approach towards regulating the gambling and the gaming sector. The Act primarily aims to curb gambling (offline as well as digital), including betting on sports or any form of match fixing or spot fixing in sports within the state of Haryana.

As States across India have been increasingly exercising their legislative powers to regulate gambling and online betting, Haryana is the latest state to have joined this list after Chhattisgarh, Tamil Nadu and Karnataka.

 The HPPGA 2025, introduces a broad framework prohibiting various forms of gambling, which extends to both physical and digital mediums. The scope of the legislation also includes online platforms which are accessible within the territorial limits of Haryana (even if there is no physical or corporate presence of the entity within the State of Haryana).

Some of the key aspects surrounding the statute are discussed below:

Section 2(1)(e) of the Act states that ‘gambling’ is an act that involves betting or gaming or both and includes a game of chance using instruments of gambling or otherwise. Even though the definition uses the term ‘gaming’ (within might raise some eyebrows at first glance), the statute goes on to define the terms ‘game of chance’ and ‘game of skill’ and differentiate between the two to carve out an exception for ‘games of skill’.

The Act defines a ‘game of chance’ as any game which has a preponderance of chance over skill, i.e. where chance plays a greater role in determining the outcome of the game than skill. On the other hand, the definition of the term ‘game of skill’ is a rather elaborate one. While the statute defines such games that have a preponderance of skill over chance, it goes on to mention that in games of skill, success depends principally on the superior knowledge, training, attention, experience and adroitness of the player, despite there being an element of chance.

To create an exception for games of skill, Section 2(1)(g) of the Act carves out a proviso which mentions that - “Provided that the State Government may notify any game to be included as game of skill.” Interestingly, the provision gives the power to the State to designate the game as a game of skill (and doesn’t automatically recognize the games which have been declared as games of skill by the Indian judicial bodies).

Such an approach also raises a recurrent question of the appropriate authority to determine whether a real money game is skill-based or not. Since the Central government has the power to regulate ‘online gaming intermediaries’ (and the IT Rules, 2021 mention about formation of self-regulatory bodies to approve the operation of real money games), the approach on the part of a State government to retain the power to determine whether a game is a game of skill or not effectively overlaps with the power of the Central government (thereby opening up the potential differing views on some online real money games).

While the statute seems to be focusing on gambling, it also ventures into the domain of match fixing and spot fixing (both are subsets and specific types of gambling). The Act targets match-fixing and spot-fixing in sports, making such offences punishable with a minimum of three years’ imprisonment (which may extend to five years), and a minimum fine of INR 5 lakh. Repeat offenders may face harsher penalties, including imprisonment of up to seven years.

It further needs to be noted that the Act takes a broad and inclusive approach by extending liability beyond just players (by adding an explanation clause to the definition of ‘player’ to include every person involved in the organization of the game or match in whatever capacity including official, manager, physio-instructor, coach, referee, umpire, ground-men, etc.).

The HPPGA introduces substantial legal uncertainty for online real money gaming platforms. Although the Supreme Court of India has time and again upheld the legality of skill-based games (such as fantasy sports), the Act’s vague language and lack of explicit exemptions for these games put legitimate operations of such platforms in a state of uncertainty.

The discretionary power granted to the State government under Section 2(1)(g) to ‘notify’ what qualifies as a skill game further compounds this uncertainty. As a result, many companies have either suspended their operations or issued user advisories as a precautionary measure.

SportsBaazi, which runs a sports prediction platform, has added the following disclaimer to caution users in Haryana: 

“Pursuant to the provisions of the Haryana Gambling Act and in the absence of sufficient legal clarity on the applicability of the law to online games of skill, we advise users located within the territorial jurisdiction of Haryana to proceed with caution and refrain from participating in any sports engagement formats like Fantasy and its variants offered on the Platform, until further notice. This advisory is issued purely as a matter of legal prudence and shall remain applicable until SportsBaazi receives legal and regulatory clarity regarding the implications of the Haryana Gambling Act on online real money gaming."

Mobile Premier League (MPL), one of India’s leading online gaming platforms, has disabled features like MPL Opinio and MPL Fantasy for Haryana users, and stated the following in its Terms and Conditions:

“Formats that pertain to events whose outcome is unknown, specifically MPL Opinio and MPL Fantasy, shall not be used by users located in the state of Haryana."

It is expected that the Haryana government will introduce clarifications on the exempted ‘games of skill’ to ensure that at least the judicially recognized games of skill can legally operate in the State with certainty.

While the objective of introducing a statute to curb gambling and fixing accountability in sports by Haryana is understandable, the lack of clarity on how and when skill-based games will be approved by the State government is something that everyone will be watching out for. The lack of clarity of the games, which have already been declared games of skill by judicial bodies, has placed legitimate gaming platforms in a precarious position.

In the absence of a mechanism of the Central government (for the determination of games as skill-based), India’s gaming industry is left to navigate a complex and inconsistent regulatory landscape, which differs from State to State. Until there is legislative uniformity through Central and State coordination, businesses and users alike must proceed with caution while accessing real money gaming platforms, particularly in States like Haryana, where the regulatory framework currently remains ambiguous.

About the authors: Gaurav Bhalla is a Partner and Parag Singhal is an Associate at Ahlawat & Associates.

Disclaimer: The opinions expressed in this article are those of the author(s). The opinions presented do not necessarily reflect the views of Bar & Bench.

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