The primary legislation governing gambling in India is the Public Gambling Act, 1867(“PGA”). The PGA criminalises act connected with ‘gambling’ in a public forum and the keeping of a ‘common gaming house’. The PGA, however, creates an essential exception in favour of games of skill, by simply revealing.
In figuring out if a given game or challenge is a Game of Skill or chance, Indian courts have embraced the standard of evaluating the ‘Dominant factor’ of a Game. The two most vital Indian cases in such manner are State of Andhra Pradesh v. K Satyanarayana (AIR 1968 SC 825) (the "Satyanarayana" case) and KR Lakshmanan v. Condition of Tamil Nadu (AIR 1996 SC 1153) (the "Lakshmanan" case).
In the Satyanarayana case, the Supreme Court characterized a ‘Game of mere Skill’ to mean a diversion "in which, in spite of the fact that the component of chance essentially can't be completely wiped out, achievement depends basically upon the unrivalled Knowledge, training, consideration, experience and adeptness of the player." By use of this definition, the Supreme Court held that the Game of rummy was a Game of Skill, and did not amount to betting or gambling under the PGA. While maintaining the duty of an ostensible administration charge for procurement of a physical space, cards, and so on, to play a session of rummy, the Court reasoned:
"Rummy...... requires certain measure of expertise in light of the fact that the fall of the cards must be remembered and the building up of Rummy requires considerable skill in holding and discarding cards. We can't, thusly, say that the Game of Rummy is a Game of entire chance. It is mainly and preponderantly a Game of ability."
In the Lakshmanan case, the Supreme Court held that the wagering on steed races was a session of ability. It supported that in a steed race the victor is not controlled by chance alone, as the condition, pace and perseverance of the steed and the expertise and administration of the rider are components influencing the consequence of the race. The bettor has the chance to practice his judgment and circumspection in deciding the steed on which to wager.