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Equine doping: the Council of State upholds trainer liability

14/05/2026

Enrico Bellei is not just any name in Italian harness racing. Born in Florence in 1963, he won the Italian Trotting Derby in 1997, 2004, 2012 and 2015, was crowned European Drivers' Champion in 2010 and 2012, and claimed the Golden Whip — the award given to the driver with the most wins in a year — on 23 occasions. In the world of harness racing, they call him "The Emperor." And yet even the weight of such a career was not enough to change the outcome of proceedings in which he has lost at every level he chose to contest.

The matter stems from an anti-doping test on a horse he was training, which came back positive. The MASAF — the Ministry of Agriculture and Food Sovereignty, the authority responsible for the equestrian sector — imposed a six-month professional suspension from his activities as both trainer and driver. Bellei challenged the decision before the TAR Lazio administrative court, which upheld it. He then appealed to the Council of State. The Sixth Section dismissed the appeal as well, declaring it "unfounded and lacking any solid legal basis," and ordered him to pay the Ministry's legal costs.


A Fundamental Principle

At the heart of the ruling is the liability framework that the Regulations on the Control of Prohibited Substances — updated by the MASAF by decree in 2023 — assigns to the trainer. Article 3.3 is unambiguous: the trainer is responsible for the management, protection and safety of the horse. A direct and non-delegable responsibility.

Bellei's defence had taken a different approach: arguing that the violation was not attributable to him, placing blame on a member of staff. In support of this argument, a single self-declaration by the staff member in question was submitted. The judges found it wholly insufficient. The Council of State made clear that the mere presence of prohibited substances in the animal's system is enough to establish the infraction, since such substances "are presumed to have a doping effect, regardless of whether any actual alteration of competitive performance is detected." As no evidence was provided that the event was entirely beyond the trainer's control, liability remains with him — both for culpa in eligendo (the choice of personnel) and culpa in vigilando (the failure to exercise oversight).


The Numbers

The Bellei case is not an anomaly within an otherwise clean system. It is an episode that must be properly situated within a picture painted by official figures. In 2024 (the most recent data available), 13,570 anti-doping checks were carried out across racetracks and training centres: 3,751 in flat racing, 9,371 in trotting and 445 in the saddle discipline. The overall positive rate was 0.33%. A figure that, taken in isolation, might appear reassuring — but is not, once broken down.

The rate of positive results at training centres was significantly higher than at the track: 2.3% versus 0.35% in trotting; 0.96% versus 0.37% in flat racing. In settings less exposed to public scrutiny — stables, daily sessions away from the grandstands — the phenomenon is considerably more widespread. It is precisely there that the trainer's responsibility becomes critical, and it is there that the culpa in vigilando established by the Council of State carries its most important meaning.


What Does the Ruling Mean?

The decision in the Bellei case reaffirms that delegating to a member of staff is not enough, that pleading ignorance is not enough, that a self-declaration is not enough. Anyone who trains a horse must know what is being administered to it, by whom, when and why. If something slips beyond their control, it is they who have failed in their duty of oversight.

For IHP, this is not merely a legal principle: it is a matter that directly concerns animal welfare. A horse subjected to prohibited substances without therapeutic need is a horse exposed to risks it did not choose and cannot refuse. As long as the system continues to treat the animal as an instrument of performance and profit, doping will remain a structural temptation. The Council of State's ruling at least sets a boundary.