Let π: (M, H) → (B, b) be a submersion equipped with a horizontal connection H over a Riemannian manifold (B, b). We present an intrinsic curvature condition that only depends on the pair (H, b). By studying a set of relative flat planes, we prove that a certain class of pairs (H, b) admits a compatible metric with positive sectional curvature only if they are fat, verifying Wilhelm's Conjecture in this class.