# All India Football Federation v. Rahul Mehra & Ors

- **Citation:** 2025 INSC 1131
- **Court:** Supreme Court of India
- **Decided:** 2025-09-19
- **Bench:** Pamidighantam Sri Narasimha, Joymalya Bagchi
- **Source:** https://unisonlegal.in/judgment/supreme-court-of-india/all-india-football-federation-v-rahul-mehra-ors-38643
- **Pages:** 64

## Headnote

Should Eminent Players be in the General Body; if so, to what
extent; what should be the Eligibility criteria to be designated
an Eminent Player; whether 'Office bearers' should be limited
to President, Treasurer, Secretary; whether the number of VPs
should be increased to ensure regional representation; whether
public servants should be included under disqualification events;
whether 'indirect interest' should be retained in the definition of
'conflict of interest'; should the All India Football Federation (AIFF)
Constitution apply to state associations; what is the permissible
extent of delegation of powers, functions, and exploitation of
rights by AIFF to third parties; whether promotion and relegation
should form part of the AIFF Constitution; to what extent are
BCCI judgements applicable to football; should Amendments to
the Constitution be approved by the Supreme Court; whether the
current AIFF administration is a permanent or interim body.
Headnotes†
Sports - National Sports Development Code of India, 2011 -
Draft Constitution of the appellant-Federation (AIFF) -
Objections and suggestions from relevant stakeholders - Draft
approved and finalised, with few modifications - AIFF to call for
a special general body meeting and adopt the draft Constitution
with the modifications, preferably within 4 weeks - National
Sports Governance Act, 2025. [Paras 24-122]
Sports - Should Eminent Players be in the General Body, to
what extent - National Sports Development Code of India,
2011 - Clauses 3.9, 3.10 or 3.20:
Held: 1.1 A harmonious and conjoint reading of clauses 3.9, 3.10 or
3.20 show that clause 3.20 is essentially a carve-out from clauses
3.9 or 3.10, and grants voting rights to the class of persons indicated
[2025] 9 S.C.R.
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All India Football Federation v. Rahul Mehra & Ors.
therein, i.e., "prominent sportspersons of outstanding merit" - The
substantive composition of the organisational structure should
consist of member associations, and it is contemplated to be an
ideal situation to have eminent sportspersons having voting rights -
The percentage indicated in clause 3.20 of the NSC 2011 is not
transgressed by clause 20.2 of the draft Constitution. [Para 33]
1.2 The freedom of choice to form an association is not in any
way compromised by the requirement to incorporate 15 eminent
players - The democratic setup of the federation is not destabilised
as the elected member associates certainly continue to hold more
than 62% as the NSC 2011 u/clause 3.20 only suggests that the
number of prominent sportspersons should be a minimum of 25%
which means that model provision has not prohibited a number
larger than 25% - The inclusion of eminent players, coaches,
referees, and club representatives in the general body, will only
further good governance, herald transparency and fair play - The
draft provision not interfered with. [Paras 35, 36]
Sports - Eligibility criteria for Eminent Players - Article 1.19
of the draft Constitution:
Held: The draft Constitution prescribed a criterion - It is reasonable
to reduce the eligibility criteria for an Eminent Player suggested
by Justice L N Rao, to 5 matches for men and from 2 matches
for women - Such modification will ensure a wider pool and
participation by retired players who will prove themselves to be
efficient administrators and guiding lights for Indian football -
Submission of AIFF qua counting domestic experience for eminence
status, not accepted - Domestic experience might not yield the
result sought to be achieved with the adoption of the Constitution,
which is formulated to project Indian football on the international
panorama. [Para 40]
Sports - Whether 'Office bearers' should be limited to
President, Treasurer, Secretary - Definition of "Office-Bearers":
Held: Office bearers must be understood in the context of the
functioning of the AIFF and the reform that needs to be brought
about - This definition will have a direct bearing on the applicability
of cooling-off, the ter

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[2025] 9 S.C.R. 1146 : 2025 INSC 1131
All India Football Federation
v.
Rahul Mehra & Ors.
(Civil Appeal No(s). 12591-12592 of 2025)
19 September 2025
[Pamidighantam Sri Narasimha and Joymalya Bagchi, JJ.]
Issue for Consideration
Should Eminent Players be in the General Body; if so, to what
extent; what should be the Eligibility criteria to be designated
an Eminent Player; whether 'Office bearers' should be limited
to President, Treasurer, Secretary; whether the number of VPs
should be increased to ensure regional representation; whether
public servants should be included under disqualification events;
whether 'indirect interest' should be retained in the definition of
'conflict of interest'; should the All India Football Federation (AIFF)
Constitution apply to state associations; what is the permissible
extent of delegation of powers, functions, and exploitation of
rights by AIFF to third parties; whether promotion and relegation
should form part of the AIFF Constitution; to what extent are
BCCI judgements applicable to football; should Amendments to
the Constitution be approved by the Supreme Court; whether the
current AIFF administration is a permanent or interim body.
Headnotes†
Sports - National Sports Development Code of India, 2011 -
Draft Constitution of the appellant-Federation (AIFF) -
Objections and suggestions from relevant stakeholders - Draft
approved and finalised, with few modifications - AIFF to call for
a special general body meeting and adopt the draft Constitution
with the modifications, preferably within 4 weeks - National
Sports Governance Act, 2025. [Paras 24-122]
Sports - Should Eminent Players be in the General Body, to
what extent - National Sports Development Code of India,
2011 - Clauses 3.9, 3.10 or 3.20:
Held: 1.1 A harmonious and conjoint reading of clauses 3.9, 3.10 or
3.20 show that clause 3.20 is essentially a carve-out from clauses
3.9 or 3.10, and grants voting rights to the class of persons indicated
[2025] 9 S.C.R.
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All India Football Federation v. Rahul Mehra & Ors.
therein, i.e., "prominent sportspersons of outstanding merit" - The
substantive composition of the organisational structure should
consist of member associations, and it is contemplated to be an
ideal situation to have eminent sportspersons having voting rights -
The percentage indicated in clause 3.20 of the NSC 2011 is not
transgressed by clause 20.2 of the draft Constitution. [Para 33]
1.2 The freedom of choice to form an association is not in any
way compromised by the requirement to incorporate 15 eminent
players - The democratic setup of the federation is not destabilised
as the elected member associates certainly continue to hold more
than 62% as the NSC 2011 u/clause 3.20 only suggests that the
number of prominent sportspersons should be a minimum of 25%
which means that model provision has not prohibited a number
larger than 25% - The inclusion of eminent players, coaches,
referees, and club representatives in the general body, will only
further good governance, herald transparency and fair play - The
draft provision not interfered with. [Paras 35, 36]
Sports - Eligibility criteria for Eminent Players - Article 1.19
of the draft Constitution:
Held: The draft Constitution prescribed a criterion - It is reasonable
to reduce the eligibility criteria for an Eminent Player suggested
by Justice L N Rao, to 5 matches for men and from 2 matches
for women - Such modification will ensure a wider pool and
participation by retired players who will prove themselves to be
efficient administrators and guiding lights for Indian football -
Submission of AIFF qua counting domestic experience for eminence
status, not accepted - Domestic experience might not yield the
result sought to be achieved with the adoption of the Constitution,
which is formulated to project Indian football on the international
panorama. [Para 40]
Sports - Whether 'Office bearers' should be limited to
President, Treasurer, Secretary - Definition of "Office-Bearers":
Held: Office bearers must be understood in the context of the
functioning of the AIFF and the reform that needs to be brought
about - This definition will have a direct bearing on the applicability
of cooling-off, the term, tenure and age limit - The inclusive definition
will be consistent with the reforms that have been introduced and
applied as independent measures for the vibrant working of the
federation. [Para 42]
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Sports - Whether the number of Vice-Presidents (VPs) should
be increased to ensure regional representation - Number of
VPs:
Held: No harm is caused by exceeding the membership of the
executive committee - Both Committee of Administrators (CoA)
and Justice L N Rao have taken into account the NSC 2011 and
balanced it with the demands of the sport - Order of this Court dtd.
22.08.2022 provided that the EC of the federation will consist of
23 persons as an arrangement at that time, a higher number than
the 12-person committee - Therefore, the size of the executive
committee not reduced - The suggestion(s) made by the State
Associations to increase the number of VPs to five would not be
possible in the present statutory scheme - However, the argument
of AIFF for increase in the number of VPs to 3, which shall include
one woman, is accepted - Such an amendment will enable women's
representation and, at the same time, confine the number of the
executive committee to fifteen members. [Paras 45, 47]
Sports - Public servants, if to be included under disqualification
events - Article 1.17 of the amended Constitution by Justice
L N Rao:
Held: The provision of disqualification based on framing of charge
is modified to the standard as envisaged in the later judgement of
BCCI i.e., "conviction followed by a sentence of imprisonment" -
Further, an amendment was passed by the BCCI which was
approved by this Court, restricting the disqualification from being
a "minister or government servant or holding a public office" to
being "a minister or government servant" - In agreement with the
view of BCCI, the provision in Article 1.17(g) modified to "being
a minister or government servant" - Furthermore, even if such a
person is a public servant, if he or she has the necessary approval
of the government, there should not be a problem u/s.4(2)(e)
of the newly enacted NGSA 2025 - The rules and regulations
applicable to a government servant provide a particular standard
to be maintained - The standard requires the public servant to
obtain necessary permissions - If these permissions are taken,
there is no justification to restrict or disqualify a public servant
altogether. [Paras 55, 58, 59]
Sports - Whether 'indirect interest' should be retained in
the definition of 'conflict of interest' - AIFF submitted that
[2025] 9 S.C.R.
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All India Football Federation v. Rahul Mehra & Ors.
a conflict of interest, as defined in Article 73.1, should not
include indirect interest - It contended that while Article
73.5 adequately covers the scenarios of conflict, it renders
Article 73.1 otiose and unnecessary - Plea of Amici that the
suggestion of AIFF does not take into account that Articles
73.1(a) and 73.5 cover entirely different fields:
Held: Art.73.1(a) is focused on indirect conflicts of interest, conflicts
through relatives, partners, or close associates; conflicts like an
Executive Committee Member's spouse running a football coaching
academy - Whereas, Art.73.5 broadly prohibits the individual from
holding two posts - a more direct conflict - and does not speak of his
interest through related parties - On plain reading of both Arts.73.1
and 73.5, it is clear that both cover different fields of conflict - The
judgment in BCCI has also approved of disqualifications based on
indirect conflicts - No reason to arrive at a different conclusion.
[Para 63]
Sports - Applicability of AIFF Constitution to State Associations:
Held: In view of the chequered history of Indian football
administration, and also that governance of football trickles down
from the superstructure to the base, i.e., National Sports Federations
(NSFs) conform to FIFA, it is important that the state associations
and local bodies conform to the NSFs - First, the office bearer(s) of
the state association will acquire with time an invaluable experience
of football governance in the same manner as the institutional history
of the AIFF - This will happen because the governance model of
both the NSF and state associations will overlap - Compliance
and application of best practices formulated in consultation with
FIFA at the local levels will ensure that the sport of football
remains organised, both in principle and in practice - In view of
the FIFA Statute, the relevant comments of Justice L N Rao and
on analysis of the far-reaching implications of this provision, the
argument that the AIFF Constitution ought not be extended to the
state associations and local bodies, not accepted. [Paras 70, 71]
Sports - Delegation of powers, functions, and exploitation of
rights by AIFF to third parties - Permissible extent of - Football
Sports Development Limited (FSDL) suggested few changes
to the proposed Constitution namely, a relevant amendment
to Art.1.21 to make the definition of 'essential aspects' less
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Supreme Court Reports
restrictive; an amendment to Art.63 to expand the role of private
parties in exploitation of rights under sports' contracts and;
also submitted that 'promotion and relegation' should not be
a criteria to satisfy the definition of 'seniormost top division
league', as defined under Art.1.54:
Held: Though there was agreement at the bar on FSDL's
suggestions on the addition of the word 'ownership' in Article
63.1, the expression is superfluous and unnecessary - AIFF has
objections to the use of the word 'organisation' and 'promotion and
relegation' in the definition of essential aspects u/Art.1.21 - Art.1.21
which had no equivalent in the Constitution drafted by the CoA,
is in the nature of a membrane separating the rights and duties
of the federation and third parties with whom the federation might
enter into contract(s) - It does not create any harm to the private
interest, except for the fact that it will impact the working of the
text of the Master Rights Agreement (MRA) - While this Court is
satisfied with the provision u/Art.1.21, and it has been apprised
that the term of the ongoing extended MRA will expire in 2025, it
is made clear that it shall be open for the federation to enter into
contractual settings, but in complete obedience to the boundary
as laid down in Art.1.21 - FSDL's suggestions qua Art.63 as well,
which are premised and expand upon the definitional clause in
Art.1.21, not adopted. [Para 79]
Sports - Whether promotion and relegation should form part
of the AIFF Constitution:
Held: After going through the literature on the principles of promotion
and relegation, the arguments of the counsels, as well as the written
material placed on record, it is held that the proposed provisions
do not necessitate any amendment. [Para 87]
Sports - Applicability of principles laid down in BCCI Judgment
to the present case concerning football administration:
Held: The BCCI series of cases envisaged and embarked on a new
dawn of Indian sports governance, and also developed principles
and best practices which can be imbibed in letter and spirit -
Distinguishing BCCI judgments only on the ground that BCCI is not
an NSF, while AIFF is, does not yield any good -The arguments
advanced by AIFF and State association are rejected. [Paras 88, 90]
[2025] 9 S.C.R.
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All India Football Federation v. Rahul Mehra & Ors.
Sports - Amendments to the AIFF Constitution, if should be
approved by the Supreme Court and the need for the Supreme
Court to retain control:
Held: The suggestion regarding insertion of "Article 23.3 - Any
such amendment shall not be given effect to without the leave
of the Hon'ble Supreme Court" is accepted for the present -
However, it is not appropriate to have continuous monitoring of
a sports federation by any forum, including the Supreme Court
- Having taken up the matter and ensured that the Constitution
is brought to this stage, it is necessary to take it to its logical
end - Supreme Court's monitoring will only be that far and no
further. [Para 94]
Sports - Whether the current AIFF administration is a
permanent or interim body:
Held: The current executive committee can be treated as a
permanent body which shall discharge its function in accordance
with the relevant laws as well as the AIFF Constitution. [Para 101]
Sports - Draft Constitution of the appellant-Federation (AIFF) -
Certain objections/suggestions with respect to other clauses,
viz. On the definition and criteria of the Candidate; Definition
of 'immediate family'; Obligation of member associations;
Suspension and Resignations; Executive committee and
concurrent memberships; Acting President etc. - Considered.
[Paras 103-121]
Case Law Cited
Public Interest Foundation v. Union of India [2018] 10 SCR 141 :
(2019) 3 SCC 224; BCCI v. Cricket Association of Bihar [2016]
8 SCR 606 : (2016) 8 SCC 535; N.P. Ponnuswami v. Returning
Officer, Namakkal Constituency [1952] 1 SCR 218 : AIR 1952 SC
64; Jagan Nath v. Jaswant Singh [1954] 1 SCR 892 : AIR 1954
SC 210; Dr. N. B. Khare v. Election Commission of India [1958] 1
SCR 648 : AIR 1958 SC 139; BCCI v. Cricket Association of Bihar
[2022] 14 SCR 519 : (2022) 19 SCC 30; Damyanti Naranga v.
Union of India [1971] 3 SCR 840 : (1971) 1 SCC 678; BCCI v.
Cricket Association of Bihar [2018] 9 SCR 526 : (2018) 9 SCC
624 - referred to.
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Supreme Court Reports
Indian Olympic Association v. Union of India, 2014 SCC OnLine
Del 2967; Rahul Mehra v. Union of India, 2022 SCC OnLine Del
2438 - referred to.
Books and Periodicals Cited
Mihir Bose, A History of Indian Cricket (London: Andre Deutsch
Ltd, 1990), pp.16-17; Boria Majumdar & Kausik Bandyopadhyay,
'A Social History of Indian Football: Striving to Score' (Sport in
the Global Society, Routledge, 2008, Taylor and Francis), pg.
109; M. Dutta Ray, 'Playing Experience Needed in our Football
Administration', in WIFA Golden Jubilee Souvenir (Bombay: WIFA,
1961); Annexure II (Guidelines for the Recognition of National Sports
Federation) of the NSC 2011; C Boillat and R Poli, 'Governance
Models Across Football Associations and Leagues' in Réflexions
sportives, vol 4, International Centre for Sport Studies (2007);
Electoral Disqualifications, Report No. 244 (Law Commission of
India; February, 2014); Jasina, John and Rotthoff, Kurt W., A Model
of Promotion and Relegation in League Sports (November 1,
2009). Journal of Economics and Finance, Volume 36, Issue 2,
Pages 303-318.
List of Websites
https://cdnbbsr.s3waas.gov.in/s3ca0daec69b5adc880fb4
64895726dbdf/uploads/2022/0 8/2022081612.pdf; https://ssrn.
com/abstract=1512144; https://inside.fifa.com/fifa-world-ranking/
IND; https://inside.fifa.com/legal/judicial-bodies.
List of Acts
National Sports Development Code of India, 2011; Constitution
of India; National Sports Governance Act, 2025; FIFA Statutes,
2022; Representation of the People's Act, 1951; FIFA Statute,
2024; Penal Code, 1860.
List of Keywords
All India Football Federation; Draft of the Constitution of All
India Football Federation; Draft of the Constitution of AIFF; AIFF
Constitution; Eminent players; Sports federations; AIFF's election;
Committee of Administrators (CoA); National Sports Federation
(NSFs); FIFA; Continuous monitoring of a sports federation;
Constitution of AIFF, 2017.
[2025] 9 S.C.R.
1153
All India Football Federation v. Rahul Mehra & Ors.
Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No(s). 1259112592 of 2025
From the Judgment and Order dated 31.10.2017 of the High
Court of Delhi at New Delhi in CM No. 46919 of 2016 and CM
No. 19815 of 2012
Appearances for Parties
Advs. for the Appellant(s):
Ranjit Kumar, Sr. Adv., Siddhesh Shirish Kotwal, Ms. Manya Hasija,
Ms. Ana Upadhyay, T.illayarasu, Ms. Vaidehi Kolhe, Saurabh Guha,
Mrs. Rasika Jalan, Nagarkatti Kartik Uday.
Advs. for the Respondent(s):
Gopal Sankaranarayanan, Sr. Adv./Amicus Curiae, Samar Bansal,
Amicus Curiae.
Tushar Mehta, Solicitor General, K. M. Nataraj, A.S.G.,
Ms. Swarupama Chaturvedi, Neeraj Kishan Kaul, Ritin Rai, Dr.
Menaka Guruswamy, Ms. Anitha Shenoy, Raghenth Basant, Sr.
Advs., Apoorv Kurup, Sharath Nambiar, Vinayak Sharma, Vatsal
Joshi, Ms. Indira Bhakar, Chitransh Sharma, Anuj Srinivas Udupa,
Ms. Satvika Thakur, Ms. Nikita Capoor, Ms. Yogya Rajpurohit,
S. Subramaniam, Ayush Ranjan, Ms. Ritika Ranjan, Kanu Agrawal,
Rajat Nair, Arkaj Kumar, Padmesh Mishra, Dr. N. Visakamurthy,
Nar Hari Singh, Sanjeev K. Kapoor, Sahil Narang, Dhritiman Roy,
Ayushman Kacker, Vidush Sinha, Raghav Agarwal, Madhavam
Sharma, M/S. Khaitan & Co., Prateek K Chadha, Utkarsh
Pratap, Sreekar Aechuri, Aniket Chauhaan, Ms. Bhumika Yadav,
Ms. Shaswati Parhia, Ms. Kashish Jain, Kotla Harshavardhan,
Raghav Kohli, N. Sai Vinod, Anmol Gupta, Shuvodeep Roy,
Siddharth Nath, Asjad Hussain, Ms. Anunaya Chowdhary, Vedant
Kapur, Tushar Shrivastava, Ms. Jhanvi Dubey, Ms. Shreya Nair,
Vishal Sinha, Ms. Trisha Chandran, Nagarkatti Kartik Uday, Ms.
Hetu Arora Sethi, Shivam Singh, Anirudh Bhat, Nirmal Prasad,
Yoshit Jain, Shubham Janghu, Ishwar Singh, Sravan Kumar
Karanam, Akshay Mann, Kumar Abhishek, Sadhana Madhavan,
Divyanshu Rai, Ms. Kaushitaki Sharma, Kshitij Maheshwari, Ms.
Purnima Krishna.
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Judgment / Order of the Supreme Court
Judgment
Contents*
1. Establishment of All India Football Federation and its history
thereafter ...............................................................................
5
2. Issues for Consideration ....................................................... 20
i.
Re: Eminent Players in the General Body ..................... 22
ii. Re: Eligibility Criteria for Eminent Players ..................... 29
iii. Re: The definition of "Office-Bearers" ............................
31
iv. Re: Number of Vice-Presidents ...................................... 33
v. Re: On Disqualification Event(s) .................................... 36
a) Disqualification on Criminal Charge and Conviction . 38
b) Disqualification on being or becoming a Public Servant
or holding any office in a sports or athletic association
or federation apart from Football, except the IOA ... 40
c) Disqualification of persons who has served as an
office-bearer of any NSF from holding a post in the
AIFF .......................................................................... 43
vi. Re: On retaining 'indirect interest' in the definition of
'Conflict of interest' .......................................................... 44
vii. Re: On the applicability of AIFF Constitution to State
Associations .................................................................... 46
viii. Re: AIFF and Third Parties: Extent of delegation of powers,
functions, and exploitation of rights ................................ 51
ix. Re: Promotion and Relegation in Indian Football .......... 56
x. Re: Applicability of principles laid down in BCCI Judgment
to the present case concerning football administration .. 60
xi. Re: Amendments to the AIFF Constitution and the need
for the Supreme Court to retain control ......................... 61
* Ed. Note: Pagination as per the original Judgment.
[2025] 9 S.C.R.
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All India Football Federation v. Rahul Mehra & Ors.
xii. Re: Whether the current AIFF administration is a permanent
or interim body? .............................................................
63
3. Other objection(s)/suggestion(s)- .......................................... 67
i.
On the definition and criteria of the Candidate: ............. 67
ii. Definition of 'immediate family .......................................
69
iii. Obligation of member associations ................................ 69
iv. Suspension and Resignations ........................................ 70
v. Executive committee and concurrent memberships ...... 70
vi. Acting President .............................................................
72
vii. Quorum ........................................................................... 72
viii. Disciplinary Committee ................................................... 73
ix. Appeal Committee .......................................................... 74
x. Dispute Resolution and Grievance Redressal ............... 74
xi. Schedule III: Election Bye-Laws of All India Football
Federation ....................................................................... 76
4. Conclusion ............................................................................. 77
1.
Leave granted.
2.
Recounting the social history of Indian Football, learned authors1
have observed that;
"While the Indians were fighting the British for their
independence, one of the most popular games in the
country was football. Logically, after independence,
football should have become India's number one sport. It
is cheaper, it certainly permeated more layers of Indian
society - even down to the semi-rural areas - than cricket
and, as in other parts of the world, could have been a
metaphor for nationalism."
1
Mihir Bose, A History of Indian Cricket (London: Andre Deutsch Ltd, 1990), pp.16-17.
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"But as freedom drew close, football's erstwhile role as
a nationalist symbol sharply diminished owing to the
game's increasing communal and regional overtones.
Despite the Indian national team's worthy performances
at international level in the first fifteen years after 1947,
gradually, regionalism seemed to become a more distinct
and viable alternative in Indian football".2
3.
Unlike rights that can be enforced through law, fraternity is not
amenable to judicial command; it must be nurtured through lived
experiences of unity, trust, and shared endeavour. National,
international, regional or even mohalla sports in India serve as the
Karmabhumi where cohesion and collective purpose take tangible
form. They bring together individuals from diverse social, linguistic,
and cultural backgrounds under a common pursuit, embodying the
Constitutional value of fraternity. Here, individual and collective
aspirations find a way to coalesce.
3.1 On the field, teamwork compels individuals to set aside personal
distinctions and work together, cultivating habits of cooperation,
solidarity, and mutual respect. Accessibility of sports is important,
for when opportunities to participate are open to all-irrespective
of race, caste, religion, sex, or economic status-the unifying
power of sport is amplified. This inclusiveness ensures that
sports become not a privilege of the few but a medium through
which fraternity is strengthened across society. In this way,
sports operationalise what the framers envisioned: an intangible
yet indispensable force that holds us together through shared
effort and common purpose.
3.2 It is high time we recognize that sporting "facilities and
opportunities"3 are "material resources of the community" 4, and
their organizers are "the institutions of the national life" 5. As
"places of public resort" 6, sporting institutions and bodies must
2
Boria Majumdar & Kausik Bandyopadhyay, 'A Social History of Indian Football: Striving to Score' (Sport
in the Global Society, Routledge, 2008, Taylor and Francis), pg. 109.
3
Article 38(2), Indian Constitution.
4
Article 39(b), Indian Constitution.
5
Article 38, Indian Constitution.
6
Article 15(2), Indian Constitution.
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All India Football Federation v. Rahul Mehra & Ors.
remain accessible, not just for pursuing sport, but also for its
administration. It should be the deeper Sadhana (endeavour)
of the State, and it is also our Constitutional duty to ensure
that sporting facilities and opportunities flourish with institutional
efficiency, integrity, professionalism, and expertise.
3.3 It is also necessary to ensure that sporting facilities and
opportunities are not concentrated in the hands of the urban
economic elite and that the revenues from sporting events,
intellectual property and media rights are so distributed to
subserve and encourage accessible and affordable sport in
our country.
4.
Establishment of All India Football Federation and its history
thereafter: The AIFF, a National Sports Federation (NSF), was
formed as the governing body of association football in the country
in 1937. It has been observed that AIFF failed to evolve with time,
took eleven years for its affiliation with the global apex body FIFA,
and struggled to manage Indian football efficiently. As a result, the
sport remained distributed in fragments, so much so that players
were alienated from the administration and with time, politics and
regionalism appeared on the centre stage. Taking into account
the lapses in organisational control around Indian football, the
commentators make a few observations, some of which are squarely
applicable to the issues in the present appeals:
"The Indian Soccer Administration
Corruption and lack of professionalism go hand in hand in
Indian football. The sport's apex body in India, AIFF, has
not played it expected role to perfection...So far as the
question of professionalism is concerned, it (AIFF) fares
little better. Since its birth in 1937, AIFF showed an utter lack
of professional attitude towards the game. It took eleven
long years to get affiliated with the world apex body, FIFA.
It played its flawed part in India's failure to participate in
the 1950 World Cup. The unresolved dichotomy of national
and club football has been, to a great extent, a result of
its failure and amateurish duplicity. Moreover, factionalism,
favouritism and infighting within the Federation are plain to
see since its inception. As one of the better administrators
of Indian soccer/ AIFF argued in 1961:
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In our country, however, things are absolutely
different. Whether it be in the All India sphere or
in the State sphere, you will find very few people
in the administration who could claim to be players
themselves. Unless this vital change is introduced
in the selection of the administrative personnel,
I am afraid, our football will never attain its rightful
stature. I have travelled throughout the world and had
an opportunity to see the football set-up in all those
places ... There football is guided by experts; here
by all sorts of people, and the difference is there for
all to see".7
5.
The present appeals arise out of a challenge to the order dated
31.10.2017 passed by the Hon'ble High Court of Delhi in CM No.
46919/2016 and CM No. 19815/2012 in W.P. (C) No. 195/2010
("Impugned Order").
6.
The short facts relevant to the present appeals are that Mr. Rahul
Mehra, respondent no. 1 (in person), preferred a writ petition W.P.
(C) No. 195/2010 raising questions on the working of various sports
federations and their election process, and prayed for issuance of
various writs directing the Union of India to interfere in the same. Amid
the pendency of the writ petition, the Government of India, through
the Ministry of Youth Affairs and Sports, issued a comprehensive code
amalgamating all previous guidelines and notifications in the form
of the National Sports Development Code of India, 2011 ("National
Sports Code"/"NSC").
7.
It is in this context that the respondent no. 1 filed an interlocutory
application C.M. No. 19815 of 2012, specifically praying for a direction
to postpone or stay the proposed elections to the various offices of
the AIFF, as the elections were allegedly being held in violation of
NSC 2011. On 18.12.2012, the High Court passed an order, finding
prima facie merit in the averments of the interlocutory application and
directing the Union of India to examine the holding of AIFF's elections
and pass a reasoned order deciding if the elections are being held
7
Supra 1 at pg. 173 quoting M. Dutta Ray, 'Playing Experience Needed in our Football Administration', in
WIFA Golden Jubilee Souvenir (Bombay: WIFA, 1961). Incidentally Dutta Ray was the president of AIFF
at that time.
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All India Football Federation v. Rahul Mehra & Ors.
in consonance with the regulatory framework. On 23.08.2013, the
Union of India filed an affidavit before the High Court highlighting
that it had examined the validity of elections held on 20.12.2012 and
arrived at the conclusion that the elections "were free and fair and
therefore the body elected in pursuance of the said election is liable
to be accorded recognition". In that manner, the proceedings before
the High Court qua 2012 elections stood concluded.
8.
In 2016, when the election to the AIFF's executive council again
became due, the High Court on 15.12.2016 passed an order staying
the election on the ground that the proposed election exercise
violated the orders passed during the last elections in 2012. It is in
these facts that the appellant filed an interlocutory application CM
No. 46919/2016 seeking vacation of the order dated 15.12.2016 so
that the elections may be concluded. On 20.12.2016, the High Court
took up the application and vacated the stay order to the extent that
the elections may proceed, but the result shall be subject to the final
outcome of the application.
9.
After the election process concluded, the matter was again taken up
with the passing of the impugned order. Vide the impugned order,
the High Court set aside the results of the elections of the appellant
federation on grounds of non-compliance with the sports code and
other regulations and also:
a)
appointed Dr. S.Y. Quraishi, Former Chief Election Commissioner
of India as the Administrator - cum - Returning Officer for the
conduct of elections of the AIFF,
b)
directed that the elections of the AIFF were to be held after the
preparation of an Electoral College, and
c)
directed that the elected body so constituted was to carry out
the requisite amendments to the AIFF Constitution to bring it
in conformity with the NSC 2011 as well.
10. The relevant directions contained in paragraph 22 of the impugned
judgment are extracted below:
"22. The Court is of the view that insofar as the Rules of
the AIFF are in breach of the National Sports Code and the
Model Guidelines for the conduct of elections, the results
of the elections of the AIFF declared on 21.12.2016 would
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have to be set aside. It is so ordered. Fresh elections shall
be conducted in accordance with the Model Guidelines.
Additionally, nominations would be required to be proposed
and seconded by one member association each and with
clear notice, as required by the Model Election Guidelines
read with rules of AIFF. Furthermore, the Electoral College
shall be first prepared after addressing the complaints of
various members who may have grievances in this regard.
This exercise should be carried out by a person who has
experience in sports affairs, public administration and
the conduct of elections. Accordingly, this Court directs
Mr. S.Y. Quraishi, former Chief Election Commissioner of
India, who has also served as Secretary in the Ministry
of Youth Affairs and Sports, Government of India, to be
appointed as the Administrator-cum-Returning Officer for
the conduct of the elections of the AIFF in the following
manner:
i.
To resolve the issue of disaffiliation of members/
units of AIFF as on 30th November, 2016 and to
prepare the Electoral List, within a month by giving
the concerned parties two weeks' notice;
ii.
Elections shall be held in six weeks after the
preparation of the Electoral college. This elected
body shall carry out the requisite amendments to
the AIFF Constitution to bring it in conformity with
the National Sports Code.
iii.
Once the AIFF Constitution has been amended, a
fresh round of elections shall be carried out in terms
of the National Sports Code, to ensure that age
and tenure restrictions along with the provision for
due representation of the sports-persons are strictly
complied with.
iv.
The AIFF shall make available to the Administrator an
appropriate office space and facilities for the discharge
of the aforesaid directions and make available such
staff and personnel as the Administrator may express
the need for. Alternatively, the Administrator may
appoint such personnel to assist him in the aforesaid
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All India Football Federation v. Rahul Mehra & Ors.
matter and expenses towards the same shall be
borne by the AIFF.
v.
Till the elections are conducted and results declared
in consonance of the National Sports Code and in
compliance with the preceding directions, the AIFF
shall not make any new financial commitments except
with the prior approval of the Administrator. Routine
expenses of AIFF too shall be defrayed, only with
the prior approval of the Administrator. The entire
exercise will be completed within five months from
the date the Administrator assumes charge;
vi.
However, to obviate any impediment in the conduct
of any competitive tournament that may have been
scheduled by the applicant, this order shall come
into effect after two weeks from today."
11. AIFF preferred the present appeals against the High Court's order.
On 10.11.2017, this Court stayed the operation of the impugned
order and, in particular, the directions given by the High Court in
paragraph 22. This Court further directed that Dr. S.Y. Quraishi and
Mr. Bhaskar Ganguly, former Indian captain and international football
player, would act as the Committee of Administrators ("CoA") for the
formulation of the Constitution of the Federation in consonance with
the NSC and Model Guidelines. The relevant paragraphs of the order
dated 10.11.2017 are extracted below:
"Considering the rival submissions, we are inclined to stay
the operation of the impugned judgment and, in particular,
the directions given by the High Court in paragraph 22
of the impugned judgment. We issue following interim
directions:-
(i)
Mr. S. Y. Qureshi, former Chief Election Commissioner
of India, who has also served as Secretary in the
Ministry of Youth Affairs & Sports, Government
of India and Mr. Bhaskar Ganguly, former Indian
Captain and International Football Player, 38, Nalta
Mahajoti Road, Kolkata-700028, are appointed as
the Committee of Administrators (Ombudsmen) for
formulation of Constitution of the Federation which
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will be in consonance with the National Sports Code
and the Model Guidelines for the conduct of its
business, constitution of the Executive Committee
and elections thereto whilst ensuring that the status
and membership of Petitioner Federation is not
undermined in any manner in the International Body.
They shall prepare the draft Constitution and submit
the same within eight weeks along with their report,
in a sealed cover before this Court.
(ii)
While formulating the proposed Constitution, the
Committee of Administrators (Ombudsmen) may take
into account the suggestions given by Respondent
No.1, if any.
(iii) After the report of the Committee of Administrators,
along with the proposed Constitution, becomes
available, further directions as may be necessary
can be issued.
We place on record the stand taken by the Petitioner
before us that the present elected body of the PetitionerFederation is committed to extend its full cooperation
to the Committee of Administrators for formulation of
the ·proposed Constitution of the Federation which will
be compliant in all respects and ensure transparency,
accountability and observance of democratic values in the
conduct of the business of the Federation.
As aforementioned, the directions issued in paragraph 22
of the impugned judgment shall remain in abeyance until
further orders, subject to the above directions."
12. The appeals again came up for hearing on 18.05.2022, wherein
the composition of the CoA was reconstituted, with the inclusion
of Mr. Justice Anil Dave, Former Judge, Supreme Court of India.
While re-constituting the CoA, the Court also noted the finalisation
of the report by the CoA after eliciting and receiving responses from
the relevant stakeholders. The Court further directed the counsel
appearing on behalf of CoA to collate the objections to render
facilitative assistance to this Court. The CoA was further requested
to assess the suggestions/objections of the stakeholders and provide
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All India Football Federation v. Rahul Mehra & Ors.
inputs on the proposed suggestions/objections. The relevant portion
of the order is as follows:
"4. The CoA, acting under the authority assigned to it by this
Court in terms of the above order has sought the permission
to place the Constitution for further consideration. The
request of the CoA is allowed.
5. The proposed Constitution of the All India Football
Federation which has been directed to be presented to
court in a sealed cover in the earlier interim order shall be
circulated to all the parties. Any objection or suggestion to
the Constitution, as proposed, shall be filed only before
this Court on or before 30 June 2022. Any party desirous
of obtaining a copy of the proposed Constitution would
be at liberty to email its request to Mr. Samar Bansal,
counsel appearing on behalf of CoA. Mr. Bansal will
circulate the proposed Constitution to the parties and to
any other constituent unit. Thereafter, all objections and
suggestions shall also be emailed to Mr. Bansal who
shall collate the objections for the purpose of rendering
facilitative assistance to this Court. Counsel is requested
to prepare a tabulated statement of:
(i) The Parties submitting suggestions/objections:
(ii) The nature of the suggestions/objections; and
(iii) The inputs of the CoA on the proposes suggestions/
objections
6. This exercise shall be carried out by the CoA on or
before 15 July 2022 and a tabulated statement shall be
placed on the record. The tabulated statement shall also
be circulated to all the parties so as to apprise them of
the position.
7. The elections of the Executive Committee which
were held on 21 December 2016 were set aside by the
judgment of the Division Bench of the High Court of Delhi
dated 31 October 2017. During the pendency of these
proceedings, by the interim order dated 10 November
2017, the operation of the judgment of the High Court
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was stayed, including the directions which were issued in
paragraph 22 of the judgment. The normal tenure of the
elected body would, in any event, have come to an end
on 20 December 2020. The consequence of the order of
stay is that despite the expiry of its four year term, the
Executive Committee has continued to govern the affairs
of the Federation. This state of affairs is not in the interest
of the proper governance of the Federation. Hence, the
two member CoA which was appointed by the order of this
Court dated 10 November 2017 with a specific mandate
to prepare the Constitution and hold elections to the
Executive Committee, is reconstituted to consist of the
following members:
(i) Mr Justice Anil R Dave, former Judge of the Supreme
Court;
(ii) Dr S Y Qureshi, former Chief Election Commissioner;
and
(iii) Mr Bhaskar Ganguly, former captain of the Indian
Football Team.
8.