The governance framework for sports in India has started to move beyond the playing field into constitutional and regulatory discourse. Courts in India are being called upon to examine the functioning of sports federations on issues relating to elections, disciplinary proceedings, athlete rights, transparency standards, and conflicts of interest. Many of these disputes involve a common tension between two competing considerations. On one side is the need for accountability and fair governance, and on the other is the principle that sporting bodies are autonomous associations governed by their own constitutions, regulations and internal mechanisms.
The issue becomes more complex where federations are affiliated with international governing institutions such as FIFA and the Olympics, both of which place considerable emphasis on institutional independence. Indian sports federations operate within a regulatory framework that includes recognition by the Ministry of Youth Affairs and Sports and compliance obligations under sports governance policies. However, despite this regulatory environment, such bodies continue to function as autonomous associations registered under the Societies Registration Act, 1860.
The Delhi High Court’s decision in All India Football Federation vs Churchill Brothers Sports Club Pvt. Ltd. examines this crossroads between institutional autonomy and judicial oversight. The dispute arose from objections raised against the composition of the Ethics and Dispute Resolution Committee constituted by the All-India Football Federation (AIFF). The matter eventually led to judicial directions restructuring the committee itself, raising an important constitutional question concerning the permissible scope of court intervention under Article 226 of the Constitution.
The Division Bench was required to determine whether a constitutional court could substitute members of an adjudicatory body constituted under the federation’s own constitutional framework, particularly where allegations of mala fide conduct or actual bias had not been established. In answering this issue, the Court held that while writ courts possess broad powers of judicial review, those powers cannot ordinarily extend to assuming governance functions that the association itself is authorised to perform under its constitution and rules.
Background of the Dispute
The dispute originated from complaints and representations filed by Churchill Brothers Sports Club Pvt. Ltd. before the AIFF. The club approached the Delhi High Court through two writ petitions seeking the constitution of an independent and impartial committee, preferably under the supervision of a retired High Court judge, to examine and adjudicate its representations. It also sought directions restraining certain office bearers from influencing the adjudicatory process.
Prior to these petitions, Churchill Brothers had already approached the Court in W.P.(C) 14408/2025. In those proceedings, the learned Single Judge directed the AIFF to consider the representations after granting an opportunity of hearing and to pass a reasoned speaking order. The Court had also clarified that the federation would be free to determine the manner in which the complaints and representations would be decided.
Subsequently, contempt proceedings were initiated alleging non-compliance with the earlier directions. During this stage, the AIFF constituted an Ethics and Dispute Resolution Committee to adjudicate the complaints. Churchill Brothers, however, raised objections regarding certain members of the committee on grounds of alleged conflict of interest and apprehension of bias.
In response to these objections, the AIFF altered the composition of the committee. The member against whom objections had been raised was replaced by a former judge of the Punjab and Haryana High Court. Other changes were also made after recusals and non-consent by certain members.
Despite these modifications, the learned Single Judge proceeded to reconstitute the Ethics Committee through judicial directions. The impugned order appointed the Chairperson, along with other members identified through the Court’s directions. The AIFF challenged this order before the Division Bench.
Structure of the AIFF’s Internal Governance Framework
The Court examined the constitutional structure governing the AIFF and its judicial bodies in detail. The federation was recognised as the sole National Sports Federation for football in India and was affiliated with FIFA, the Asian Football Confederation and the Indian Olympic Association. The AIFF was registered as a society under the Societies Registration Act, 1860 and functioned through its Memorandum of Association, constitution, bye-laws, rules and regulations.
Article 45 of the federation’s constitution provided for various judicial bodies, including the Ethics Committee and Appeal Committee. The constitution further prescribed that the Chairperson, Deputy Chairperson and other members of judicial bodies would hold office for a fixed term and that appointments and removals would be governed through decisions of the general body.
The Court also noted that the federation had already replaced the originally contested Chairperson and that the reconstituted Ethics Committee consisted of retired judicial officers and advocates. An appellate mechanism was also available under the AIFF constitution. The Appeal Committee was chaired by a former judge of the Supreme Court and included retired judges and advocates as members.
Arguments Before the Court
The appellants argued that the principal objection raised by the defendants had originally been directed only against one member of the Ethics Committee, who had already been replaced by a retired High Court judge. According to the appellants, once this replacement was made, the alleged apprehension of bias no longer survived.
The appellants further argued that it was an autonomous body governed by its own constitution and regulations. The Ethics Committee had been constituted in accordance with its constitutional framework, and therefore, judicial substitution of members amounted to direct interference in internal governance.
Another important submission by the appellants was that the Single Judge had observed that there was no assumption of mala fide conduct or malice on the part of the federation. In the absence of findings relating to bad faith or bias, there was no legal basis for restructuring the committee.
Contrarily, the defendants defended the impugned order, arguing that no prejudice would result if an independent committee adjudicated the dispute. The defendants contended that concerns existed regarding the role and influence of the federation’s President in the constitution of the Ethics Committee, and therefore, judicial intervention was necessary to ensure neutrality and public confidence in the process.
Court’s Findings on Autonomy of Registered Societies
A substantial section of the judgment dealt with the legal position of societies registered under the Societies Registration Act, 1860. The Division Bench observed that the right to form associations is protected under Article 19(1)(c) of the Constitution and that registered societies function through their own constitutions, bye-laws and regulations.
The Court examined the scheme of the Societies Registration Act and observed that the legislation primarily facilitates registration and legal recognition of societies. Except for limited statutory compliance, the Act does not create a broad supervisory framework that permits governmental authorities to interfere with the functioning of such associations.
The Court further observed that the rules and regulations framed by a society operate essentially as a contractual arrangement among its members. The mere fact that those rules are registered under the statute does not transform them into statutory provisions.
On this basis, the Court held that associations registered under the Societies Registration Act enjoy substantial autonomy in relation to their internal affairs and governance structures. According to the Court, judicial interference in such matters must therefore remain limited and justified only in exceptional circumstances.
On the Scope of Judicial Intervention Under Article 226
The Court clarified that while Article 226 grants wide powers to constitutional courts, those powers do not ordinarily permit courts to assume functions that an association itself is authorised to perform under its constitution and rules. At the same time, the Bench recognised that situations may arise where judicial intervention becomes necessary. The Court observed that directions affecting the internal governance structure of an autonomous body may still be issued where compelling circumstances exist. However, such intervention would require “very strong and cogent reasons”. This distinction formed the foundation of the Court’s reasoning.
According to the Division Bench, the facts of the present case did not disclose circumstances warranting such extraordinary intervention. The original objection had already been addressed through the replacement of the contested Chairperson. The Court also placed reliance on the existence of an appellate mechanism headed by retired judges. In its view, the structure of the federation’s adjudicatory framework itself provided sufficient safeguards against unfairness or improper influence.
The Bench further observed that the learned Single Judge had recorded absence of mala fide conduct or malice. In such circumstances, replacing the federation’s adjudicatory body through judicial directions was held to be unjustified. The Court therefore set aside the impugned order and directed that the complaints and representations be adjudicated by the Ethics Committee constituted by the AIFF in accordance with its rules and regulations.
Conclusion
The Delhi High Court’s decision draws attention to an issue that extends beyond football administration or sports governance. The judgment addresses the constitutional principle concerning the relationship between judicial review and institutional autonomy. While courts retain the authority to examine procedural fairness, legality, and abuse of power, the decision makes it clear that constitutional courts cannot ordinarily step into the role of governing bodies and redesign their internal structures merely because one party has expressed apprehensions. Intervention of that nature requires demonstrable illegality, established bias or compelling circumstances supported by the record. The ruling is a landmark decision for future disputes involving sports federations, professional associations and other autonomous societies that function through internal constitutions and adjudicatory mechanisms.
Authors – Manisha Singh (Partner) and Shivi Gupta (Associate Partner)