The main legal point established in the judgment is the requirement for procedural fairness and adherence to the constitution in decisions taken by sports governing bodies, and the court's authority to intervene when such principles are violated.

JUDGMENT :

1. Rule. Rule, made returnable forthwith.

2. By consent of the parties, taken up for hearing forthwith.

3. Petitioner is State Wrestling Association, a public Charitable Trust registered in the year 1953 under hte provisions of the Bombay Public Trusts Act, 1950 (‘the Act’ for short). Taluka and Zilla Wrestling Associations are the Unit Members of the petitioner-Trust. Petitioner-Trust is administered by General Council consisting of President, Executive President, Vice-Presidents, General Secretary, eight Regional Secretaries and 23 Governing Council Members.

4. On 28th February, 2020, Mr. Landge reporting Trustee/General Secretary, filed Change Report in Schedule-III in the office of the Deputy Charity Commissioner for recording names of elected Members of General Council and office bearers, for the period 2019-2023. The Change Report of petitioner-Trust, is pending for consideration.

5. The respondent no.2 is the Wrestling Federation of India (“WFI” for short). It is governing body of Wrestling in India having 28 affiliated Unit Members; including Maharashtra State Wrestling Association-petitioner herein.

Facts of the case, in brief are as under :

6. The Executive Committee of WFI in its meeting held on 30th June, 2022 dissolved three of its’ Unit Members; (i) Associations of Karnataka, (ii)Maharashtra; and (iii)Haryana; and appointed three Members Ad-Hoc Committee to conduct fresh election and run the day-to-day affairs of these Associations till the new Body enters the Office. Whereafter, Wrestling Federation of India’s, Joint Secretary was appointed as, the Chairman of the Ad-Hoc Committee of the petitioner Association.

7. Minutes of Meeting records the reasons, which forced WFI to dissolve petitioner-Association. It reads as under :

2. “Maharashtra : The President, WFI informed the Committee that the WFI has been receiving many complaint against Sh. B.S. Landge. The complaints were made by the local wrestles/officials of the Maharashtra State. Not only this, 30 District Wrestling Associations out of 45, have also made complaints against Sh. B.S. Landge. The President, WFI expressed great concerned about the activities of the Office Bearers of the Maharashtra Wrestling Association especially Sh. B.S. Landge as the Maharashtra is one of the biggest state of Wrestling. However, the Committee framed the following charges against the Office Bearers of the Maharashtra State Wrestling Association :

2. As the Maharashtra is the biggest wrestling State and the wrestlers of this State have brought many laurels for the country but due to mismanagement in the Association, the wrestlers are not getting any benefit in the State.

3. Sh. B.S. Landge has approached many times to the General Council of WFI to conduct the National Events in the State but he always backs out at the last minute. This was happened during the Under-23 National Championship held at Shirdi which was offered to Maharashtra but later they refused to hold this competition. Finally, the local sport lovers organized this event in Shirdi. Not only this, Sh. B.S. Landge requested to General Council to allot Under-15 National Championship for the year 2022 but at last moment they refused to hold they refused to hold this competition and later it was organized by Jharkhand State Wrestling Association. In view of the above, the Executive Committee of WFI unanimously dissolved the Maharashtra State Wrestling Association and authorised the President, WFI to form an Ad-Hoc Committee to conduct the fresh elections of the Maharashtra State and also to run the day-to-day affairs of the Association till the election is held so that the wrestlers of the State doesn’t suffer.”

8. Whereafter, on 4th July, 2022 WFI communicated, its decision to the Secretary of the petitioner-Association, stating that the Executive Committee of Wrestling Federation of “ India in its Meeting held on 30th June, 2022 at New Delhi, has unanimously dissolved the Maharashtra State Wrestling Association .