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2025 Supreme(Ker) 3172

IN THE HIGH COURT OF KERALA AT ERNAKULAM
N. NAGARESH, J.
Rajeev P.J. S/o James P.L. – Appellant
Versus
The State of Kerala – Respondent
W.P. (C) No. 13077 of 2024
Decided On : 25-11-2025

Advocates Appeared:
For the Appellants : R. Lakshmi Narayan, R. Ranjanie, Meera M.
For the Respondents: S. Kannan, Latha Anand, S. Vishnu, Thomas Abraham, P. Mohandas, Dinesh R. Shenoy, K. Sudhinkumar, Sabu Pullan, Gokul D. Sudhakaran, R. Bhaskara Krishnan, Bharath Mohan, K.P. Satheesan, Merciamma Mathew, Aswin P. John, R. Ananthapadmanaban, Paul Baby

The Kerala State Sports Council lacks authority to dissolve or intervene in the internal affairs of recognized sports associations as per the Kerala Sports Act, 2000.

Headnote:(A) Kerala Sports Act, 2000 - Sections 31 and 31A - Writ petitions concerning governance and election of the Kerala Hockey Association - Petitioner challenged the legality of the existing governing body and demanded fresh elections - Kerala State Sports Council approved prior election; however, the Government ordered an enquiry and recommended dissolution of the body - Court found action of the Sports Council to approve the election unjustified, affirming that the Council does not possess power to dissolve or intervene in internal affairs of sports associations. (Paras 44, 46, 50)

(B) Governance of Sports Associations - The Kerala Sports Act delineates powers of the Sports Council and sets forth conditions for withdrawal of recognition of sports bodies. (Paras 36, 38)

(C) Legal Standing - Certain petitioners lacked the locus standi to challenge the Sports Council’s approval of elections for lack of membership in the organization. (Paras 5, 6)

Table of Content
1. petitioner alleges illegal governance of kerala hockey. (Para 2 , 3 , 4 , 5 , 6)
2. petitioners demand district and state championships amid governance disputes. (Para 7 , 8 , 9 , 10)
3. government's authority to intervene and investigate kerala hockey's governance questioned. (Para 24 , 34 , 35)
4. key provisions for sports organization governance under kerala sports act. (Para 36 , 39 , 42)

JUDGMENT :

N. NAGARESH, J.

1. All these writ petitions relate to same set of facts and are hence heard together and disposed of by a common judgment. The parties and exhibits are referred to in this judgment as they are described/marked in W.P.(C) No.13077/2024 unless otherwise specified, for convenience.

2. The petitioner in W.P.(C) No.13077/2024 is a former Player and Captain of the Kerala State Hockey Team. “Kerala Hockey” is a State Level Hockey Sports Association. According to the petitioner, the Kerala Hockey's Governing Body is functioning illegally and arbitrarily and the members thereof are not entitled to occupy their respective posts. Considering the complaints raised from various quarters, the Kerala State Sports Council constituted an Enquiry Committee.

3. The Sports Council accepted the enquiry report drafted by the Committee without conducting proper hearing. The petitioner urged that constitution of the Governing Body of the Kerala Hockey is not in terms of law. The petitioner therefore prayed that Ext.P5 proceedings dated 14.12.2023 be set aside to the extent it refrains from allowing the representations submitted by the petitioner. The petitioner further sought to direct the Sports Council to pass orders on Exts.P1 and P2 representations within a time frame. The petitioner also sought to direct the Sports Council to conduct a fresh election to the Governing Body of the Kerala Hockey.

4. The 3rd respondent-Hockey India filed counter affidavit. The 3rd respondent stated that “Hockey India” is a national sports federation recognised by the Central Government. The 4th respondent-”Kerala Hockey” is recognised by the 3rd respondent. Process of election of Kerala Hockey was carried out under the direction and concurrence of Hockey India. An Observer from the Kerala State Sports Council attended the election proceedings. The office bearers of the 4th respondent are competent to hold the posts. The petitioner is not entitled to any relief.

5. The 2nd respondent-Kerala State Sports Council also filed counter affidavit. The Sports Council, in its meeting held on 02.07.2024, approved the election held on 15.05.2022, to Kerala Hockey. The petitioner is essentially challenging the proceedings issued by the Kerala State Sports Council. The petitioner is not a member of the 4th respondent Association. Therefore, he has no locus standi to challenge the approval of the election to the 4th respondent Association. The petitioner has not challenged the election.

6. The 2nd respondent stated that there is another sports organisation named “Hockey Kerala” which had affiliation with Hockey India. It had recognition of the Sports Council also. Subsequently, the Hockey India revoked the affiliation of “Hockey Kerala”. The Sports Council has also withdrawn its recognition in the year 2014. The 4th respondent-Kerala Hockey is allowed to continue as a recognised sports organisation as per the provisions of the Kerala Sports Act, 2000.

7. W.P.(C) No.17066/2024 has been filed by three petitioners. The 1st petitioner is a 10th Standard student and a Hockey Player. The 2nd petitioner is a Hockey Player and has participated in the University, District and State Championships. The 3rd respondent is also a Hockey Player. The petitioners in W.P.(C) No.17066/2024 sought to command the Sports Council to conduct District and State Level Championships in the sports discipline Hockey in the State of Kerala till disputes between the Sports Council and Kerala Hockey are settled.

8. The petitioners in W.P.(C) No.17066/2024 contended that the Kerala Hockey has

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