The Sports Council can inquire about election irregularities in sports associations but cannot dissolve them or interfere in their internal elections.

JUDGMENT :

Sathish Ninan, J.

1. The writ petitions from which these writ appeals arise, relate to the election held to the administration of “Kerala Hockey”, a Society registered under the Societies Registration Act.

2. The National Sports Code, 2011, provides for recognition of National Sports Federations. There will be only one such Federation in each sport, having the recognition of the Government of India. In the sport of Hockey, “Hockey India” is such Federation. State Associations from the various states in the country get affiliation from such Federation. Such State Associations can seek recognition from the State Sports Council. The National Federation recognises only such players send with the approval of the Sports Council. The State Association is comprised of nominees from the District Associations. “Hockey Kerala” is an association recognized by the Kerala Sports Council and affiliated to “Hockey India”.

3. Formerly there was a State Association named “Hockey Kerala”. It was recognized by the Sports Council and was affiliated to “Hockey India”. One Mr.V.SunilKumar was its President. In the year 2014 (with effect from 30.06.2014) its recognition was withdrawn by Hockey India and the Sports Council on allegations of misappropriation of funds. It is in the meanwhile that the present association, “Kerala Hockey”, came into existence somewhere in August, 2014.

4. In October 2016, the then President of “Kerala Hockey” resigned. On 02.10.2016 a General Body meeting of “Kerala Hockey” was held, in which substantial amendments are alleged to have been made to the bye-laws of the Association. There is an allegation that the General Body was not properly convened and that the amendments to the bye laws were effected without complying with the required mandates.

5. On 09.07.2017, there was a general body meeting of “Kerala Hockey”. In the said meeting, elections were held to its Committee. Therein, the earlier mentioned Sri.V.SunilKumar was elected as the President. There is an allegation that there was no valid meeting and no proper election.

6. On 15.05.2022, the next election to the Committee of “Kerala Hockey” was conducted and Sri.V.SunilKumar was elected as the President. There is allegation that the meeting was not properly held and that there was no proper election.

7. Raising complaints against the amendment to the bye-laws and election, there were complaints from hockey players of various districts. This Court as per judgment dated 04.07.2023 in Writ Petition(C) No.21601/2023 directed the Sports Council to look into the complaints.

8. In the meantime a suit was instituted as OS 120/2023 before the Munsiff's Court, Palakkad, challenging the amendment of the bye-law. The suit was subsequently withdrawn with leave to file a fresh suit, and OS 665/2025 has been filed before the same court, which is pending.

9. With respect to the conduct of election on 15.05.2022 and regarding the selection of players by the association, Writ Petition (C) Nos.31063/2022, 34913/2023, 37508/2023 and 37582/2023 were filed before this Court by interested persons. As per common judgment dated 16.11.2023, the writ petitions were disposed of. The directions in the judgment were essentially two fold – (a) granting liberty to the Sports Council to enquire into the elections, under the statutory scheme; and (b) the teams selected by the “Kerala Hockey” was allowed to participate in the National Championship.

10. Pursuant to the directions of this Court as above, the Sports Council constituted a three member enquiry commi