1. Members of a society challenged resolutions removing elected office-bearers, the induction of new members, and the subsequent electoral process of the sports association under the societies registration law. (Para 2 , 3 , 5 )
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2026 Supreme(Online)(AP) 37932
HIGH COURT OF ANDHRA PRADESH
Lisa Gill, CJ, Challa Gunaranjan, J
Andhra Pradesh Football Association – Appellant
Versus
Union of India – Respondent
WRIT APPEAL Nos.64 & 65 OF 2025
Important Points
Writ jurisdiction is not the appropriate remedy for resolving complex factual disputes regarding the internal management, bye-law interpretations, and election processes of a registered society when a statutory remedy under the A.P. Societies Registration Act is available.
Subject
Civil - Societies/Associations
Act Referred
Headnote
(A) Writ Jurisdiction - Disputed Questions of Fact - When the validity of elections and voters lists depends on the interpretation of bye-laws and the validity of general body resolutions involving complex factual disputes, such issues cannot be adjudicated under Article 226 of the Constitution of India. (Para 22)
(B) Statutory Remedy - A.P. Societies Registration Act - Where an efficacious alternative remedy is available under Section 23 of the A.P. Societies Registration Act for disputes concerning the affairs of a registered society, the writ court may relegate the parties to such statutory remedy. (Para 6, 16, 23)
(C) Bye-laws - Amendment - Dispute over whether amendments to a society's bye-laws take effect from the date of the resolution or the date of approval by the Registrar is a matter of evidence and cannot be decided in a writ proceeding. (Para 15, 16)
Issues: Whether the writ petitions were maintainable given the existence of disputed questions of fact and an alternative statutory remedy under the A.P. Societies Registration Act.
(B) Statutory Remedy - A.P. Societies Registration Act - Where an efficacious alternative remedy is available under Section 23 of the A.P. Societies Registration Act for disputes concerning the affairs of a registered society, the writ court may relegate the parties to such statutory remedy. (Para 6, 16, 23)
(C) Bye-laws - Amendment - Dispute over whether amendments to a society's bye-laws take effect from the date of the resolution or the date of approval by the Registrar is a matter of evidence and cannot be decided in a writ proceeding. (Para 15, 16)
Issues: Whether the writ petitions were maintainable given the existence of disputed questions of fact and an alternative statutory remedy under the A.P. Societies Registration Act.
Legal Category Hierarchy
Advocates:
For the Appellants/Petitioners: Ghanta Rama Rao, Ghanta Sridhar
For the Respondents: O. Manohar Reddy, O. Ramesh, P. Durga Prasad, Harsha Vardhana Rao C, T. Niranjan, Malireddy Gowtham, G. Sai Narayana Rao, Moka Kondala Rao
For the Appellants/Petitioners: Ghanta Rama Rao, Ghanta Sridhar
For the Respondents: O. Manohar Reddy, O. Ramesh, P. Durga Prasad, Harsha Vardhana Rao C, T. Niranjan, Malireddy Gowtham, G. Sai Narayana Rao, Moka Kondala Rao
Table of Contents
Reserved for judgment on : 08.10.2026 Date of pronouncement : 16-10-2026 Date of uploading : 16.10.2026 Whether only operative part of the judgment is pronounced or whether full judgment is pronounced : FULL.[3584]APHC010013692025
COMMON JUDGMENT: (per Hon’ble Sri Justice Challa Gunaranjan)
These two writ appeals preferred under Clause 15 of Letters Patent assailing common order, dated 30.08.2024, in W.P.Nos.8158 and 10297 of 2023, besides other two writ petitions, since intrinsically connected, are taken up for consideration and disposed by this common judgment.
2. Appellants are unsuccessful writ petitioners. They were elected office bearers of Andhra Pradesh Football Association (hereafter referred to as “APFA”). Since there were certain rival claims with regard to induction of new members, granting affiliation, and rearrangement of office-bearers for the purpose of managing APFA, initially they preferred W.P.No.13152 of 2022, challenging resolution, dated 11.04.2022, whereby certain decisions were taken in general body meeting which, according to the petitioners, was convened by persons who were not members or strangers to APFA. The decisions regarding removal of the then existing President, appointment of ad-hoc President, granting affiliation to newly formed District Football Associations, through whom the ad-hoc President was inducted, and further proposing to hold elections were challenged on the ground that the very conducting of the general body meeting was not in accordance with the bye-laws, and that bye-laws do not empower removal of an elected President in the manner it was executed, besides the same being in violation of principles of natural justice. Appellants claim that as they were elected on 22.05.2019, they had a tenure of four years, which was to expire on 21.05.2023, thus, an elected body could not have been dethroned in violation of bye-laws and provisions of the A.P. Societies Registration Act .
3. The learned Single Judge initially passed interim directions on 02.05.2022, staying the decision of proposing to hold elections. However, later, considering gamut of entire matter, vide order dated 14.02.2023, elections were directed to be conducted under the supervision of a retired Judge of this Court, with the assistance of observers from All India Football Federation (AIFF). In the process, it was also directed to undertake the exercise of issuing final voters list after considering objections from all stakeholders. Even before aforesaid direction came to be issued, it is stated that 8 newly formed District Football Associations were granted affiliation on 03.05.2022, which were communicated under the signature of M. Srinivasa Rao as President of APFA upon collecting admission fee of ₹100/-. The same prompted appellants to file W.P.No.8158 of 2023 to declare the action of respondents therein in attempting to include names of outsiders, who are not members of APFA, as voters, as arbitrary, illegal, and contrary to the bye-laws.
4. The contesting respondents filed detailed counter-affidavits refuting the challenge laid in aforesaid writ petitions. It was pleaded that general body meeting, held on 11.04.2022, followed by resolutions and decisions taken thereon, was validly done strictly in accordance with provisions of bye-laws and the A.P. Societies Registration Act . Further, learned Court Supervisor published final voters list only after calling for objections on tentative list published, which was done in a fair and transparent manner, therefore, the final voters list cannot be faulted with. It was also pleaded that the issues raised in the writ petitions are not amenable for adjudication under Article 226 of the Constitution of India when there is an efficacious remedy provided under Section 23 of the A.P. Societies Registration Act .
5. Learned Court Supervisor, in pursuance to directions issued by Writ Court, issued notice, dated 23.03.2023, calling for objections from APFA, concerned District Footb
