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2026 Supreme(Online)(Del) 1060

IN THE HIGH COURT OF DELHI AT NEW DELHI
Tejas Karia, J
Union of India – Appellant
Versus
Taekwondo Federation of India – Respondent
LPA 5/2026 | LPA 776/2025



Advocates:
For the Appellants/Petitioners: Chetan Sharma, Udit Dedhiya, Apurva Sachdeva, Preyansh Gupta, Amit Gupta, Shubham Sharma, Vikram Aditya, Yashwardhan, Nishit Kush, Sidharth Sikri, Jaya Kumar Nair
For the Respondents: Rahul Mehra, Saurabh Jain, Chatanya Gosain, Prayag Jain, Aashita Khanna, Neil Goswami, V. Singh, JP Sengh, Tarkeshwar Yadav, Ayush Gandhi, Firoz Ahmed

An administrative body cannot automatically withdraw or de-recognize a National Sports Federation for non-compliance or failure to renew without adhering to the principles of natural justice and following the mandatory show cause procedures prescribed under the National Sports Development Code, 2011.

Headnote:The controversy concerns the recognition of a National Sports Federation (NSF) under the National Sports Development Code, 2011. The appellant revoked recognition of the first respondent due to its failure to obtain affiliation from the international governing body and subsequently recognized the second respondent. The court examined whether withdrawal of recognition could be automatic upon non-renewal. Following the Sports Code, the court addressed the issue: whether an NSF can be de-recognized without a formal opportunity for hearing. The ratio decidendi holds that the principles of natural justice, as enshrined in the Sports Code, mandate that withdrawal of recognition cannot be automatic and necessitates a positive act following a show cause notice and an opportunity for the affected entity to defend itself. The court directed the appellant to initiate a show cause process for withdrawal of the first respondent's recognition, allowed for participation by all stakeholders, and ordered that neither party shall act as the NSF until a fresh reasoned order is passed, modifying the single judge's directions accordingly.

Table of Content
1. summary of facts regarding non-renewal of nsf status. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14)
2. procedural fairness requires notice before de-recognition. (Para 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27)
3. directions for reasoned decision-making process. (Para 28 , 29 , 30 , 31 , 32 , 33 , 34)

O R D E R

CM APPL. 360/2026 and CM APPL. 361/2026 in LPA 5/2026

CM APPL. 80402/2025 & CM APPL. 80403/2025 in LPA 776/2025

1. Allowed, subject to all just exceptions.

2. The Applications stand disposed of.

LPA 5/2026 and CM APPL. 359/2026

3. The present Appeal challenges the judgment dated 18.11.2025 (“Impugned Judgment”) passed by learned Single Judge in WP(C) 7029/2025 (“Writ Petition”), whereby the letter dated 08.05.2025 issued by the Appellant recognizing Respondent No. 2 as the National Sports Federation (“NSF”) for the sport of Taekwondo has been set aside.

4. Mr. Chetan Sharma, learned ASG for the Appellant submitted that the Impugned Judgment is in the teeth of the provisions of the National Sports Development Code, 2011 (“Sports Code”) as it directs the Appellant to reconsider the recognition of Respondent No. 2 as NSF for the sport of Taekwondo after according an opportunity of hearing to all stakeholders including Respondent No. 1 and Respondent No. 2. Further, the direction that Respondent No. 1 shall continue to act as the NSF till such time the decision is taken by the Appellant is contrary to the provisions of the Sports Code and will also adversely impact the prospects of the Indian Athletes to take part in prestigious future International Events including the forthcoming Asian Games, 2026 to be held in Japan.

5. The learned ASG relied upon Paragraph Nos. 8.1 to 8.3 of the Sports Code, which provides as under:

“8.1 The purpose of this is to ensure that NSFs maintain certain basic standards, norms and procedures with regard to their internal functioning, which conform to the high principles and objectives laid down by the concerned International Federation, and which are also in complete consonance with the principles laid down in the Olympic Charter or in the constitution of the Indian Olympic Association while being compliant with Government guidelines applicable to NSFs.

8.2 From the year December, 2009, a new system of annual recognition was notified under which NSFs are required to submit detailed documentation for grant of recognition, which would get automatically renewed in the subsequent years subject to submission of prescribed documents such as annual report, audited accounts, details of national championships held, utilization certificate in respect of Government grants. Copies of relevant circulars issued vide No.F.9- 69/2009-SP-I dated 12.11.2009, 02.12.2009 & 29.11.2010 are placed at Annexure-XV. Federations not availing of grants from the Government will receive permanent recognition instead of annual recognition.

8.3 NSFs seeking recognition will have to apply as per Guidelines given at Annexure-II. While considering the proposals for recognition, the Ministry, inter alia, will be guided by the following:

i. The current legal status of the Organization

ii. Recognition by the International Federation and the Asian Federation.

iii. Recognition by the IOA in respect of Olympic Sports

iv. Undisputed status as an Apex Body in India

v. All India spread.

vi. The role and contribution of the organization in promoting and developing Sports in India.

vii. Conduct of national championships across age groups and gender

viii. Financial and managerial accountability.

ix. Fair, transparent and democratic elections.

x. Compliance with age and tenure limit guidelines.

xi. Protection and promotion of players’ interests and welfare.”

6. The learned ASG also relied upon the letter dated 17.03.2023 recognizing Respondent No. 1 as NSF for the sport of Taekwondo. He further emphasized on Paragraph Nos. 4 and 5 of the said letter, which state as under:

“4. Further, in view of

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