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2026 Supreme(Online)(Del) 5143

Devendra Kumar Upadhyaya, CJ, Tejas Karia, J
President, Indian Olympic Association – Appellant
Versus
Ski And Snowboard India – Respondent
LPA 104/2026 | CM APPL. 14068/2026 | CM APPL. 14069/2026 | CM APPL. 14070/2026



Advocates:
For the Appellants/Petitioners: Mr. Gopal Jain, Ms. Aashita Khanna, Ms. Aanya Agarwal, Mr. Vidushpat Singhania
For the Respondents: Ms. Neha Singh, Mr. Udit Dedhiya, Ms. Apurva Sachdev, Mr. Preyansh Gupta, Mr. Amit Rana

An apex sports body cannot impose an ad hoc committee on an independent affiliate. Committee-formation powers in its rules apply only to its own committees. The National Sports Governance Act, 2025 applies only to recognized National Sports Bodies.

Headnote:(A) Karnataka Societies Registration Act, 1960 - Indian Olympic Association Rules and Regulations, Article 17.5 - National Sports Governance Act, 2025 - Sections 2(p), 3, 4, 16 - National Sports Governance (National Sports Bodies) Rules, 2026 - Rule 18 - The interpretation of Article 17.5 of the rules of the Indian Olympic Association cannot be construed to empower the President to appoint an ad hoc committee to manage the affairs of an independent affiliated body. The Act, 2025 and the Rules, 2026 apply only to bodies recognized as National Sports Bodies or National Sports Federations. (Paras 8, 9, 12)

Facts of the case:
The Indian Olympic Association (appellant) issued an office order appointing an ad hoc committee to manage the affairs of Ski and Snowboard India (respondent No.1), including selection and conduct of elections. The Single Judge quashed the order. The appellant appealed, arguing that Article 17.5 of its Rules allowed such appointment and that the Single Judge's direction to hold elections conflicted with the National Sports Governance Act, 2025 and Rules, 2026.

Findings of Court:
The court upheld the quashing of the office order but modified the direction on payment of returning officer's fees. The court held that Article 17.5 only permits formation of committees for the Indian Olympic Association itself, not for independent bodies. It observed that respondent No.1 is not a recognized National Sports Federation or Body under Act, 2025, so the Act does not apply. The court also found no legal basis for the appellant to impose an ad hoc committee on an independent society.

Issues: Whether Article 17.5 of the Indian Olympic Association's Rules empowers it to appoint an ad hoc committee for an affiliated independent body; whether the National Sports Governance Act, 2025 and Rules apply to respondent No.1; and whether the Single Judge's direction to the appellant to pay election costs was justified.

Ratio Decidendi: The power to form committees under Article 17.5 is limited to committees of the Indian Olympic Association itself. The Act, 2025 applies only to recognized National Sports Bodies, and since respondent No.1 is not recognized, the Act is inapplicable. An independent society's affairs are governed by its own memorandum, by-laws, and rules. The appellant has no authority to manage the affairs of an independent affiliate.

Result: Appeal disposed of with modification of the impugned order regarding payment of costs.

Table of Content
1. court considers the background of the appeal and the impugned order of the single judge (Para 1 , 2 , 3 , 4)
2. appellant argues article 17.5 permits ad hoc committee; court finds submission misconceived (Para 5 , 6 , 7)
3. article 17.5 applies to committees of ioa, not affiliate bodies; respondent not a recognized federation (Para 8 , 9 , 10)
4. act, 2025 does not apply to non-recognized bodies; respondent is independent society (Para 11 , 12 , 13 , 14 , 15)
5. ioa has no authority to appoint ad hoc committee for independent body (Para 16 , 17)
6. order modified: appellant not liable for election costs; appeal disposed (Para 18 , 19 , 20 , 21)

J U D G M E N T

DEVENDRA KUMAR UPADHYAYA, C.J.

1. Heard Shri Gopal Jain, learned senior counsel representing the appellants, Ms. Neha Singh, learned counsel appearing for respondent No.1 and Shri Udit Dehiya, learned special panel counsel representing the respondent No.2 and have perused the records available before us on this Letters Patent Appeal.

2. This Intra-Court appeal seeks to challenge the judgment and order dated 10.02.2023, passed by the learned Single Judge whereby the W.P.(C) No. 3418 of 2025 instituted by the respondent No.1 has been allowed, and the Office Order under challenge therein dated 13.10.2023 has been quashed.

At this juncture itself, we may state that the Office Order dated 13.10.2023, that was under challenge in the proceedings of the writ petition before the learned Single Judge, was passed by the appellant No.1 – President, Indian Olympic Association whereby an ad hoc Committee comprising of four members was appointed to manage the affairs of the respondent No.1 – Ski and Snowboard India, including selection of the athletes and making entries for participation of sportspersons in international events. The said ad hoc Committee was also mandated to conduct the elections of the executive committee of the respondent No.1.

3. The learned Single Judge, while allowing the writ petition by the impugned judgment and order has held that the respondent No. 1 is an

independent body registered as a society under the Karnataka Societies Registration Act, 1960, and that the appellant did not have any jurisdiction or authority or power to replace the executive committee of the respondent No.1 by appointing an ad hoc committee to manage its affairs.

4. By the impugned order, the learned Single Judge has also observed that as a result of quashing of the Office Order dated 13.10.2023, the ad hoc Committee stood dissolved with immediate effect. The learned Single Judge has also appointed a retired Judge of this Court as the Returning Officer to draw up the list of eligible members and thereafter conduct the election of the respondent No.1, with a further direction that the exercise relating to conducting the election shall be concluded expeditiously and in not later than a period of 12 weeks.

5. The impugned judgment and order passed by the learned Single Judge has been challenged by the appellants primarily on two counts – (a) Article 17.5 of the Rules and Regulations of the appellant permits appointment of an ad hoc Committee of the respondent No.1 and (b) the direction issued by the learned Single Judge for conducting the election of the respondent No.1 by the impugned order is contrary to the provisions contained in the National Sports Governance Act, 2025 (hereinafter referred to as ‘Act, 2025’) and the Rules made thereunder, namely National Sports Governance (National Sports Bodies) Rules, 2026 (hereinafter referred to as ‘Rules, 2026’).

6. It has been argued by learned senior counsel for the appellant that Article 17.5 of the Rules and Regulations of the appellant – Indian Olympic Association vests ample power with the appellant to appoint an ad hoc Committee for managing the affairs of any sports federation and further that

the ad hoc Committee was appointed by the Office Order dated 13.10.2023 having regard to certain differences within the respondent No.1 and on t

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