Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(Del) 6500

IN THE HIGH COURT OF DELHI AT NEW DELHI
Mini Pushkarna, J
Somdev Kishore Devvarman – Appellant
Versus
Union of India – Respondent
CONT.CAS(C) 1378/2025|W.P.(C) 13458/2024

Advocates:
For the Appellants/Petitioners: Varun Dewan, Himanshu Chaturvedi, Rahul Mehra, Trisha Chandran, Chaitanya Gosain, Tushar S, Hanif Chimthanawala
For the Respondents: Nidhi Raman, Jitendra Kumar Tripathi, Akash Mishra, Arunav Padhi, Ashish Prasad, P. Dhinoja, Atri Roy Chowdhury, Rajiv Dutta, Parth Goswami, Ranjeet Pawar, Pratyush Singh, Akshit Pradhan

Where new legislation dictates the governance of athletic associations, they must promptly realign their bylaws. Following internal divisions, judicial intervention through administrative oversight ensures continuity, democratic representation, and strict conformity with updated regulatory frameworks, preventing the stagnation of essential organizational affairs.

Headnote:(A) Sports Governance - Elections of sporting associations - Shift in legislative regime - Requirement to align constituent rules with new statutory mandates - Adoption of specific criteria for age, tenure, and executive composition - Duty of sports bodies to ensure democratic and representative frameworks.

(B) Administrative Law - Writ jurisdiction - Appointment of independent administrator for transitional management - Role of court in mediating internal power struggles - Interim arrangement for the management of affairs pending regulatory alignment - Judicial oversight of financial and procedural decision-making processes in athletic entities.

Facts of the case:
Disputes arose regarding the election process for a national sporting body, with allegations of non-compliance with existing governing norms. During the pendency of the litigation, new national legislation was enacted to regulate the governance of such bodies. The association exhibited significant internal factionalism, creating a deadlock in administrative functioning and the interpretation of its own governing rules.

Findings of Court:
The court determined that the tenure of the previous executive committee had lapsed and that the new governing legislation rendered prior academic challenges moot. It held that the association, as a public-facing entity, could not function under a divided executive. The court mandated the disclosure of frozen election results to provide an interim management bridge while directing an appointed administrator to lead the constitutional amendment process and conduct fresh elections in strict adherence to the new statutory regime.

Issues: The main issues were the validity of the existing executive committee's term, the impact of new governing legislation on pending litigation, and the necessity of judicial intervention in a factionally divided association to ensure administrative continuity and statutory compliance.

Ratio Decidendi: Following the introduction of comprehensive new governing legislation, administrative bodies are compelled to harmonize their internal rules with the supreme legal framework. In cases of internal paralysis, judicial intervention is justified to prevent administrative vacuum, safeguard the interests of participants, and facilitate a transparent transition to a reformed democratic governance structure.

Result: Elections declared as an interim measure, an administrator appointed for bye-law amendment and conduct of future elections, and the existing body directed to comply with updated statutory guidelines.

Table of Content
1. background of legal challenges and transition to new statutory regime. (Para 1 , 2 , 3 , 4 , 5)
2. compliance requirements under sports act 2025 and governance rules 2026. (Para 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20)
3. mandatory conformity to new laws and cessation of outdated tenures. (Para 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29)
4. internal factionalism impairs functional governance of sports bodies. (Para 30 , 31 , 32 , 33 , 34 , 35 , 36 , 37)
5. judicial appointment of administrator to ensure transition and compliance. (Para 38 , 39 , 40 , 41 , 42 , 43 , 44 , 45)

JUDGMENT

MINI PUSHKARNA, J.

1. The present writ petition has been filed challenging the elections of the respondent no. 2 – All India Tennis Association (“AITA”), which were scheduled to be held on 28th September, 2024. The petitioners alleged flagrant violations of the then existing National Sports Development Code of India, 2011 (“Sports Code, 2011”) and the judgment dated 16th August, 2022, passed by the Division Bench of this Court in W.P.(C) 195/2010.

2. The matter came to be listed for the first time on 24th September, 2024, wherein, it was directed that the election to the AITA shall remain subject to the outcome of the instant writ petition. Further, the election results were directed to be placed in a sealed cover, with further direction that the result of the election shall not be published. The relevant portion of order dated 24th September, 2024, is reproduced as under:

“xxx xxx xxx

7. The respondents are directed to file their respective counter affidavits before the next date of hearing.

8. In the meantime, the Election shall remain subject to the outcome of the instant writ petition. Let the result of the Election be placed in a sealed cover by the Election Officer, meaning thereby, the result of the Election shall not be published.

xxx xxx xxx”

(Emphasis Supplied)

3. During the pendency of the present petition, the Government vide its Notification dated 31st December, 2025, brought into force various provisions of the National Sports Governance Act, 2025 (“Sports Act, 2025”).

4. The following provisions of the Sports Act, 2025 have been brought into force vide said Notification dated 31st December, 2025, issued by the Central Government:

• Sections 1 to 3

• Sub-Sections (1), (2) and (4) of Section 4

• Sub-Sections (1) and (2) of Section 5

• Sub-Section (5) of Section 8

• Sub-Section (1) of Section 11

• Section 14

• Section 15

• Sub-Sections (1) to (7) and (10) of Section 17

• Section 30

• Section 31

• Sections 33 to 38

5. Further, the National Sports Board (Search-cum-Selection Committee) Rules, 2026 were notified on 08th January, 2026 and the National Sports Governance (National Sports Bodies) Rules, 2026 (“Sports Governance Rules, 2026”) were notified on 12th January, 2026.

6. In light of the latest enactment and Rules therein, i.e., Sports Act, 2025 and Sports Governance Rules, 2026, this Court takes into consideration the purport and intent of the aforesaid latest legislative mandate that governs National Sports Federations, such as AITA. Therefore, it would be appropriate to discuss certain provisions in relation to the Sports Act, 2025 and Sports Governance Rules, 2026, applicable for the adjudication of the present matter.

7. Section 4(2) of the Sports Act, 2025 details the qualifications of a person for contesting the election or seeking nomination to the Executive Committee of National Sports Bodies, which includes the National Sports Federation for each designated sport, like the AITA for Tennis, in the present case. Section 4(2) of the Sports Act, 2025, reads as under:

“xxx xxx xxx

(2) A person shall not be qualified to contest for election or seek nomination to, the Executive Committee, unless—

(a) such person is a citizen of India who has attained at least twenty-five years of age;

(b) the nomination of such person is duly proposed and seconded by a voting member of the General Body;

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2026 Supreme(Online)(Del) 6500

IN THE HIGH COURT OF DELHI AT NEW DELHIMini Pushkarna, JSomdev Kishore Devvarman – AppellantVersusUnion of India – RespondentCONT.CAS(C) 1378/2025|W.P.(C) 13458/2024

IN THE HIGH COURT OF DELHI AT NEW DELHI
Mini Pushkarna, J
Somdev Kishore Devvarman – Appellant
Versus
Union of India – Respondent
CONT.CAS(C) 1378/2025|W.P.(C) 13458/2024