SupremeToday Landscape Ad
Back
Next
Judicial Analysis Court Copy Headnote Facts Arguments Court observation
Listen Audio Icon Pause Audio Icon
judgment-img

2026 Supreme(Online)(Del) 6551

IN THE HIGH COURT OF DELHI AT NEW DELHI
Devendra Kumar Upadhyaya, CJ, Tejas Karia, J
All India Football Federation – Appellant
Versus
Churchill Brothers Sports Club Pvt. Ltd. – Respondent
LPA 321/2026 | LPA 322/2026



Advocates:
For the Appellants/Petitioners: Tanmaya Mehta, Aashita Khanna, Neil M Goswami, Vidushpat Singhania, Ritwik Prakash, Aanya Agarwal
For the Respondents: Ravi Prakash, Niharika Tiwari, Ranjeet Pawar

Registered societies maintain autonomy under their own constitutions. Judicial interference via writ jurisdiction requires strong, compelling reasons or proven mala fides. Courts should not assume or replace internal administrative functions or committees of such bodies in the absence of established illegality or demonstrated bias.

Headnote:(A) Societies Registration Act, 1860 - Autonomy of registered societies - The court held that registered societies are autonomous bodies governed by their constitutional documents, bye-laws, and regulations. Judicial interference in the functioning of such societies is impermissible unless there exist strong, cogent reasons or specific, proven allegations of malice or mala fide. (Paras 33, 40, 42).

(B) Writ Jurisdiction - Article 226 of the Constitution of India - Courts should not assume functions designated to the internal bodies of an autonomous society. The power under Article 226 is not to be exercised to substitute the members of an internal committee with court-nominated members absent clear findings of legal perversity or bias. (Paras 41, 49).

Facts of the case:
An appeal was brought against an order of a single bench that had directed the reconstitution of a dispute resolution committee for an autonomous sports federation. The primary grievance of the complainant had already been addressed by the federation, which had replaced the objected member with a former judicial officer. The federation argued that the court-ordered substitution undermined its organizational autonomy and contravened its internal governing rules.

Findings of Court:
The court observed that the federation is an autonomous society and that no finding of malice or mala fide was recorded by the single bench to justify the substitution of the committee members. It was noted that legitimate mechanisms for internal appeal were already in place, presided over by senior former judicial officers, which ensured impartial grievance redressal.

Issues: Whether a court, while exercising writ jurisdiction, is empowered to reconstitute the internal committees of an autonomous society despite the absence of proven malice or failure of the society's internal governance mechanisms.

Ratio Decidendi: An autonomous society possesses the right to govern its affairs through its internal constitution. Judicial intervention in the formation of internal committees is unwarranted unless there are compelling, cogent reasons or verified instances of malice. Courts cannot substitute their discretion for the internal processes established by a society's governing rules.

Result: Appeals allowed; order for reconstitution set aside.

Table of Content
1. consolidated hearing of appeals arising from a common judgment. (Para 1 , 2)
2. procedural history of dispute concerning internal ethics committee constitution. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9)
3. autonomous management of professional sports federation affairs. (Para 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19)
4. conflict between judicial oversight and organizational autonomy. (Para 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29)
5. registered societies maintain autonomy without state interference. (Para 32 , 33 , 34 , 35 , 36 , 37 , 38 , 39 , 40 , 41)
6. judicial interference invalid without strong, compelling justification. (Para 42 , 43 , 44 , 45 , 46 , 47 , 48 , 49)
7. final order granting appeal and setting aside impugned judgment. (Para 50 , 51 , 52 , 53)

CORAM:

HON'BLE THE CHIEF JUSTICE

HON'BLE MR. JUSTICE TEJAS KARIA

DEVENDRA KUMAR UPADHYAYA, CJ. (ORAL)

1. Heard the learned counsel for the appellant, Sh. Tanmaya Mehta and Sh. Ravi Prakash, learned senior counsel representing the respondent no.1 and perused the record available before us on these appeals.

2. Since both the appeals arise out of the same judgment and order dated 01.04.2026 passed by learned Single Judge in W.P.(C) 3981/2026 and W.P.(C) 4064/2026, both have been heard together and are being decided by the common judgment which follows:

3. Before adverting to the respective submissions made by learned counsel representing the parties, we may note certain facts which are essential for proper adjudication of the controversy involved in these appeals.

4. The respondent no.1 instituted W.P.(C) 3981/2026 with the prayer to set aside the proceedings in respect of representation dated 14.03.2026 and to constitute an independent, neutral and impartial committee, preferably under the supervision of a retired Judge of the High Court, to examine and adjudicate the representation dated 14.03.2026 preferred by the respondent no.1. Another prayer made in the writ petition was that a direction be issued to the respondent no.2 in the Writ Petition that he shall not, directly or indirectly, participate in or influence any proceedings, decisions or processes relating to the representation preferred by the respondent no.1 or any subject matter connected with the same.

5. W.P.(C) 4064/2026 was instituted by the respondent no.1 with the prayer for setting aside the proceedings in respect of the representation dated 16.01.2026 with a further prayer to constitute an independent, neutral and impartial committee, preferably under the supervision of retired Judge of a High Court, to adjudicate the representation dated 16.01.2026 preferred by the respondent no.1 and counter complaint filed by Inter Kashi FC.

6. Prior to instituting the aforesaid two writ petitions, the respondent no.1 had filed a W.P.(C) 14408/2025, which was disposed of by learned Single Judge vide order dated 08.01.2026, whereby it was provided that the respondent no.1 shall submit their comprehensive representations enclosing all the documents, including earlier complaints, and on receipt of such representations, the appellant will deal with the same after affording opportunity of hearing to the parties. The Court also directed the respondent no.1 to pass a speaking order dealing with the grievances raised by the parties. The learned Single Judge in his order dated 08.01.2026 further observed that it will be open to the appellant to determine as to how the complaints/representations will be decided.

7. It appears that in compliance of the order dated 08.01.2026 passed by learned Single Judge in W.P.(C) 14408/2025, the complaints/representations were not decided by the appellant, which led to filing of CONT.CAS.(C) 357/2026. In the said contempt case, notices were ordered to be issued, whereupon the Ethics and Dispute Resolution Committee (Ethics Committee) was constituted by the appellant. The respondent no.1 appears to have raised certain grievances against some of the members of the Ethics Committee

Click Here to Read the rest of this document
1
2
3
4
5
6
7
8
9
10
11
SupremeToday Portrait Ad
supreme today icon
logo-black

An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers

Please visit our Training & Support
Center or Contact Us for assistance

qr

Scan Me!

India’s Legal research and Law Firm App, Download now!

For Daily Legal Updates, Join us on :

whatsapp-icon Back to top