Writ jurisdiction is generally not maintainable for disputes concerning internal governance and electoral processes of sports associations when the governing legislation provides a complete, efficacious adjudicatory mechanism, such as arbitration, for dispute resolution.

ORDER :

1. Instant D.B. Special Appeal (Writ) is preferred by the appellant, aggrieved from the order dated 13.03.2026 passed in Writ Petition No. 13261/2025 by the learned Single Judge of this Court, whereby the effect of the election held on 04.03.2026 was stayed and the Registrar, Cooperative Societies was directed to appoint an Administrator to look after the day-to-day functioning of the Association.

2. Learned Senior Advocate appearing on behalf of the appellant submits that Rajasthan Chess Association, (hereinafter referred as “the Association”), is a State-level sports body registered under the provisions of The Rajasthan Sports (Registration, Recognition and Regulation of Association) Act, 2005 (hereinafter referred to as “the Act of 2005”) and has conducted elections on 04.03.2026 wherein present appellant was elected as Honorary Secretary. He further submitted that the record of the proceedings has been placed on record to show that the election was conducted in a free and fair manner, in accordance with the provisions of the Act of 2005 and the Rules and Bye-laws made thereunder. He further submitted that Respondent No. 1, who was Honorary Secretary for term 2021-2025 was suspended by the erstwhile Association, filed a writ petition to stall the elections to be held after completion of his term. He also submitted that an interim stay was initially obtained to stall the elections, but after modification on 25.02.2026, a liberty was granted to conduct election.

3. Learned Senior Counsel also submitted that pursuant to said liberty, the General Body Meeting was convened and the election was conducted on 04.03.2026. He also submitted that after the election, the elected body has taken over the charge of the Association on 04.03.2026 itself. He further submitted that on 13.03.2026, the learned Single Judge has stayed the effect of the election held on 04.03.2026, and also appointed an Administrator, that too beyond the scope of the writ petition.

4. Learned Senior Advocate has further placed reliance upon judgment in the case of Ram Chandra Choudhary & Ors. Vs. Roop Nagar Dugdh Utpadak Sahakari Samiti Limited and Ors. 2026 INSC 347 and submitted that dispute relating to internal management, governance or electoral process of any society do not, as a matter of course, attract writ jurisdiction because such societies owe their incorporation to a statute. He further submitted that a specific mechanism is provided under the "Act of 2005" for governance of sports bodies and filing a writ petition in such a matter is contrary to provision of law. He further referred Section 16 of the Act of 2005 and submitted that any dispute relating to election of Association is required to be resolved through conciliation and arbitration and in such circumstances writ petition under Article 226 of the Constitution of India is not maintainable. He also submitted that the learned Single Judge has decided the writ petition by granting entire relief as interim measure to the petitioner; hence, the special appeal, as provided under Rule 134 of the RAJASTHAN HIGH COURT RULES , 1952, is filed and same is maintainable before this Hon’ble Court. He also submitted that the appellant was elected as Honorary Secretary and the elections have already come into effect as soon as the declaration was made and he has a right to defend a proceeding instituted by respondent No.1-writ petitioner.

5. Aforesaid contentions were opposed by the learned counsel appearing