NITHIN THIMMAIAH vs HOCKEY KARNATAKA
- Court
- Karnataka High Court
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®
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
TH
DATED THIS THE 8 DAY OF JULY, 2026
BEFORE
THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ
WRIT PETITION NO. 20256 OF 2026 (GM-RES)
BETWEEN:
1. NITHIN THIMMAIAH
AGED ABOUT 38 YEARS,
S/O M.N. PEMMAIAH,
ND
VIJAYANAGAR 2 STAGE,
VIRAJPET TOWN, VIRAJPET, KODAGU,
KARNATAKA - 571218.
2. AIYAPPA M B,
AGED ABOUT 37 YEARS
S/O M N BIDADAPPA
NALVATHOKULE VILLAGE AND POST
VIRAJPET TALUK
KODAGU, KARNATAKA-571236
3. MOHAMMED NAEEMUDDIN
AGED ABOUT 36 YEARS,
C/O MD. NASEERUDDIN
NO. 24, GROUND FLOOR,
ND
2 CROSS, DHANANJAYA LAYOUT,
KITHAGANUR, KRISHNARAJAPURAM,
BENGALURU NORTH,
BENGALURU, KARNATAKA 560036.
4. BOPAIAH K.J.
AGED ABOUT 37 YEARS,
S/O K.B. JOYAPPA,
ND
NO. 14, CAUVERY COLONY, 2 CROSS,
SRINIVAGILU EXTENSION,
VIVEKNAGAR, BANGALORE SOUTH,
BENGALURU, KARNATAKA 560047.
5. CHANGAPPA P.S.
AGED ABOUT 35 YEARS
C/O SHAMBU P.K.
Digitally signed
by SHWETHA
RAGHAVENDRA
Location: HIGH
COURT OF
KARNATAKA
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PONNAMPET TALUK,
NALKERI VILLAGE, VIRAJPET TALUK,
KODAGU DISTRICT, KARNATAKA – 571217
6. APPACHU S K,
AGED ABOUT 37 YEARS,
S/O LATE KAVERIAPPA,
HATHUR HOBALI, VIRAJAPET TALUK,
K BYGODU, KODAGU,
KARNATAKA 571213
7. PRADEEP MARIA PRAKASH G.
AGED ABOUT 37 YEARS
S/O J. GNANA PRAGASM,
ST
NO. 87, MARIA NILAYA, 1 A CROSS,
NEAR JACK AND JILL SCHOOL,
GANGAPPA LAYOUT, SHAKTHI NAGAR,
DOORAVANI NAGAR, BENGALURU,
KARNATAKA 560016.
…PETITIONERS
(BY SRI. SOMANNA K P., ADVOCATE)
AND:
1. HOCKEY KARNATAKA
REPRESENTED BY ITS SECRETARY GENERAL,
FIELD MARSHAL K.M. CARIAPPA HOCKEY ARENA,
SHANTHI NAGAR, BENGALURU.
2. KARNATAKA OLYMPICS ASSOCIATION,
REPRESENTED BY ITS SECRETARY GENERAL,
KANTEERAVA STADIUM, SPORTS COMPLEX,
KASTURBA RD, NUNEGUNDLAPALLI,
AMBEDKAR VEEDHI, BENGALURU,
KARNATAKA 560001
3. HOCKEY INDIA,
REPRESENTED BY ITS SECRETARY GENERAL,
B1/E14, MOHAN CO-OP, INDUSTRIAL ESTATE,
MATHURA ROAD, NEW DELHI-110003
…RESPONDENTS
(BY SRI. D.R. RAVISHANKAR., SR. COUNSEL FOR
SRI. DARSHAN.R., ADVOCATE FOR R1;
SRI. UDITH DEDHIYA &
SRI. ADOORYA HARISH., ADVOCATES FOR R3)
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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227
OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE AN
APPROPRIATE WRIT, ORDER OR DIRECTION IN THE NATURE OF
CERTIORARI QUASHING THE IMPUGNED LETTER DATED 18.06.2026
VIDE ANNEXURE-A ISSUED BY THE 1ST RESPONDENT ONLY ON SO
FAR AS THE PETITIONERS ARE CONCERNED AND ETC.
THIS WRIT PETITION, COMING ON FOR PRELIMINARY
HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ
ORAL ORDER
1. The petitioners are before this Court seeking for the
following reliefs:
i. An appropriate writ, order or direction in the
nature of certiorari quashing the impugned Letter
dated 18.06.2026 vide ANNEXURE-A Issued by
the 1st Respondent only on so far as the
petitioners are concerned.
ii. An appropriate writ, order or direction in the
nature of Mandamus directing the Respondent
No.1 to permit the Petitioners to participate in the
10th Hockey Karnataka League Championship
2026 and all consequential selection processes,
by treating the Petitioners as eligible to
participate, notwithstanding the letter dated
18.06.2026, vide ANNEXURE-A and pass such
other or further orders as this Hon'ble Court
deems fit in the facts and circumstances of the
case, in the interest of justice and equity.
iii. Such other writ or order or direction as this
Hon'ble Court may deem fit in the facts and
circumstances of the case, including the cost of
this writ petition in the interest of justice.
2. The petitioners are permanent employees of the
Accounts and Audit General Office (AGORC),
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Bengaluru, and are accomplished hockey players who
have represented the organisation in various Inter-
Departmental, State and National-level tournaments.
Petitioners Nos.1 and 2 are stated to have
represented India in several international hockey
tournaments, while Petitioners Nos.3 to 7 have
represented the State of Karnataka in numerous
State and National-level hockey tournaments.
The petitioners are aggrieved by the communication
dated 18.06.2026 issued by the Secretary General,
Hockey Karnataka, addressed to the Sports Welfare
Officer, AGORC, Bengaluru, insofar as it states that
the petitioners are ineligible to participate in the
League Championship proposed to be organised by
Hockey Karnataka.
3. The communication dated 18.06.2026 is, in
substance, an invitation extended by the Secretary
General, Hockey Karnataka, to the Sports Welfare
Officer, AGORC, inviting the AGORC team to
participate in the League Championship scheduled to
be held at the Field Marshal K.M. Cariappa Hockey
Arena, Shanthi Nagar, Bengaluru, from 06.07.2026
to 05.08.2026. The communication further indicates
that the championship is intended to facilitate the
selection of players for the forthcoming 97th All India
MCC–Murugappa Gold Cup Hockey Tournament,
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2026. However, while extending the invitation,
Hockey Karnataka has specifically intimated that the
petitioners are not eligible to participate in the said
League Championship.
4. It is in the above factual backdrop, and being
aggrieved by the declaration of their ineligibility
contained in the communication dated 18.06.2026,
that the petitioners have approached this Court
seeking the reliefs prayed for in the present writ
petition.
5. The submission of Sri.Somanna.K.P., learned counsel
for the petitioners is that;
5.1. Learned counsel for the petitioners submits that
the sole basis for declaring the petitioners
ineligible, as reflected in the communication
dated 18.06.2026, is the allegation that they
had participated in an "unsanctioned
tournament" organised by the Karnataka State
Hockey Association ("KSHA"), which, according
to Hockey Karnataka, is an unrecognised body
in the State of Karnataka.
5.2. Learned counsel places reliance upon the
Hockey India Regulations Relating to
Sanctioned and Unsanctioned Events, published
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in August 2019, particularly Clause B (1.1)
thereof, which deals with participation in
sanctioned and unsanctioned events, which is
reproduced hereunder for easy reference;
B. Sanctioned and Unsanctioned Events
1. Prohibition on participating in Unsanctioned
Events:
1.1 Organisations or individuals (including
Athletes, technical officials, umpires, coaching or
management staff) under HOCKEY INDIA
jurisdiction may not participate in any manner in
any Unsanctioned Event.
1.2 Any Athlete or other individual under HOCKEY
INDIA jurisdiction who is found to have
participated in an Unsanctioned Event:
1.2.1 is automatically ineligible for twelve months
participate in any capacity in any International
Event:
a. Such Athlete or other individual may apply to
the FIH Disciplinary Commissioner for a waiver of
all or part of this period of ineligibility for good
cause shown, provided that the circumstances will
have to be exceptional to justify such waiver. The
FIH Disciplinary Commissioner's decision may be
appealed by the Athlete/other individual or the FIH
to the Judicial Commission;
b. During the period of ineligibility, the
Athlete/other individual may not be selected to
participate in any capacity in an International
Event, and any selection made despite this
prohibition may be declined by the FIH or other
event organiser.
1.2.2. may have disciplinary consequences
imposed upon him or her under the Hockey India
Disputes and Grievance Redressal Committee for
such breach of clause B.1.1, including (if seen fit)
being ruled ineligible to participate in any capacity
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in Sanctioned Events for a period of up to 12
months (first offence) or more (subsequent
offences).
1.3 HOCKEY INDIA will recognise and give effect
within its own jurisdiction to any restriction,
exclusion or ineligibility imposed by another
National Association on an organisation or
individual under that National Association's
jurisdiction for participating in an Unsanctioned
Event.
1.4 It is a condition of eligibility for any
organisation or individual from another National
Association wishing to participate in any Event
under HOCKEY INDIA jurisdiction that the
organisation or individual in question has not
participated in any Unsanctioned Event in the
twelve months prior to the Event in question.
5.3. Referring to Clause B(1.1), learned counsel
submits that although the said provision
prohibits athletes, technical officials, umpires,
coaching staff and management personnel
falling under the jurisdiction of Hockey India
from participating in any unsanctioned event,
the provision does not, by itself, prescribe any
automatic consequence of disqualification or
ineligibility in respect of domestic competitions.
5.4. Inviting the attention of the Court to Clauses
1.2.1 and 1.2.2, learned counsel contends that
the scheme of the Regulations clearly
distinguishes between ineligibility to participate
in international events and domestic events.
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Clause 1.2.1 provides for automatic ineligibility
for a period of twelve months only in relation to
participation in an international event.
5.5. In contrast, Clause 1.2.2 contemplates
disciplinary consequences only after
proceedings are initiated before the Hockey
India Disputes and Grievance Redressal
Committee.
5.6. It is, therefore, submitted that the petitioners,
merely because they are alleged to have
participated in an unsanctioned event, cannot
be automatically suspended or declared
ineligible to participate in domestic or national
tournaments. According to learned counsel,
automatic ineligibility is confined to
international events under Clause 1.2.1,
whereas any restriction in respect of domestic
or national events can be imposed only after
disciplinary proceedings are initiated and
concluded in accordance with Clause 1.2.2.
5.7. In this regard, he relies on the bye-laws of
Hockey India, more particularly Article 20
thereof, which is reproduced hereunder for easy
of reference;
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Article 20: Dispute Resolution Committee
20.1 HI shall constitute a. Dispute Resolution
Committee in accordance with these bye-laws, rules
and regulations framed for the purpose and
applicable law.
20.2 The constitution, composition, tenure, powers,
functions, operation and procedures of the Dispute
Resolution Committee shall be governed by rules
shall be chaired by a retired Judge of High Court or
eminent personality or and regulations framed by Hl
and applicable law. Preferably the Committee legal
practitioner.
20.3 The Dispute Resolution Committee shall
function in a manner consistent with principles of
natural justice and fairness, as prescribed in the
applicable byelaws.
5.8. Learned counsel next relies upon Article 20 of
the Bye-laws of Hockey India dealing with the
constitution of the Dispute Resolution
Committee. Referring to Articles 20.1 to 20.3, it
is submitted that Hockey India is required to
constitute a Dispute Resolution Committee
whose constitution, powers and procedure are
governed by the Bye-laws and applicable
regulations, and that such Committee is
required to function consistently with the
principles of natural justice.
5.9. It is, therefore, contended that any dispute
relating to the alleged breach of the Regulations
is required to be considered by the Dispute
Resolution Committee constituted under Article
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20 and cannot be decided unilaterally by
Hockey Karnataka.
5.10. Apart from the Dispute Resolution Committee,
there is a Grievance Refusal Committee
contemplated in Article 22 of Bye-laws of
Hockey India. Article 22 is reproduced
hereunder for easy reference.
Article 22: Grievance Redressal Committee
22.1 HI shall establish an internal grievance redressal
mechanism, including the constitution of a Grievance
Redressal Committee, in accordance with these bye-
laws and applicable law.
22.2 The Grievance Redressal Committee shall address
grievances raised by athletes, coaches and other
persons associated with HI in a fair, timely and
transparent manner, in accordance with the procedure
prescribed under the applicable regulations.
22.3 The composition, tenure, powers, functions,
jurisdiction and procedure of the Grievance Redressal
Committee shall be governed by rules and regulations
framed by HI in accordance with these bye-laws and
applicable law. Preferably the Committee shall be
chaired by a retired Judge of High Court or eminent
personality or legal practitioner.
22.4 The grievance redressal mechanism shall operate
without prejudice to any other remedy available under
these bye-laws or applicable law.
5.11. By referring to Article 22, his submission is that
whenever there is any grievance, the Grievance
Committee shall address grievances raised by
athletes, coaches and other persons associated
with Hockey India in a fair, timely and
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transparent manner in accordance to the
procedure prescribed under the applicable
regulations. The Grievance Redressal
Committee in terms of Article 22.2 the word
“fair” would include compliance with the
principles of natural justice.
5.12. By referring to Article 22.3, he submits that the
Grievance Redressal Committee shall have to
be chaired by a retired Judge of the High Court
or eminent personality or legal practitioner,
which would require that the petitioners are
heard by the Grievance Redressal Committee
before any orders are passed.
5.13. He refers to the Hockey India Code of Ethics
and Ethics Committee, which relates to Article
19 of Hockey India bye-laws and submits that
even if there is any ethical violation on the part
of the petitioners, the same would have to be
enquired into by the Ethics Committee and in
this regard, he relies on Article 4, which relates
to complaints and references. Article 4 is
reproduced hereunder for easy reference;
Article 4- Complaints and References
1. Any complaint alleging violation of the Hockey
India Code of Ethics or related regulations may be
filed before Hockey India in writing, physically or
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electronically, in such form and manner as may be
prescribed.
2 Every complaint shall contain:
a) the name and particulars of the complainant:
b) particulars of the respondent:
c) material facts and allegations:
d) supporting documents or evidence, where
available: and
e) a declaration affirming the correctness of the
contents.
3. Anonymous or pseudonymous complaints may be
examined where the allegations disclose serious
ethical violations or matters affecting the integrity of
the sport.
4. The President of Hockey India, the Executive
Committee or any competent authority may also refer
any matter suo motu to the Ethics Committee for
inquiry or consideration.
5. Hockey India may prescribe a reasonable
complaint fee, procedural requirements or filing
conditions, subject to waiver or exemption in
appropriate cases.
5.14. By referring to Article 4, his submission is that
if there is any complaint alleging violation of
Hockey India Code of Ethics or related
regulations, the said complaint would have to
be filed before Hockey India in writing,
physically or electronically, and the contents of
the complaint are as described under Clause (2)
thereof.
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5.15. The President of Hockey India, the Executive
Committee or any Competent Authority may
also refer any matter suo motu to the Ethics
Committee for enquiry or consideration. The
procedure on a complaint being received or suo
motu reference being made is that under Article
5 of the Ethics Committee, which is reproduced
hereunder for easy reference;
Article 5 - Procedure and Inquiry
1. Upon receipt of a complaint or reference, the Ethics
Committee shall undertake a preliminary examination
to determine whether a prima facie case exists.
2. If the Committee is satisfied that a prima facie
case exists, notice shall be issued to the respondent
along with relevant material and documents.
3. The respondent shall ordinarily be granted a period
of 2 (two) weeks from receipt of notice to file a
written response or explanation. The Committee may
extend such period for sufficient cause recorded in
writing.
4. The Ethics Committee shall ensure compliance with
the principles of natural justice and provide
reasonable opportunity of hearing to all concerned
parties.
5. During the course of inquiry, the Ethics Committee
may:
a) call for records, information, reports or documents;
b) seek written statements or affidavits;
c) summon and hear parties, witnesses or experts;
d) permit representation through legal counsel where
considered appropriate;
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e) conduct hearings physically or through video
conferencing;
f) appoint Independent experts, investigators or
advisors;
g) seek assistance from Hockey India officials or
external agencies; and
h) take any other measure necessary for effective
adjudication of the matter.
6. Proceedings before the Ethics Committee may be
conducted in person, through virtual mode or by
circulation of documents, as the Committee may
deem appropriate.
7. The Committee may grant interim
recommendations or directions where necessary to
preserve integrity, fairness, safety, confidentiality or
the proper administration of the proceedings.
5.16. By referring to of Article 5, his submission is
that to preserve integrity, fairness, safety and
confidentiality interim recommendations could
be submitted and in terms of Sub-clause (1) of
Article 5, on receipt of the complaint, a
preliminary examination is required to be
conducted and in terms of Clause (2), if the
Committee is satisfied that a prima facie case
exists, notice is to be issued to respondents
along with relevant material. In terms of Clause
(3), respondents are required to be granted two
weeks' time to file a written response or
explanation. Thereafter, the Committee,
ensuring compliance with the principles of
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natural justice and providing reasonable
opportunity of hearing to all concerned, could
pass such orders, including interim directions.
5.17. His submission is that even if there is a suo
motu reference which has been made by
Hockey Karnataka, there is no enquiry which
has been held in terms of Article 5 without an
enquiry being held and the principles of natural
justice being satisfied, so-called ineligibility
arrived at by Hockey Karnataka in respect to
the petitioners, is not sustainable and is
required to be set aside.
6. Sri.D.R.Ravishankar., learned Senior Counsel
appearing for Hockey Karnataka, would submit that:
6.1. The bye-laws of Hockey India have been
mutatis mutandis adopted by Hockey
Karnataka, and all the bye-laws are equally
applicable to Hockey Karnataka.
6.2. His submission is that the aspect of discipline is
very important for any game and more so for
the national game of hockey. There being
various issues which had arisen on account of
indiscipline, the Hockey India Regulations
Relating to Sanctioned and Unsanctioned
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Events published in August 2019 had been
introduced. This was to ensure that the players
participate only in sanctioned events and not in
unsanctioned events, and that their schedule is
regulated in a proper manner.
6.3. Apart therefrom, he submits that the
classification of sanctioned and unsanctioned
events is also in the interest of protecting the
interests of the players so that they are not
used or misused in other unsanctioned events.
6.4. His submission is that an event is being
specifically adverted to in Clause 1.14 of Article
1 of the bye laws of Hockey India, which means
any match, tournament, competition, league,
trial, camp or programme which is organised,
recognised, sanctioned or controlled by Hockey
India or by any affiliated unit of Hockey India
acting in accordance with the bye laws or
conducted under aegis of Federation of
International Hockey (FIH), Asian Hockey
Federation (AHF) and Indian Olympic
Association (IOA). Clause 1.14 is reproduced
hereunder for easy reference:
1.14 “Event” means any match, tournament,
competition, league, trial, camp or programme which
is organized, recognised, sanctioned or controlled by
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HI, or by any affilated unit of HI acting in accordance
with these bye-laws, or conducted under the aegis of
the FIH, AHF or IOA.
6.5. His submission is that Hockey Karnataka, being
registered in Karnataka, has a Memorandum of
Association. The main objective is to affiliate
Hockey Karnataka with Hockey India and the
Karnataka Olympic Association, and to bring it
within the purview of their rules, by-laws, and
regulations, and to comply with them and be
bound by them. Thus, he submits that there is
no option but to incorporate the by-laws of
Hockey India into Hockey Karnataka.
6.6. By referring to Clause (xvi) of the main
objectives of Hockey Karnataka, his submission
is that Hockey Karnataka is required to take
disciplinary action against District Hockey
Organisation/institutions/units indulging in anti-
social activities, showing inappropriate acts,
indulging in any act, bringing bad
name/ignominy, defame to State and to the
Hockey game.
6.7. His contention is that participation in
unsanctioned events would come within the
disciplinary powers of Hockey Karnataka.
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6.8. By referring to the Rules and Regulations of
Hockey Karnataka, more particularly Clause (v)
of Rule 1, which defines ‘player’, he submits
that any person participating in any activities or
units accepted and controlled by Hockey India
or its members would be a ‘player’. Clause (v)
of Rule 1 of Hockey Karnataka is reproduced
hereunder for easy reference:
v . ‘ Player ’ its meaning: persons participating in any
activities/units accepted and controlled by HOCKEY
INDIA/its members.
6.9. Learned Senior Counsel for respondent No.2
submits that the regulatory framework
governing the sport of hockey operates at three
distinct levels, namely, the District/State level,
the National level and the International level.
According to him, insofar as domestic
tournaments conducted within the country are
concerned, Hockey Karnataka is the competent
authority to regulate the conduct of players
within the State, whereas Hockey India
exercises jurisdiction in respect of international
events.
6.10. Learned Senior Counsel submits that Hockey
Karnataka is vested with the authority to
regulate participation in domestic tournaments
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conducted within the State and is equally
empowered to initiate disciplinary proceedings
against players who violate the applicable Rules
and Regulations.
6.11. In support of the said contention, learned
Senior Counsel places reliance upon Rule
5(1)(vi) of the Rules of Hockey Karnataka to
contend that the Association is expressly
empowered to impose fines or penalties and to
initiate disciplinary action against any person
committing a violation of the Act, the Rules or
the Bye-laws. It is on the strength of the said
power that the impugned action has been
taken.
6.12. Learned Senior Counsel further relies upon Rule
5(2)(v) to submit that the Executive Committee
is specifically empowered to take decisions
relating to indiscipline, misconduct and allied
matters and, therefore, the impugned decision
falls squarely within its powers.
6.13. Referring to the Hockey India Regulations
Relating to Sanctioned and Unsanctioned
Events (August, 2019), learned Senior Counsel
submits that the expression "Event" has been
defined broadly to include any indoor or
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outdoor hockey match, tournament,
competition or other event at any level,
whether international, continental, national or
local, including age-group events. A
"Sanctioned Event" is one organised or
sanctioned by the relevant Continental
Federation, National Association or the FIH in
accordance with the Regulations, including
events organised or sanctioned by Hockey India
under Clause B.2 thereof.
6.14. It is his submission that every event which does
not satisfy the above definition is necessarily an
"Unsanctioned Event". Therefore, if a player
participates in a tournament which has not
been sanctioned by the competent authority,
such participation constitutes a violation of the
Regulations, warranting disciplinary action by
Hockey Karnataka to maintain discipline and
the integrity of the sport.
6.15. Learned Senior Counsel further places reliance
upon the communication dated 24.02.2026
issued by Hockey Karnataka, wherein the
tournaments recognised and sanctioned by
Hockey Karnataka for the relevant season have
been specifically enumerated. According to him,
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any tournament not included in the said list is
necessarily an unsanctioned tournament. Since
the KSHA League in which the petitioners
admittedly participated does not figure in the
said list, the participation of the petitioners
therein amounts to participation in an
unsanctioned event.
6.16. Learned Senior Counsel fairly submits that no
individual notice or show-cause notice was
issued to the petitioners before the impugned
communication was addressed. However, he
contends that a communication was addressed
to the Sports Welfare Officer of the Comptroller
and Auditor General of India informing the
employer that the petitioners had participated
in the KSHA B Division, A Division and Super
Division League matches representing various
private clubs in tournaments which were not
sanctioned by Hockey Karnataka and,
consequently, they were not eligible to
participate in the League Championship
organised by Hockey Karnataka.
6.17. Learned Senior Counsel also places reliance
upon the newspaper reports produced as
Annexure-R11 to contend that there is no
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dispute whatsoever regarding the participation
of the petitioners in the KSHA tournaments.
According to him, once the factual participation
in an unsanctioned event is admitted or
otherwise indisputable, no further enquiry into
the factual aspect is warranted. The only
consequence flowing from such admitted
participation is the initiation of disciplinary
action in terms of the governing Regulations.
6.18. Learned Senior Counsel submits that issuance
of a prior notice to the petitioners would have
been an empty formality, since there was no
factual dispute regarding their participation in
the unsanctioned tournaments. According to
him, in the absence of any tenable defence
available to the petitioners, non-issuance of
notice has not caused any prejudice. It is on
this basis that Hockey Karnataka declared the
petitioners ineligible to participate in the
League Championship.
6.19. Learned Senior Counsel therefore submits that,
even assuming that there has been some
deviation from the principles of natural justice,
the same would not vitiate the impugned
action, as the present case falls within the well-
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recognised "empty formality" exception to the
rule of audi alteram partem. Since the
participation of the petitioners in the
unsanctioned tournaments is undisputed, no
useful purpose would have been served by
issuing a prior notice or conducting an enquiry.
On the aforesaid grounds, he submits that the
writ petition is devoid of merit and is liable to
be dismissed.
7. Sri.Udith Dedhiya, learned counsel appearing for
Hockey India would also support the submission of
Sri D.R. Ravishankar, learned Senior counsel.
7.1. He further submits that it is the responsibility of
Hockey India to discipline its players in respect
of the national and international events. The
respective State units would have to maintain
discipline in respect of their respective State
events.
7.2. He also submits that players cannot participate
in unsanctioned events and in that regard he
submits that Hockey Karnataka has necessary
powers to take action against any indiscipline
by any particular player.
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8. Heard Sri Somanna K.P., learned counsel for the
petitioners, Sri D.R.Ravishankar, learned Senior
Counsel for respondent No.1 and Sri Udith Dedhiya,
learned counsel for respondent No.3.
9. The rival submissions advanced on behalf of the
parties have been noticed in considerable detail for
the sake of completeness. However, in the opinion of
this Court, it is neither necessary nor appropriate to
examine each of those contentions at this stage. The
controversy involved in the present writ petition lies
within a narrow compass and turns essentially upon
the interpretation of the Hockey India Regulations
Relating to Sanctioned and Unsanctioned Events,
2019 and the procedure prescribed therein.
10. The principal question that arises for determination
by this Court is whether the mere participation of a
player in an alleged unsanctioned domestic event
automatically renders such player ineligible or
disqualified from participating in domestic
tournaments, or whether such ineligibility can be
imposed only after following the disciplinary
procedure contemplated under the governing
Regulations.
11. The answer to the aforesaid question is found in
Clause B of the Hockey India Regulations Relating to
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Sanctioned and Unsanctioned Events, published in
August, 2019. Clause B(1.2.1) provides that an
athlete or other individual under the jurisdiction of
Hockey India who is found to have participated in an
unsanctioned event shall be automatically ineligible
for a period of twelve months to participate in any
capacity in any International Event. The language
employed in the provision is plain, unambiguous and
admits of only one interpretation. The consequence
of automatic ineligibility is expressly confined to
participation in international events. The Regulation
does not provide that such automatic ineligibility
extends to domestic, State, District or National-level
tournaments. The Regulations contemplate automatic
disqualification, restricted to international events. It
is a settled principle of interpretation that where the
language of a provision is clear, the Court cannot
enlarge its scope by reading into it words which the
rule-making authority has consciously omitted.
12. The scheme of the Regulations further fortifies the
above interpretation. Clause B(1.2.2) specifically
deals with disciplinary consequences arising out of
participation in an unsanctioned event and provides
that an athlete may have disciplinary consequences
imposed upon him or her by the Hockey India
Disputes and Grievance Redressal Committee for
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breach of Clause B(1.1), including, where considered
appropriate, being declared ineligible to participate in
sanctioned events for the prescribed period. The use
of the expression "may" and the specific reference to
the competent Disputes and Grievance Redressal
Committee clearly indicate that, insofar as domestic
events are concerned, ineligibility is not automatic
but is dependent upon an adjudicatory process
undertaken by the competent authority. Thus, the
Regulations themselves make a conscious distinction
between international events, where the
consequence follows automatically by operation of
Clause B(1.2.1), and domestic events, where
disciplinary action is contingent upon an enquiry
contemplated under Clause B(1.2.2).
13. The Bye-laws and the Code governing the functioning
of the Disputes and Grievance Redressal Committee,
as extracted hereinabove, prescribe a comprehensive
procedure to be followed before any disciplinary
consequence is imposed. Upon receipt of a complaint
or upon a suo motu reference, the competent
Committee is required to undertake a preliminary
examination to determine whether a prima facie case
exists. If satisfied that a prima facie case is made
out, notice is required to be issued to the concerned
athlete together with the relevant material and
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documents relied upon. The athlete is required to be
afforded adequate time to submit a written
explanation, following which the Committee is
obliged to consider the matter after complying with
the principles of natural justice and pass an
appropriate reasoned order. Such a structured
procedure is not an “empty formality”. It constitutes
the very foundation of the disciplinary mechanism
envisaged under the Regulations.
14. In the present case, admittedly, no proceedings have
been initiated before the competent Disputes and
Grievance Redressal Committee. There is nothing
placed on record to indicate that any complaint has
been lodged before the Committee or that any suo
motu reference has been made by the competent
authority. There is equally no material to
demonstrate that a preliminary examination has
been undertaken, notice has been issued to the
petitioners, an opportunity has been afforded to
them to submit their explanation or that the
competent Committee has rendered any finding
regarding the alleged violation. In the absence of any
such adjudication, the declaration made by the
Secretary General of Hockey Karnataka that the
petitioners are ineligible to participate in the League
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Championship is dehors the procedure prescribed
under the governing Regulations.
15. The submission urged on behalf of the respondents
that no enquiry was necessary since the petitioners
do not dispute their participation in the KSHA
tournament also cannot be accepted. The disciplinary
process contemplated under the Regulations is not
intended merely to ascertain the factum of
participation. The enquiry may extend to several
aspects including whether the tournament in
question answers the definition of an "unsanctioned
event", whether the concerned players were in fact
subject to the jurisdiction of the Regulations in the
manner alleged, whether there existed any
justification, exemption or mitigating circumstance,
whether the alleged violation attracts disciplinary
consequences, and if so, the nature and extent of
such consequences. These are matters which the
Regulations entrust to the specialised disciplinary
forum constituted under the Bye-laws. Merely
because one factual circumstance may not be
disputed does not render the entire adjudicatory
process redundant.
16. The further contention that issuance of notice would
have been an empty formality is equally devoid of
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merit. The "empty formality" theory constitutes a
narrow exception to the rule of audi alteram partem
and cannot be invoked to dispense with a statutory
or regulatory procedure which expressly requires
adjudication by a designated authority. Where the
governing Regulations themselves prescribe the
authority competent to determine the existence of a
violation and the procedure to be followed before
imposing disciplinary consequences, such procedure
cannot be bypassed on the assumption that the
outcome is a foregone conclusion. Acceptance of
such a contention would amount to permitting an
authority to substitute its subjective satisfaction for
the adjudicatory mechanism consciously created by
the rule-making authority, a course which is
impermissible in law.
17. This Court is therefore of the considered opinion that
the impugned communication dated 18.06.2026
proceeds on an assumption that participation in an
alleged unsanctioned domestic event automatically
results in ineligibility. Such an assumption is contrary
to the plain language of Clause B of the 2019
Regulations. While automatic ineligibility is expressly
provided only in relation to international events
under Clause B(1.2.1), any disciplinary consequence
affecting participation in domestic or national
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tournaments can be imposed only after the
procedure contemplated under Clause B(1.2.2) has
been duly followed by the competent Disputes and
Grievance Redressal Committee.
18. Whether the petitioners have, in fact, violated the
Regulations, whether the KSHA tournament was an
unsanctioned event within the meaning of the
Regulations, whether Hockey Karnataka possesses
the authority claimed by it, and whether any
disciplinary consequence ultimately deserves to be
imposed are all questions which this Court
intentionally refrains from adjudicating. Those
questions fall within the domain of the competent
disciplinary authority and must first be considered by
it in accordance with the procedure prescribed under
the Regulations. Any opinion expressed by this Court
on those issues at this stage would amount to
prejudging matters which are yet to be examined by
the authority vested with the jurisdiction to do so.
19. In the above circumstances, this Court is satisfied
that the impugned communication dated 18.06.2026
cannot be sustained, not because this Court has
expressed any opinion on the merits of the
allegations against the petitioners, but because the
declaration of ineligibility has been made by
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bypassing the mandatory disciplinary mechanism
prescribed under the governing Regulations and in
violation of the principles of natural justice
embedded therein. It is always open to the
competent Disputes and Grievance Redressal
Committee to initiate appropriate proceedings, if so
advised, and to take a decision in accordance with
law after affording the petitioners a reasonable
opportunity of being heard. All rival contentions on
merits are accordingly left open.
20. As such this Court passes the following:
ORDER
i) Writ petition is partly allowed .
ii) A mandamus is issued directing respondent
No.1 to permit the petitioners to participate in
th
the 10 Hockey Karnataka League
Championship 2026.
iii) Liberty is reserved to respondent No.1 to
initiate such disciplinary proceedings as may be
permissible under the relevant rules and
regulations.
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iv) The respondents shall act on the printout of the
operative portion of the order without insisting
on the entire order.
Sd/-
(SURAJ GOVINDARAJ)
JUDGE
SR/KTY
List No.: 1 Sl No.: 28