President, Indian Olympic Association & Anr. vs Ski And Snowboard India & Anr.

$~
* IN THE HIGH COURT OF DELHI AT NEW DELHI

+ Date of Decision: 24.04.2026

% LPA 104/2026
PRESIDENT, INDIAN OLYMPIC ASSOCIATION & ANR.
.....Appellants
Through: Ms. Aashita Khanna and Ms. Aanya
Agarwal, Advs

versus

SKI AND SNOWBOARD INDIA & ANR. .....Respondents
Through: Ms. Neha Singh, Adv. for R-1.
Mr.Udi Dedhiya, SPC with
Ms.Apurva Sachdev, Mr.Preyansh
Gupta, Advs. and Mr.Amit Rana, GP
for R-2.

CORAM:
HON'BLE THE CHIEF JUSTICE
HON'BLE MR. JUSTICE TEJAS KARIA

DEVENDRA KUMAR UPADHYAYA, CJ. (ORAL)

REVIEW PET. 189/2026 & CM APPL. 26660/2026

1. Heard learned counsel for the review applicant/petitioner.
2. By instant review petition, the review petitioner has sought review of
the final judgment and order dated 23.03.2026 whereby LPA No. 104/2026
filed by the President, Indian Olympic Association against the order dated
10.02.2026 passed by the learned Single Judge, has been disposed of with a
minor modification of the order passed by the learned Single Judge.
LPA 104/2026 Page 1 of 5
Signature Not Verified
Digiltally Signed
By:SREERAM L
Signing Date:25.04.2026
15:19:12

3. The W.P.(C.) No. 3418/2025 was instituted by the review petitioner
primarily challenging the order dated 13.10.2023 whereby a Four-Member
Ad Hoc Committee was formed by the Indian Olympic Association to look
after the affairs of the review petitioner.
4. The writ petition was allowed by the learned Single Judge by means
of the order dated 10.02.2026 whereby the order impugned therein, dated
13.10.2023, was set aside and it was observed by the learned Single Judge
that the Ad Hoc Committee stood dissolved with immediate effect. The
learned Single Judge also appointed a retired Judge of this Court as
Returning Officer to draw up the list of eligible members of the review
petitioner and conduct its elections. The learned Single Judge also
determined Rs. 5 Lakhs per month to be paid to the Returning Officer as her
fee.
5. While upholding the order passed by the learned Single Judge to the
extent it had quashed the order dated 13.10.2023, we only set aside the
direction issued to the Indian Olympic Association to bear the fee to be paid
to the Returning Officer and directed that the fee shall be paid by the review
petitioner. The reason for absolving the Indian Olympic Association of the
charge of payment of fee to the Returning Officer was that the review
petitioner is an independent society, elections of which is the responsibility
of the association or its office bearers themselves and, therefore, for
conducting the election, no third party, in this case the Indian Olympic
Association, can be saddled with the burden of bearing the fee to be paid to
the Returning Officer for conducting the elections of the review petitioner.
6. Learned counsel for the review petitioner has stated that the judgment
LPA 104/2026 Page 2 of 5
Signature Not Verified
Digiltally Signed
By:SREERAM L
Signing Date:25.04.2026
15:19:12

and order under review records a wrong finding that the review petitioner is
not a recognised national sports federation. Such finding, according to the
learned counsel for the review petitioner is not sustainable for the reason
that the review petitioner is an affiliated body of the Indian Olympic
Association and, therefore, it is a National Sports Federation.
7. The said submission is absolutely untenable for the reason that prior
to enforcement of National Sports Governance Act, 2025, the entire regime
of recognising a body or association as National Sports Federation was
governed by the National Sports Development Code of India issued in the
year 2011. Clause 8 of the National Sports Code, 2011 (hereinafter referred
as “Sports Code, 2011” ) explicitly provides that for the purpose of ensuring
that National Sports Federations maintain certain basic standards, norms and
procedures in respect of their internal functioning which conforms to the
principles and objectives laid down by international federation and which
are also in consonance with the principles laid down in the Olympic Charter,
the National Sports Federations seeking recognition will have to apply as per
the guidelines appended as annexure-2 to the Sports Code, 2011. The Sports
Code, 2011 also provides conditions of eligibility as a recognized National
Sports Federation and the procedure for such recognition. There is no other
instrument or provision which provides for recognition of any sports body as
a National Sports Federation which function is now governed by the
provisions of 2025 Act. Prior to enforcement of 2025 Act, the only
provision for recognition of any body or association as National Sports
Federation was the Sports Code, 2011.
8. Learned counsel for the review petitioner has, however, stated that
LPA 104/2026 Page 3 of 5
Signature Not Verified
Digiltally Signed
By:SREERAM L
Signing Date:25.04.2026
15:19:12

prior to enforcement of 2025 Act, there were two types of National Sports
Federations, the one recognised by the Ministry of Sports and Youth Affairs,
Government of India under the Sports Code, 2011 and the other by the
Indian Olympic Association under its memorandum and rules and
regulations.
9. Our attention has been drawn to Clause 3 of the Memorandum and
Rules and Regulations of Indian Olympic Association which provides for
membership of Indian Olympic Association. According to Clause 3,
membership of association shall be open to certain category of organisations
which include the National Sports Federations affiliated to International
Sports Federations which adhere to the International and National Sports
Code in respect of sports included in the Summer and Winter Olympic
Games, National Sports Federations affiliated to International Sports
Federations which adhere to International and National Sports Code in
respect to sports not included in the Summer and Winter Games but
included in Asian or Commonwealth Games, National Sports Federations
affiliated to International Sports Federation which adhere to International
and National Sports Code in respect of sports not included either in Summer
or Winter Games or Asian or Commonwealth Games and National Sports
Federations of indigenous games. Certain other category of individuals are
also eligible to become member of Indian Olympic Association.
10. Thus, submission of the learned counsel for the review petitioner that
Clause 3 of Memorandum and Rules and Regulations of Indian Olympic
Association also provides for registration or recognition as National Sports
Federation is absolutely misconceived and incorrect for the reason that what
LPA 104/2026 Page 4 of 5
Signature Not Verified
Digiltally Signed
By:SREERAM L
Signing Date:25.04.2026
15:19:12

Clause 3 of Memorandum and Rules and Regulations of Indian Olympic
Association prescribes is the eligibility for its membership. Attaining of
eligibility of membership of Indian Olympic Association does not mean
recognition as National Sports Federation which is permissible only under
the provisions of the National Sports Code, 2011.
11. For the aforesaid reasons, we are of the view that the review petition
is absolutely misconceived. Learned counsel for the review petitioner
completely fails to point out any error apparent on the face of record of our
judgment and order dated 23.03.2026.
12. The review petition is, thus, dismissed with a cost of Rs.10,000/- to be
deposited by the review petitioner in the account of Delhi High Court Bar
Clerk’s Association (A/c. No. 15530100006282, IFSC – UCBA0001553,
UCO Bank, Delhi High Court Branch, New Delhi) within a month, failing
which, it shall be lawful for the Registrar General of this Court to get the
amount of costs recovered as arrears of land revenue.

DEVENDRA KUMAR UPADHYAYA, CJ


TEJAS KARIA, J
APRIL 24, 2026
N.Khanna
LPA 104/2026 Page 5 of 5
Signature Not Verified
Digiltally Signed
By:SREERAM L
Signing Date:25.04.2026
15:19:12