Administrator Cannot Usurp Statutory Powers of Electoral Officer to Determine Eligibility for Electoral College

The Petitioners, State Judo Associations affiliated with the Judo Federation of India (JFI), sought to participate in the elections for the Interim Executive Committee of the JFI

Pursuant to court directions, an Electoral Officer was appointed on 17.03.2026, and a notice was issued for associations to submit nominations for the Electoral College by 10.04.2026

Although the Petitioners submitted their nominations within the timeframe, the Administrator of the JFI issued a communication on 20.04.2026, personally conducting a scrutiny and declaring the Petitioners' representatives ineligible

The Petitioners challenged this communication, arguing the Administrator usurped the powers of the Electoral Officer

1. Whether the Administrator of a National Sports Federation has the legal authority to scrutinize nominations and determine the eligibility of representatives for the Electoral College when an Electoral Officer has been appointed.

Rule 10(5) of the National Sports Governance Rules, 2026, which mandates that the electoral roll must be prepared by the Electoral Officer, whose decisions regarding inclusion or exclusion are final and binding

Foundational principle established in Taylor v. Taylor (1876) and affirmed by the Supreme Court of India in State of Uttar Pradesh v. Singhara Singh (1964), which dictates that if a statute prescribes a specific manner for performing an act, that act must be done in that manner or not at all

Doctrine of expressio unius est exclusio alterius (the express mention of one thing excludes all others)

The Court reasoned that because Rule 10(5) of the 2026 Rules identifies the Electoral Officer as the sole authority for preparing the electoral roll and deciding on eligibility, this power is necessarily excluded from the Administrator

Since an Electoral Officer had already been appointed on 17.03.2026, the Administrator’s subsequent act of scrutinizing nominations on 20.04.2026 constituted an unauthorized performance of statutory functions belonging exclusively to another officer

The Court found that by undertaking a "preliminary exercise" not contemplated by the rules, the Administrator violated the procedural requirements laid down by law

The Court set aside the impugned communication dated 20.04.2026. The petitions were disposed of with a direction that the eligibility of the Petitioners be considered solely by the duly appointed Electoral Officer, who is granted liberty to undertake the exercise and pass appropriate orders in accordance with the extant rules