Administrator cannot usurp statutory powers of Electoral Officer to determine eligibility for the electoral roll.

The petitioners, the Madhya Pradesh Judo Association and the All Assam Judo Association, are state-level bodies affiliated with the Judo Federation of India (JFI).

Following a court direction, an Electoral Officer was appointed on 17.03.2026 to conduct elections for the Interim Executive Committee.

The petitioners submitted their authorized representatives' names in Form-1 by the deadline of 10.04.2026.

On 20.04.2026, the Administrator of the JFI issued a communication declaring the petitioners' representatives ineligible and excluded them from the Electoral College after performing his own scrutiny.

The petitioners challenged this communication, arguing the Administrator lacked the authority to perform functions vested in the Electoral Officer.

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

Foundational principle established in Taylor v. Taylor (1876) and affirmed by the Supreme Court in State of Uttar Pradesh v. Singhara Singh (1964), which dictates that if a statute prescribes a specific method for exercising a power, that power must be exercised in that manner and no other.

The maxim expressio unius est exclusio alterius (the express mention of one thing excludes all others) to establish that vesting power in the Electoral Officer excludes that power from the Administrator.

The court reasoned that Rule 10(5) creates a specific statutory scheme where the Electoral Officer is the sole authority responsible for the preparation and finalization of the electoral roll.

The court noted that in the present case, an Electoral Officer had already been appointed prior to the impugned action.

By undertaking the scrutiny of nominations and declaring representatives ineligible, the Administrator performed a function that the law reserves exclusively for the Electoral Officer.

Applying the rule in Taylor v. Taylor, the court held that since the statute (Rules of 2026) provides a specific mode for determining eligibility through the Electoral Officer, any exercise of that power by the Administrator is legally impermissible and renders the resulting communication void.

The court quashed and set aside the impugned communication dated 20.04.2026.

The court granted liberty to the duly appointed Electoral Officer to conduct the necessary scrutiny and pass appropriate orders regarding the petitioners' eligibility in accordance with the extant rules and regulations.