Automatic Ineligibility for Domestic Events Requires Adherence to Prescribed Disciplinary Procedures and Natural Justice

In brief

The question

1. Whether the mere participation of a player in an alleged unsanctioned domestic event automatically renders such player ineligible for domestic tournaments without a formal disciplinary process

The court held

The Court concluded that the impugned communication was unsustainable as it bypassed the mandatory disciplinary mechanism and violated the principles of natural justice

It also directed

Through a Writ of Mandamus, the Court directed Respondent No. 1 to permit the petitioners to participate in the 10th Hockey Karnataka League Championship 2026 [para. 20]. However, the Court reserved liberty for the Respondents to initiate formal disciplinary proceedings in accordance with the prescribed rules and regulations [para. 20]. All rival contentions on the merits of the alleged violation were left open

01Facts

The petitioners are professional hockey players and permanent employees of the Accounts and Audit General Office (AGORC), Bengaluru

p. 3

On 18.06.2026, Respondent No. 1 (Hockey Karnataka) issued a communication to the AGORC inviting their team to the 10th Hockey Karnataka League Championship but specifically declared the petitioners ineligible to participate

p. 4

This declaration was based on the allegation that the petitioners had participated in an "unsanctioned tournament" organized by the Karnataka State Hockey Association (KSHA), an unrecognized body

p. 5

The petitioners challenged this communication, arguing that no disciplinary procedure or hearing was conducted prior to their disqualification

p. 15

02Issues

i.1. Whether the mere participation of a player in an alleged unsanctioned domestic event automatically renders such player ineligible for domestic tournaments without a formal disciplinary process

p. 24 / para. 10

ii.2. Whether the "empty formality" doctrine applies to dispense with the principles of natural justice when the factum of participation in a tournament is undisputed

pp. 22, 28-29 / para. 15-16

03Law Applied

Hockey India Regulations Relating to Sanctioned and Unsanctioned Events (August 2019): Clause B(1.2.1) mandates automatic ineligibility for twelve months only for "International Events"

p. 6, 25

For domestic events, Clause B(1.2.2) stipulates that disciplinary consequences must be imposed by the Disputes and Grievance Redressal Committee

pp. 6-7, 25-26

Article 20 and 22 of the Hockey India Bye-laws, along with Articles 4 and 5 of the Code of Ethics, establish a mandatory adjudicatory framework requiring preliminary examination, notice, and a hearing consistent with the principles of natural justice

pp. 9-11, 13-14

The principle that the "empty formality" exception to audi alteram partem cannot override express regulatory procedures

p. 29

Provisions in the judgment · 7

Central Electricity Regulatory Commission (Fees and Charges of Regional Load Despatch Centre and other related matters) Regulations, 2019 BSection 1

National Dope Testing Laboratory (Service, Administrative & Financial) Bye-Laws, 2009 Section 19Section 20Section 22

Flag Code Of India, 2002 Section 4Section 5

04Reasoning

The Court observed that the Regulations create a clear distinction between international and domestic events; while the former triggers automatic disqualification, the latter requires a discretionary adjudicatory process

¶ 11-12

The Court found that Respondent No. 1 unilaterally declared the petitioners ineligible without initiating any proceedings before the competent Disputes and Grievance Redressal Committee as required by Clause B(1.2.2)

¶ 14

The Court rejected the Respondents' argument that an enquiry was unnecessary due to the "undisputed" participation in the KSHA tournament. It held that an enquiry is not merely to establish facts, but to determine jurisdictional applicability, justifications, and the proportionality of the penalty

¶ 15

The Court further ruled that the "empty formality" theory cannot be used by an authority to substitute its subjective satisfaction for a designated statutory adjudicatory mechanism

¶ 16

05Holding

The Court concluded that the impugned communication was unsustainable as it bypassed the mandatory disciplinary mechanism and violated the principles of natural justice

¶ 19

¶ 19-20

LawLens.Karnataka High Court

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