Autonomy of Registered Societies Precludes Judicial Interference in Governing Internal Committees Absent Malice or Bias

In brief

The question

1. Whether the High Court, in exercising writ jurisdiction, can legally substitute the internal judicial bodies of a registered society with a court-appointed committee in the absence of a finding of malice or illegality

The court held

The Court answered that the learned Single Judge was not justified in reconstituting the Ethics Committee

It also directed

The final holding set aside the order dated 01.04.2026, allowing the appeals

The Court directed that Respondent No. 1’s representations be decided by the Ethics Committee as reconstituted by the AIFF, following the principles of natural justice and providing an opportunity for a hearing, within eight weeks

01Facts

Respondent No. 1 filed writ petitions seeking the constitution of an independent committee to adjudicate its representations regarding grievances against the All India Football Federation (AIFF) and its President

¶ 4-5

Previously, the learned Single Judge had directed AIFF to decide these representations after a hearing

¶ 6

In response to contempt proceedings and allegations of conflict of interest against an initial member (Mr. Pachnanda), AIFF reconstituted its Ethics and Dispute Resolution Committee under its Constitution, appointing Justice (Retd.) Shekhar Dhawan as Chairperson

¶ 7-8, 16-17

Despite this internal reorganization, the learned Single Judge, via order dated 01.04.2026, overrode the AIFF’s internal committee and appointed a court-constituted committee chaired by Justice (Retd.) Rekha Palli

¶ 8, 19

The AIFF appealed this interference with its internal governance

¶ 9

02Issues

i.1. Whether the High Court, in exercising writ jurisdiction, can legally substitute the internal judicial bodies of a registered society with a court-appointed committee in the absence of a finding of malice or illegality

¶ 21-26, 41

ii.2. Whether the autonomy of a National Sports Federation (NSF) registered under the Societies Registration Act, 1860, is violated by judicial interference in its internal committee appointments

¶ 33, 40

03Law Applied

The Court primarily applied Article 19(1)(c) of the Constitution of India, which guarantees the fundamental right to form associations, implying a degree of internal autonomy for such bodies

¶ 34, 39

It examined the Societies Registration Act, 1860, noting that the Act does not grant the State or Courts a supervisory role over the internal functions of a registered society

¶ 37-38

The rules and regulations of a society constitute a binding contract between its members, and any judicial interjection into its governance is impermissible unless strong, cogent reasons, such as malice or bad faith, are proven

¶ 40, 42

Provisions in the judgment · 3 · Linked ones open on LawLens

Societies Registration Act, 1860 Section 3 Section 13 Section 20

04Reasoning

The Court reasoned that AIFF is an autonomous society governed by its own Constitution and Rules

¶ 33

It noted that the learned Single Judge explicitly reached a finding that there was no "malice or mala fide" on the part of the AIFF

¶ 25, 45

In the absence of such findings, the Court held that the Single Judge erred by assuming the functions of the society and eroding its autonomy

¶ 23, 41

The Court found that Respondent No. 1’s primary grievance regarding the original Chairperson’s conflict of interest was already cured by the AIFF through the appointment of Justice (Retd.) Shekhar Dhawan

¶ 43

the existence of an internal Appeal Committee headed by a retired Supreme Court Judge provided sufficient protection against potential bias or influence from the Federation’s President

¶ 44, 46-47

Consequently, there were no "compelling reasons" to justify the Court substituting its choice of members over those appointed via the society’s constitutional process

¶ 49