Court Cannot Interfere with Autonomy of Registered Societies or Reconstitute Domestic Committees Without Findings of Malice

Respondent No. 1 (Churchill Brothers) filed writ petitions seeking the constitution of an independent committee to adjudicate its representations dated 16.01.2026 and 14.03.2026, alleging conflict of interest within the Appellant’s (AIFF) Ethics Committee.

Initially, the AIFF replaced the contested Chairperson with a retired High Court Judge and inducted a practicing advocate to address these concerns.

Despite this, a learned Single Judge of the Delhi High Court passed an order on 01.04.2026, further reconstituting the Ethics Committee by appointing a different retired Judge as Chairperson and adding specific external members.

The AIFF challenged this order, asserting it unconstitutionally interfered with the autonomy of a registered society.

1. Whether the Court can interfere with and reorganize the internal judicial bodies of a registered society when the society has acted in accordance with its own Constitution.

2. Whether the Single Judge was legally justified in reconstituting the Ethics Committee in the absence of a finding of malice or mala fides.

The Court applied Article 19(1)(c) of the Constitution of India, which guarantees the fundamental right to form associations, establishing that societies enjoy autonomy in their internal affairs.

It relied on the framework of the Societies Registration Act, 1860, noting that the Act does not grant the State or the Registrar a supervisory role over a society’s internal functions.

The legal principle established is that the rules and regulations of a society constitute a contract between its members, and judicial interference via writ jurisdiction under Article 226 is only permissible under "very strong and cogent reasons" or statutory permit.

The Court reasoned that AIFF is an autonomous society governed by its own Constitution, which prescribes the appointment of judicial bodies.

The Bench noted that the Single Judge specifically found an absence of malice or mala fides on the part of the Appellant.

Since the AIFF had already voluntarily allayed Respondent No. 1’s apprehensions by replacing the contested Chairperson with a retired High Court Judge, the Court held that further judicial interjection was an unwarranted erosion of the society’s autonomy.

The Court observed that the presence of an Appeal Committee chaired by a retired Supreme Court Judge provided sufficient protection against bias, making the judicial reconstitution of the Ethics Committee legally impermissible.

The Division Bench set aside the Single Judge’s order dated 01.04.2026 and directed the AIFF-reconstituted Ethics Committee to decide the Respondent’s representations in accordance with the law, ensuring an opportunity for a hearing, within eight weeks, allowing the appeals with no order as to costs.