Delhi High Court

Court Mandates Collaborative Constitutional Amendment and Fresh Elections for National Sports Federation to Ensure Statutory Compliance

All India Tennis Association vs Somdev Kishore Devvarman & Ors.

Delhi High CourtJUDGMENT: June 18, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellants in both matters challenged a Single Judge’s judgment dated 27.04.2026.

Source reference: p.1

The original dispute arose from a Writ Petition alleging that the All India Tennis Association (AITA) elections held on 28.09.2024 violated the National Sports Development Code of India, 2011 ("Sports Code").

Source reference: para. 5

The Single Judge appointed Justice (Retd.) Gita Mittal as Administrator to amend the AITA Constitution and oversee affairs, while simultaneously allowing the newly elected body to function as an "Interim Executive Committee".

Source reference: para. 9

AITA challenged the appointment and wide powers of the Administrator.

Source reference: para. 2

Mr. Devvarman challenged the recognition of the elected committee, alleging members were disqualified under age and tenure norms.

Source reference: para. 3, 11.5

During the appeal, the International Tennis Federation (ITF) signaled that prolonged administrator-led regimes could lead to derecognition of the AITA.

Source reference: para. 12.1
02

Issues

1. Whether the appointment of an Administrator with powers to amend the Constitution and manage finances was valid absent an adjudication on the illegality of the AITA elections.

Source reference: para. 10.1

2. Whether the Interim Executive Committee could continue to function despite allegations of non-compliance with age, tenure, and cooling-off requirements of the Sports Act and Sports Code.

Source reference: para. 11.5, 11.7

3. Whether the court should modify the administrative structure to ensure compliance with the National Sports Governance Act, 2025, while avoiding international derecognition.

Source reference: para. 15, 20
03

Law Applied

The Court considered the National Sports Development Code of India, 2011 and the recently enacted National Sports Governance Act, 2025 ("Sports Act") and the Rules thereunder (2026).

Source reference: para. 4, 9

It acknowledged the principle of institutional autonomy for societies registered under the Societies Registration Act, 1860.

Source reference: para. 10.2

It referred to Rahul Mehra v. Union of India regarding the mandatory nature of the Sports Code for National Sports Federations.

Source reference: para. 5

It further noted the precedent in All India Football Federation v. Rahul Mehra, where the Supreme Court emphasized that sporting bodies discharge public functions but cautioned against court-appointed administrators triggering international sanctions.

Source reference: para. 11.8
04

Reasoning

The Court avoided a merits-based adjudication on the validity of the 2024 elections, choosing instead a pragmatic "workable arrangement" due to the 30.06.2026 statutory deadline for amending NSF constitutions under the Sports Act.

Source reference: para. 15-17

The Court balanced the need for legal compliance (pushed by the Respondents) with the threat of international suspension by the ITF (highlighted by AITA and UoI).

Source reference: para. 12.1, 12.3

By allowing the Interim Executive Committee to submit objections to the Administrator's draft amendments, the Court integrated the democratic process of a registered society with judicial oversight.

Source reference: 20(ii)

The Court dispensed with notice periods to meet statutory timelines, ensuring that the final "Sports Act-compliant" Constitution would be the basis for fresh, undisputed elections.

Source reference: para. 20(v), 20(vii)
05

Holding

The Court modified the Impugned Judgment.

(i) AITA Interim Committee must submit suggestions to the Administrator’s draft by 25.06.2026; (ii) The Administrator must afford a hearing and finalize a consolidated draft by 15.07.2026; (iii) An EGM must be held by 31.07.2026 to vote on the amendments; (iv) Fresh elections must be conducted by 30.09.2026. All EGM outcomes remain subject to the final result of these Appeals.

Source reference: para. 20(i)-(vii), 22
Delhi High Court

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All India Tennis AssociationvsSomdev Kishore Devvarman & Ors.

Delhi High Court · June 18, 2026

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