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

In brief

The question

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.

The court held

The Court modified the Impugned Judgment.

It also directed

(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.

01Facts

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

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").

¶ 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".

¶ 9

AITA challenged the appointment and wide powers of the Administrator.

¶ 2

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

¶ 3, 11.5

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

¶ 12.1

02Issues

i.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.

¶ 10.1

ii.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.

¶ 11.5, 11.7

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

¶ 15, 20

03Law 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).

¶ 4, 9

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

¶ 10.2

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

¶ 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.

¶ 11.8

Provisions in the judgment · 2

National Sports Development Code of India, 2011 Section 4

National Sports Governance (National Sports Bodies) Rules, 2026 Section 5, 6, 8

04Reasoning

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.

¶ 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).

¶ 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.

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.

¶ 20(v), 20(vii)