Interim orders granting final relief in election disputes through writ jurisdiction are impermissible when statutory arbitration exists.

The appellant, Rajasthan Chess Association, is a State-level sports body registered under the Rajasthan Sports (Registration, Recognition and Regulation of Association) Act, 2005

Respondent No. 1, a former Secretary, filed a writ petition seeking to conclude a pending inquiry against the association and to stall elections

On 25.02.2026, a Single Judge granted liberty to conduct elections but suggested changing the Returning Officer

Elections were subsequently held on 04.03.2026, and the appellant was elected Honorary Secretary

On 13.03.2026, the Single Judge stayed the effect of the election, initiated contempt proceedings against the Returning Officer for not withdrawing, and directed the Registrar to appoint an Administrator

The appellant challenged this interim order via a Special Appeal

1. Whether a Special Appeal (intra-court appeal) is maintainable against an interim order under Rule 134 of the Rajasthan High Court Rules, 1952

2. Whether the High Court can exercise writ jurisdiction under Article 226 of the Constitution to interfere in election disputes of a sports association governed by the Act of 2005

The court applied Rule 134 of the Rajasthan High Court Rules, 1952, which permits appeals from a "judgment" or "final order"

the court applied Sections 13, 16, and 35 of the Rajasthan Sports Act, 2005, which mandate that disputes regarding elections or management be resolved through conciliation and arbitration under the Arbitration and Conciliation Act, 1996

It relied on Shah Babulal Khimji v. Jayaben D. Kania, establishing that interlocutory orders possessing "traits and trappings of finality" are appealable

It further cited Ram Chandra Choudhary v. Roop Nagar Dugdh Utpadak Sahakari Samiti Ltd. [2026 INSC 347] and Zee Telefilms Ltd. v. Union of India, holding that internal electoral processes of societies do not typically attract writ jurisdiction when an efficacious alternate statutory remedy exists

The Division Bench first determined maintainability, reasoning that because the interim order stayed the election results and appointed an Administrator, it effectively granted the final relief sought in the writ, thereby deciding substantial rights and qualifying as an appealable "judgment"

On the merits, the court noted that the Act of 2005 provides a self-contained adjudicatory mechanism for election disputes via arbitration (Section 16) and statutory appeals (Section 35)

The Bench found that the Single Judge exceeded the scope of the writ petition, as the original prayer was largely for the conclusion of an inquiry, not a challenge to the finalized election of 04.03.2026

It observed that allegations of bias or favoritism are factual disputes that must be established through the statutory machinery (arbitration) rather than a writ court, which is not a fact-finding body

It further held that the Single Judge erred in exercising writ jurisdiction over an election dispute that was governed by a specific statutory arbitration mechanism under the Act of 2005

The Division Bench allowed the appeal, set aside the order dated 13.03.2026, and quashed the appointment of the Administrator

Any challenge to the election must proceed through the conciliation and arbitration process provided under Section 16 of the Act of 2005