Mandatory restructuring and fresh elections of National Sports Federations must align with National Sports Governance Act, 2025.

In brief

The question

Whether the continued functioning of the EFI Executive Committee beyond its mandate is legally sustainable following the conclusion of the Paris Olympics 2024.

The court held

The Court held that fresh elections are the "need of the hour" and that the EFI cannot function without a duly elected body under the NSG Act.

It also directed

The Court directed the Indian Olympic Association (IOA) to appoint an Ad-Hoc Committee within seven days to take over EFI administration.

The Ad-Hoc Committee must finalize the EFI Constitution in accordance with the NSG Act within two months and notify elections within thirty days thereafter.

The newly elected body is then mandated to formally ratify and adopt the revised Constitution as its first measure.

The writ petition was disposed of with these directions.

01Facts

The Petitioner challenged the governance structure and electoral framework of the Equestrian Federation of India (EFI), specifically the granting of direct membership and voting rights to individuals and clubs, alleging these actions violated the National Sports Development Code, 2011.

¶ 1-2

The EFI Executive Committee, elected in 2019, had a tenure that expired in September 2023.

¶ 11

However, due to ongoing litigation and the impending Paris Olympics 2024, the Committee continued to function under various interim court arrangements.

¶ 12-15

Following the conclusion of the Olympics and the enactment of the National Sports Governance Act, 2025 (NSG Act), the Union of India sought the appointment of an Ad-Hoc Committee to oversee fresh elections.

¶ 16

02Issues

i.Whether the continued functioning of the EFI Executive Committee beyond its mandate is legally sustainable following the conclusion of the Paris Olympics 2024.

¶ 16, 19

ii.Whether the governance and electoral process of the EFI must be reconstituted to align with the newly enacted National Sports Governance Act, 2025 and the Rules of 2026.

¶ 20-21

03Law Applied

The Court primarily applied the National Sports Governance Act, 2025, specifically Sections 1-3, 4(1), (2), (4), and 5(1), (2), which mandate a statutory framework for the recognition and election of National Sports Federations (NSFs).

¶ 7

It further relied on the National Sports Governance (National Sports Body) Rules, 2026, which operationalized governance standards and institutional accountability.

¶ 6

Additionally, the Court applied the principles of democratic representation established in the National Sports Development Code, 2011, and followed the precedent in *Karnataka Judo Association v. Judo Federation of India* (2026:DHC:1419), which directed the use of Court-appointed Administrators for expeditious elections when elective mandates expire.

¶ 16-17

Provisions in the judgment · 11

National Sports Governance Act, 2025 11 provisions

Section 4Section 1 to 3Section 5Section 8Section 11Section 14Section 15Section 17 toSection 30Section 31Section 33 to 38

04Reasoning

The Court reasoned that the only justification for the EFI Executive Committee's continued operation past its 2023 expiry was the "interim arrangement" necessitated by the Paris Olympics.

¶ 15, 19

Once the event concluded, the "very basis for continuation" vanished.

¶ 16

The Court analyzed the notification dated 31.12.2025, which brought the election-related provisions of the NSG Act into force as of 01.01.2026, creating a mandatory statutory regime.

¶ 7-8

The Court observed that permitting an unelected body to govern in the face of this new legislation would be "inconsistent with both the statutory framework and the principles of democratic representative governance".

¶ 20

Consequently, the Court found that the transition to the new statutory structure required an independent Ad-Hoc body to ensure the EFI's Constitution and By-laws were brought into strict compliance with the NSG Act.

¶ 21

05Holding

The Court held that fresh elections are the "need of the hour" and that the EFI cannot function without a duly elected body under the NSG Act.

¶ 18, 20

The Court directed the Indian Olympic Association (IOA) to appoint an Ad-Hoc Committee within seven days to take over EFI administration.

¶ 21(i)

The Ad-Hoc Committee must finalize the EFI Constitution in accordance with the NSG Act within two months and notify elections within thirty days thereafter.

¶ 21(ii)-(iii)

The newly elected body is then mandated to formally ratify and adopt the revised Constitution as its first measure.

¶ 21(iv)

The writ petition was disposed of with these directions.

¶ 22

LawLens.Delhi High Court

Original Court PDF