Membership in the Indian Olympic Association does not constitute recognition as a National Sports Federation under the National Sports Code.

The review petitioner (Ski and Snowboard India) challenged an order dated 13.10.2023, by which the Indian Olympic Association (IOA) formed an Ad Hoc Committee to manage the petitioner’s affairs

A Single Judge set aside the formation of the committee and appointed a Returning Officer (RO) to conduct elections, directing IOA to pay the RO's fee

On appeal, the Division Bench upheld the dissolution of the committee but modified the order, directing the petitioner (as an independent society) to bear the RO's fee instead of the IOA

The petitioner sought a review of this judgment, arguing that the court erred in finding that the petitioner was not a recognized National Sports Federation (NSF)

1. Whether there exists any error apparent on the face of the record regarding the legal status of the petitioner as a National Sports Federation

2. Whether affiliation with the Indian Olympic Association (IOA) under its Memorandum and Rules equates to recognition as a National Sports Federation under Indian law

The Court primarily applied the National Sports Development Code of India, 2011 (“Sports Code, 2011”), specifically Clause 8 and Annexure-2, which establish the exclusive criteria and procedures for recognition as a National Sports Federation

The Court also interpreted Clause 3 of the Memorandum and Rules and Regulations of the Indian Olympic Association regarding membership eligibility

It noted that the legal regime for such recognition is now transitioned to the National Sports Governance Act, 2025

The Court rejected the petitioner’s contention that it held NSF status by virtue of being an affiliated body of the IOA. The Court reasoned that prior to the 2025 Act, the Sports Code, 2011 was the sole instrument governing the recognition of sports bodies as NSFs

Upon reviewing Clause 3 of the IOA’s Memorandum, the Court clarified that this clause merely defines eligibility for IOA membership and does not confer the legal status of a "National Sports Federation"

The Court found the petitioner's argument—that there are two types of NSFs (those recognized by the Government and those by the IOA)—to be "absolutely misconceived" because the IOA's internal membership rules cannot override the statutory/regulatory requirements of the National Sports Code

Consequently, since the petitioner failed to show recognition under the 2011 Code, there was no error in the original judgment

The Court affirmed that membership in the IOA does not constitute recognition as a National Sports Federation

The review petition was dismissed with costs of Rs. 10,000/- to be deposited with the Delhi High Court Bar Clerk’s Association