National Sports Development Code is mandatory for all constituents and state-level affiliates of National Sports Federations.

The Appellant, a registered society and former member of Respondent No. 1 (KKFI), was de-affiliated in January 2020 based on an alleged dissolution letter from its then-President.

Following a challenge to this de-affiliation in W.P.(C) 863/2021, the Delhi High Court appointed a retired Judge as a Returning Officer (RO) to conduct fresh elections.

The RO conducted elections on 27.10.2021 based on "Model Election Guidelines," erroneously excluding the "National Sports Development Code, 2011" (Sports Code) after relying on a non-existent Orissa High Court order cited by a party.

The KKFI refused to recognize the results, citing violations of the Sports Code. The Appellant’s subsequent writ petition challenging this non-recognition was dismissed by a Single Judge, leading to this intra-court appeal.

1. Whether the National Sports Development Code, 2011, applies to State-level sports associations like the Appellant.

2. Whether the principles laid down in Rahul Mehra v. Union of India regarding the Sports Code apply retrospectively to elections concluded before the judgment date.

3. Whether the KKFI was barred by estoppel or res judicata from challenging the election results due to its prior withdrawal of applications in related proceedings.

The Court primarily applied the National Sports Development Code, 2011, which regulates the governance and elective structures of National Sports Federations (NSFs) and their constituents.

It relied on the precedent set in Rahul Mehra v. Union of India & Ors. (2022) and K.P. Rao v. Union of India & Ors. (2023), which established that the Sports Code must be made applicable to every constituent (including State and District associations) of an NSF to ensure fair play and eligibility for government facilities.

Additionally, it considered the Ministry of Youth Affairs and Sports letter dated 30.12.2020 regarding the tenure and eligibility of government employees in sports bodies.

The Court reasoned that the legal position regarding the Sports Code is clarificatory; thus, the Appellant's argument against "retrospective application" fails because the Code was always applicable to NSF constituents.

The RO’s election process was fundamentally flawed because it was predicated on a fraudulent/non-existent court order, leading to the exclusion of the Sports Code’s eligibility criteria.

Factually, six elected office bearers were government employees who exceeded the permissible tenure under the Code, and the creation of the post of "Chairman" was an "innovative nomenclature" previously deprecated by the court.

Regarding estoppel, the Court found that KKFI had specifically sought (and was granted) liberty to raise objections at the appropriate stage when it withdrew its earlier application, and its initial consent to hold elections did not imply consent to recognize results that violated the law.

The Court held that the elections held on 27.10.2021 were invalid as they bypassed mandatory eligibility norms and were conducted under a mistaken legal premise. The Appeal was dismissed, affirming the Single Judge's judgment, while granting the Appellant liberty to pursue separate evidentiary remedies regarding its allegations of fraudulent de-affiliation.