National Sports Federation’s General Council remains functional despite government suspension of executive day-to-day activities.

The Petitioner, a registered trust affiliated with the Wrestling Federation of India (WFI) since 1960, challenged the WFI's order dated 18/04/2023 disaffiliating it and the subsequent grant of affiliation to Respondent No. 5 (Maharashtra Rajya Kustigir Sangh).

This followed a prior attempt by WFI to dissolve the Petitioner in 2022, which was quashed by the High Court.

WFI subsequently issued a show-cause notice alleging financial embezzlement, failure to host national competitions, and age-fudging by wrestlers.

On 21/01/2023, the Ministry of Sports suspended "all activities" of WFI and appointed an Oversight Committee following allegations of sexual harassment against the WFI President.

The Petitioner argued that during this suspension, WFI lacked the authority to pass the disaffiliation order.

The Returning Officer also rejected the Petitioner’s claim to nominate members for the WFI electoral college on 21/07/2023.

1. Whether a Writ Petition under Article 226 of the Constitution is maintainable against the Wrestling Federation of India (WFI).

2. Whether the General Council of WFI stood suspended by the Ministry’s order dated 21/01/2023, thereby vitiating the disaffiliation order.

3. Whether the disaffiliation of the Petitioner and affiliation of Respondent No. 5 were arbitrary or in violation of natural justice.

The court primarily applied the principles of judicial review over private bodies performing public functions as established in BCCI v. Cricket Association of Bihar, holding that while such bodies may not be "State" under Article 12, they are amenable to Article 226 if they discharge public duties.

It relied on Zee Telefilms Ltd. v. Union of India to distinguish between Article 32 and Article 226 maintainability.

Regarding administrative law, the court applied the doctrine that ratification by a superior body (General Council) can cure procedural defects in a sub-committee’s recommendation, as seen in Maharashtra State Mining Corporation v. Sunil.

Article XXVI of the WFI Constitution provided the specific grounds for disaffiliation.

The court first determined that WFI performs public functions (selecting national teams, representing India in Olympics), making it amenable to writ jurisdiction despite being a private society.

On the merits, the court rejected the Petitioner’s claim that WFI was "non-existent" during the Ministry's suspension. It interpreted the Ministry’s orders as suspending only the "Executive Committee" and "day-to-day" operational activities, not the "General Council," which is a permanent policy-making body.

The court found that the General Council acted within its competence under the WFI Constitution.

Regarding the disaffiliation process, the court found no violation of natural justice, as a show-cause notice was issued and the Petitioner's Secretary, Mr. Landge, responded and participated in the disciplinary proceedings.

The court noted grave findings of financial embezzlement and misuse of WFI's name by the Petitioner’s Secretary, which provided a substantive basis for disaffiliation.

The court observed that the General Council had ratified the decision on 21/12/2023, and this ratification remained unchallenged.

It directy answered that the General Council was never suspended and possessed the authority to disaffiliate the Petitioner.

The court upheld the disaffiliation order dated 18/04/2023 and the Returning Officer’s order dated 21/07/2023, finding them non-arbitrary and based on substantial evidence of misconduct.

The prayer to disaffiliate Respondent No. 5 was rejected as it had secured the necessary affiliations. Rule discharged; all interim applications disposed of.