National Sports Federations must constitute Athletes’ Commissions in accordance with international body regulations.

In brief

The question

Whether the Volleyball Federation of India (VFI) is legally obligated to adopt and implement the Athletes’ Commission regulations prescribed by the international governing body (FIVB) and the IOA rather than its own internal bye-laws?

The court held

The court held that the VFI must adopt the regulations forwarded by the FIVB for setting up the Athletes’ Commission

It also directed

It directed the VFI to constitute the Commission and hold elections in accordance with these international regulations within six weeks

To ensure transparency and fairness, the court further ordered the Union of India and the IOA to appoint observers for the election process

The matter was listed for remaining reliefs on July 20, 2026

01Facts

The petitioner, an Arjuna Awardee and former national volleyball player, sought directions to the Indian Olympic Association (IOA) and the Volleyball Federation of India (VFI) to conduct elections for the VFI Athletes’ Commission in accordance with the regulations approved by the Fédération Internationale de Volleyball (FIVB)

pp. 1-2, para 1-2

Following court-ordered interim elections for the VFI in May 2025, the VFI claimed to have constituted an Athletes’ Commission consisting of eight members (four elected and four nominated by the VFI Executive Committee)

pp. 2, para 3-5

The petitioner challenged this, alleging that the VFI bypassed the specific "Athletes’ Commission Regulations 2025" communicated by the FIVB to the IOA on July 5, 2025

pp. 2-3, para 6-7

Subsequent communications from the FIVB in March 2026 confirmed that VFI’s provisional recognition was contingent upon establishing the Commission as per the joint FIVB-IOA guidelines

pp. 5-7, para 16-18

02Issues

i.Whether the Volleyball Federation of India (VFI) is legally obligated to adopt and implement the Athletes’ Commission regulations prescribed by the international governing body (FIVB) and the IOA rather than its own internal bye-laws?

pp. 8, para 20-23

03Law Applied

Section 15 of the National Sports Governance Act, 2025, which mandates that National Sports Organisations must adhere to the rules, regulations, and bye-laws of their respective international sports bodies

p. 8, para 21

Principle of international sports hierarchy, establishing that National Sports Federations (NSFs) must comply with International Federation (IF) standards to ensure the eligibility of national athletes for international events like the Olympics and Asian Games

pp. 8, para 21-22

Provisions in the judgment · 1

National Sports Governance Act, 2025 Section 15

04Reasoning

The court performed a comparative analysis between the VFI’s internal bye-laws and the FIVB Athletes’ Commission Regulations 2025.

pp. 3-5, para 13-15

It noted significant discrepancies: the VFI rules restricted eligibility to athletes active within the last eight years and required nominations through state units, whereas the FIVB regulations emphasized a tier-wise selection of "sportspersons of outstanding merit" (such as Arjuna Awardees or Olympic medalists) independent of federation-controlled nomination structures

pp. 3-5, para 13-15

The court observed that the FIVB had explicitly conditioned the VFI’s provisional recognition on compliance with the July 5, 2025 communication

pp. 5-6, para 16

It reasoned that since the FIVB is the international regulatory authority and the IOA is the apex domestic body for Olympic sports, the VFI had no plausible justification for bypassing their directives

p. 8, para 22

Furthermore, failure to comply would jeopardize the participation of Indian athletes in international competitions

p. 8, para 21