Principles of natural justice must be read into suspension powers absent express statutory exclusion.

In brief

The question

1. Whether the writ petition is maintainable despite an arbitration clause in the MoA.

The court held

The Court held that natural justice must be read into Clause 11(d) of the MoA.

It also directed

The Court allowed the petition and quashed the Impugned Order dated 28.01.2026, restoring the Petitioner to his post.

The Court appointed Hon’ble Mr. Justice (Retd.) Krishna Murari as a sole Enquiry Authority to investigate the functioning of the TTFI and its office bearers; any further action against the Petitioner is subject to the findings of this newly appointed Authority.

01Facts

The Petitioner, an Olympian and elected Secretary General of the Table Tennis Federation of India (TTFI), challenged an order dated 28.01.2026 passed by the Executive Committee (EC) of the TTFI.

¶ 1-2

The order declared him persona non grata and suspended him pending an inquiry.

¶ 1

The dispute arose following the Petitioner convening a Special General Meeting (SGM) on 17.01.2026 upon the request of 17 State member associations.

¶ 4

At the subsequent EC meeting and Annual General Meeting (AGM) on 28.01.2026, the President moved a resolution for his suspension alleging non-cooperation, financial irregularities, and conflict of interest.

¶ 35-36

The Petitioner was suspended under Clause 11(d) of the Memorandum of Association (MoA) without prior notice or a hearing.

¶ 29-30

02Issues

i.1. Whether the writ petition is maintainable despite an arbitration clause in the MoA.

¶ 10, 14

ii.2. Whether the principles of natural justice (audi alteram partem) are applicable to a suspension and declaration of persona non grata under Clause 11(d) of the MoA.

¶ 19, 28

iii.3. Whether there existed "emergent circumstances" that justified bypassing the requirement of a prior hearing.

¶ 33, 43

iv.4. Whether the constitution of the Enquiry Committee was legally sustainable given its members were part of the EC.

¶ 13

03Law Applied

The Court applied the principles of Natural Justice, asserting that even administrative inquiries must aim at just decisions [AK Kraipak v. Union of India].

¶ 19

The Court relied on the doctrine that rules of natural justice are flexible but a "modicum of residual, core natural justice" must be observed even in interim suspension orders that cause serious prejudice [Liberty Oil Mills v. Union of India].

¶ 21

The Court applied Article 14 of the Constitution to prevent irrational differentiation between similarly situated clauses within the MoA.

¶ 26

Principle from Mohinder Singh Gill v. CEC that an order's validity must be judged by the reasons mentioned therein and cannot be improved by subsequent affidavits.

¶ 31

National Sports Federations (NSFs) perform public functions and must comply with the "law of the land" [Rahul Mehra v. Union of India].

¶ 17

Provisions in the judgment · 2

Memorandum of Association of the Table Tennis Federation of India Section 11Section 14

04Reasoning

The Court rejected the Respondents' plea for arbitration, noting that the transparency of NSFs is a matter of public interest and constitutional oversight.

¶ 17-18

Analyzing Clause 11 of the MoA, the Court found it "irrational" to grant a 14-day notice for suspension under Clause 11(a) while denying it for the more severe persona non grata declaration under Clause 11(d) for the same conduct.

¶ 25-26

The Court reasoned that as an elected representative, the Petitioner’s suspension deprived his constituents of representation, necessitating a hearing.

¶ 22-23

The Court dismissed the "emergency" argument, observing that the SGM actions could have been rectified through democratic voting at the AGM rather than unilateral suspension.

¶ 37-38

The Court noted that the Enquiry Committee was ex-facie unsustainable as its members were also part of the EC that passed the suspension order.

¶ 13