Sports federation’s recognition cannot be deemed withdrawn without notice and hearing, Delhi HC rules; AICF allowed to retain “India” in its name

The All India Carrom Federation (“AICF”), a society claiming to be the National Sporting Federation for carrom and affiliated with the International Carrom Federation, challenged the common order dated 29.10.2025 passed by the learned Single Judge in proceedings instituted by the Maharashtra Carrom Association (“MCA”), Union Territory Pondicherry Carrom Association (“PCA”) and another petitioner.

The Single Judge directed AICF to delete “India” from its name, logo and competitions, permitted it only to describe a team as a “Team from India”, and directed it to seek fresh recognition from the Union of India (“UOI”).

AICF’s 2023 election had been conducted on 27.08.2023 and its report was submitted to the Ministry on 30.08.2023.

Following directions issued during the appeal, the Ministry first rejected the election on 06.02.2026 and, after the order was treated as a show-cause notice and AICF was given an opportunity to respond, passed a fresh order dated 10.07.2026 refusing to take the election on record or renew AICF’s annual recognition.

That order was separately challenged by AICF in W.P. (C) No. 10610/2026, which remained pending.

1. Whether non-renewal of AICF’s annual recognition, without a formal order of suspension or withdrawal following the procedure prescribed under Annexure III of the Sports Code, resulted in its automatic de-recognition as an NSF.

2. Whether the UOI/Ministry could direct AICF, an existing sports federation, to remove the expressions “India” or “Indian” from its name, logo and competitions in the absence of a valid order suspending or withdrawing its recognition.

3. Whether the subsequent Ministry order dated 10.07.2026 affected the adjudication of the present appeals.

The Court applied Annexure III of the Sports Code, which requires suspension or withdrawal of recognition of an NSF to follow a prescribed procedure, including notice, an opportunity of hearing, a reasoned determination and a consequential order.

It relied on Union of India v. Taekwondo Federation of India & Anr., LPA 5/2026, for the principle that recognition cannot be treated as automatically withdrawn or deemed extinguished merely because annual recognition has not been renewed; de-recognition must result from a positive administrative act complying with natural justice.

The Court also considered Clause 3.6(2) of the Sports Code and the Ministry’s communications concerning use of “India” or “Indian”, but held that those restrictions could not be applied on the premise of de-recognition where no valid suspension or withdrawal had occurred.

Compliance with the National Sports Governance Act, 2025 and the National Sports Governance Rules, 2026 remained mandatory for future recognition.

The Court found that the Ministry’s letter dated 07.12.2020 merely recorded an objection concerning AICF’s alleged violation of the One State One Unit principle under Clause 3.10 of the Sports Code.

It did not initiate or conclude proceedings under Annexure III, did not provide a notice or hearing, and did not contain a reasoned determination that AICF’s recognition stood suspended or withdrawn.

Applying the principle in Taekwondo Federation, the Court held that non-renewal of annual recognition could not, by itself, establish automatic or deemed de-recognition.

The Single Judge had therefore proceeded on an unsustainable premise in treating AICF as having ceased to be an NSF and restraining it from using “India” or “Indian”.

The Court noted that the Ministry had subsequently considered AICF’s response and passed the order dated 10.07.2026.

Since that order was the subject of a separate pending writ petition, its legality and effect could not be determined in the present appeals and had to be examined independently by the learned Single Judge.

The Court nevertheless clarified that setting aside the impugned order did not exempt AICF from complying with the NSG Act and NSG Rules as a condition for recognition.

Consequently, the direction requiring AICF to remove “India” or “Indian” from its name, logo and competitions was unsustainable.

LPA 697/2025 filed by AICF was allowed and the impugned order dated 29.10.2025 was set aside.

The connected appeals filed by MCA and PCA, being LPA 739/2025 and LPA 744/2025, were dismissed.

The Court expressly declined to rule on the merits of the Ministry’s order dated 10.07.2026, leaving W.P. (C) No. 10610/2026 to be decided independently. All pending applications were disposed of, with no order as to costs.