Writ Courts cannot order roving enquiries into internal management of National Sports Federations absent exceptional circumstances.

The Table Tennis Federation of India (Appellant/TTFI) conducted elections on 05.12.2022, resulting in the election of Ms. Meghna Ahlawat as President and Mr. Kamlesh Mehta (Respondent No. 1) as Secretary General

Following internal disputes and a Special General Meeting held on 17.01.2026, the TTFI Executive Committee passed a Resolution on 28.01.2026 declaring Respondent No. 1 persona non-grata and suspending him pending an internal enquiry

On 11.05.2026, a Single Judge set aside the suspension, finding a violation of natural justice, and appointed a retired Supreme Court Judge as an "Enquiry Authority" to investigate the conduct of the entire Federation and its office bearers

The TTFI filed this intra-court appeal challenging the scope of that intervention.

1. Whether the principles of natural justice can be read into Clause 11(d) of the MoA, which does not explicitly provide for a pre-decisional hearing

2. Whether the High Court, in the exercise of its writ jurisdiction, was justified in appointing an Enquiry Authority to conduct a broad investigation into the general affairs and office bearers of a National Sports Federation (NSF)

the Court applied the principle that while societies registered under the Societies Registration Act, 1860, are bound by their regulations, writ jurisdiction under Article 226 is limited when the body is not performing public functions like team selection

It relied on the doctrine established in Ajay Jadeja v. Union of India (2002) that internal management and disciplinary matters of an NSF are generally not amenable to writ jurisdiction

Regarding administrative law, the court applied the principle that natural justice (audi alteram partem) should be read into regulations unless expressly excluded

the principle that a court should not grant relief (such as a roving inquiry) that was not prayed for by the petitioner

The Court agreed with the Single Judge that Clause 11(d) of the MoA did not explicitly exclude natural justice; therefore, suspending an elected official without a hearing was procedural lapse

However, the Bench found that the Single Judge exceeded his jurisdiction by appointing an Enquiry Authority to investigate the entire Federation's "conduct and functioning."

The Court reasoned that judicial interference in the internal management of an autonomous society is only permissible in "extremely exceptional circumstances"

Since the original Writ Petition did not pray for a general inquiry and the affected office bearers were not parties to the litigation, the direction for a broad "roving and fishing exercise" violated basic procedural fairness

The Court concluded that any inquiry must be narrowly tailored to specific misconduct rather than a general audit of the society’s governance

it set aside the direction for a general enquiry into the Federation’s affairs and office bearers

The Court held that while the court-appointed Enquiry Authority (Justice Krishna Murari) would remain, his mandate is strictly limited to inquiring into the specific allegations against Respondent No. 1, should the TTFI choose to proceed with a fresh, hearing-inclusive disciplinary process

All other merits of the dispute remain open for appropriate legal proceedings