Holding

The Supreme Court approved the draft AIFF Constitution with the specified modifications, ordered its adoption, and confirmed that the current AIFF executive constitutes a permanent body subject to the Constitution and applicable statutes.

Summary

The Supreme Court examined a series of challenges to the draft Constitution of the All India Football Federation (AIFF) raised by Rahul Mehra and other stakeholders, focusing on issues such as the inclusion and eligibility of eminent players, the definition of office‑bearers, the number of vice‑presidents, disqualification criteria for public servants, conflict of interest provisions, and the applicability of the Constitution to state associations. The Court interpreted the National Sports Development Code of India, 2011 and FIFA statutes, holding that the inclusion of eminent players with voting rights is permissible and that the eligibility criteria should be reduced to five international matches for men and two for women. It affirmed that office‑bearers may include vice‑presidents, accepted a three‑vice‑president structure with one woman, and aligned disqualification provisions with BCCI precedents, limiting disqualification of public servants to ministers and government servants. The Court also upheld the applicability of the AIFF Constitution to state associations, rejected the removal of indirect interest from conflict‑of‑interest definitions, and endorsed the draft Constitution with specific modifications, ordering its adoption and treating the current AIFF executive as a permanent body subject to statutory limits.

Issues considered

Should eminent players be included in the AIFF General Body and to what extent?
What eligibility criteria should designate an eminent player?
Should the term “office‑bearers” be limited to President, Treasurer, and Secretary?
Should the number of Vice‑Presidents be increased to ensure regional representation?
Should public servants be included under disqualification events?
Should ‘indirect interest’ be retained in the definition of conflict of interest?
Should the AIFF Constitution apply to state associations?
What is the permissible extent of delegation of powers, functions, and exploitation of rights by AIFF to third parties?
Should promotion and relegation be part of the AIFF Constitution?
To what extent are BCCI judgments applicable to football governance?
Should amendments to the AIFF Constitution be approved by the Supreme Court?
Is the current AIFF administration a permanent or interim body?

Legislation cited

Constitution of India
FIFA Statute, 2024
FIFA Statutes, 2022
Indian Penal Code, 1860s. Section 21
National Sports Development Code of India, 2011
National Sports Governance Act, 2025s. Section 4(1)(b), s. Section 4(2), s. Section 4(2)(e)
Representation of the People’s Act, 1951

Headnote

Issue for Consideration Should Eminent Players be in the General Body; if so, to what extent; what should be the Eligibility criteria to be designated an Eminent Player; whether ‘Office bearers’ should be limited to President, Treasurer, Secretary; whether the number of to ensure regional representation; whether public servants should be included under disqualification events; whether ‘indirect interest’ should be retained in the definition of ‘conflict of interest’; should the All India Football Federation (AIFF) Constitution apply

Subjects

All India Football FederationDraft of the Constitution of All India Football FederationDraft of the Constitution of AIFFAIFF ConstitutionEminent playersSports federationsAIFF’s electionCommittee of Administrators (CoA)National Sports Federation (NSFs)FIFAContinuous monitoring of a sports federationConstitution of AIFF, 2017

Judgment

[2025] 9 S.C.R. 1146 : 2025 INSC 1131

All India Football Federation
v.
Rahul Mehra & Ors.
(Civil Appeal No(s). 12591-12592 of 2025)
19 September 2025
[Pamidighantam Sri Narasimha and Joymalya Bagchi, JJ.]

Issue for Consideration
Should Eminent Players be in the General Body; if so, to what
extent; what should be the Eligibility criteria to be designated
an Eminent Player; whether ‘Office bearers’ should be limited
to President, Treasurer, Secretary; whether the number of VPs
should be increased to ensure regional representation; whether
public servants should be included under disqualification events;
whether ‘indirect interest’ should be retained in the definition of
‘conflict of interest’; should the All India Football Federation (AIFF)
Constitution apply to state associations; what is the permissible
extent of delegation of powers, functions, and exploitation of
rights by AIFF to third parties; whether promotion and relegation
should form part of the AIFF Constitution; to what extent are
BCCI judgements applicable to football; should Amendments to
the Constitution be approved by the Supreme Court; whether the
current AIFF administration is a permanent or interim body.

Headnotes†
Sports – National Sports Development Code of India, 2011 –
Draft Constitution of the appellant-Federation (AIFF) –
Objections and suggestions from relevant stakeholders – Draft
approved and finalised, with few modifications – AIFF to call for
a special general body meeting and adopt the draft Constitution
with the modifications, preferably within 4 weeks – National
Sports Governance Act, 2025. [Paras 24-122]

Sports – Should Eminent Players be in the General Body, to
what extent – National Sports Development Code of India,
2011 – Clauses 3.9, 3.10 or 3.20:
Held: 1.1 A harmonious and conjoint reading of clauses 3.9, 3.10 or
3.20 show that clause 3.20 is essentially a carve-out from clauses
3.9 or 3.10, and grants voting rights to the class of persons indicated
[2025] 9 S.C.R. 1147

All India Football Federation v. Rahul Mehra & Ors.

therein, i.e., “prominent sportspersons of outstanding merit” – The
substantive composition of the organisational structure should
consist of member associations, and it is contemplated to be an
ideal situation to have eminent sportspersons having voting rights –
The percentage indicated in clause 3.20 of the NSC 2011 is not
transgressed by clause 20.2 of the draft Constitution. [Para 33]
1.2 The freedom of choice to form an association is not in any
way compromised by the requirement to incorporate 15 eminent
players – The democratic setup of the federation is not destabilised
as the elected member associates certainly continue to hold more
than 62% as the NSC 2011 u/clause 3.20 only suggests that the
number of prominent sportspersons should be a minimum of 25%
which means that model provision has not prohibited a number
larger than 25% – The inclusion of eminent players, coaches,
referees, and club representatives in the general body, will only
further good governance, herald transparency and fair play – The
draft provision not interfered with. [Paras 35, 36]

Sports – Eligibility criteria for Eminent Players – Article 1.19
of the draft Constitution:
Held: The draft Constitution prescribed a criterion – It is reasonable
to reduce the eligibility criteria for an Eminent Player suggested
by Justice L N Rao, to 5 matches for men and from 2 matches
for women – Such modification will ensure a wider pool and
participation by retired players who will prove themselves to be
efficient administrators and guiding lights for Indian football –
Submission of AIFF qua counting domestic experience for eminence
status, not accepted – Domestic experience might not yield the
result sought to be achieved with the adoption of the Constitution,
which is formulated to project Indian football on the international
panorama. [Para 40]

Sports – Whether ‘Office bearers’ should be limited to
President, Treasurer, Secretary – Definition of “Office-Bearers”:
Held: Office bearers must be understood in the context of the
functioning of the AIFF and the reform that needs to be brought
about – This definition will have a direct bearing on the applicability
of cooling-off, the term, tenure and age limit – The inclusive definition
will be consistent with the reforms that have been introduced and
applied as independent measures for the vibrant working of the
federation. [Para 42]
1148 [2025] 9 S.C.R.

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Sports – Whether the number of Vice-Presidents (VPs) should
be increased to ensure regional representation – Number of
VPs:
Held: No harm is caused by exceeding the membership of the
executive committee – Both Committee of Administrators (CoA)
and Justice L N Rao have taken into account the NSC 2011 and
balanced it with the demands of the sport – Order of this Court dtd.
22.08.2022 provided that the EC of the federation will consist of
23 persons as an arrangement at that time, a higher number than
the 12-person committee – Therefore, the size of the executive
committee not reduced – The suggestion(s) made by the State
Associations to increase the number of VPs to five would not be
possible in the present statutory scheme – However, the argument
of AIFF for increase in the number of VPs to 3, which shall include
one woman, is accepted – Such an amendment will enable women’s
representation and, at the same time, confine the number of the
executive committee to fifteen members. [Paras 45, 47]

Sports – Public servants, if to be included under disqualification
events – Article 1.17 of the amended Constitution by Justice
L N Rao:
Held: The provision of disqualification based on framing of charge
is modified to the standard as envisaged in the later judgement of
BCCI i.e., “conviction followed by a sentence of imprisonment” –
Further, an amendment was passed by the BCCI which was
approved by this Court, restricting the disqualification from being
a “minister or government servant or holding a public office” to
being “a minister or government servant” – In agreement with the
view of BCCI, the provision in Article 1.17(g) modified to “being
a minister or government servant” – Furthermore, even if such a
person is a public servant, if he or she has the necessary approval
of the government, there should not be a problem u/s.4(2)(e)
of the newly enacted NGSA 2025 – The rules and regulations
applicable to a government servant provide a particular standard
to be maintained – The standard requires the public servant to
obtain necessary permissions – If these permissions are taken,
there is no justification to restrict or disqualify a public servant
altogether. [Paras 55, 58, 59]

Sports – Whether ‘indirect interest’ should be retained in
the definition of ‘conflict of interest’ – AIFF submitted that
[2025] 9 S.C.R. 1149

All India Football Federation v. Rahul Mehra & Ors.

a conflict of interest, as defined in Article 73.1, should not
include indirect interest – It contended that while Article
73.5 adequately covers the scenarios of conflict, it renders
Article 73.1 otiose and unnecessary – Plea of Amici that the
suggestion of AIFF does not take into account that Articles
73.1(a) and 73.5 cover entirely different fields:
Held: Art.73.1(a) is focused on indirect conflicts of interest, conflicts
through relatives, partners, or close associates; conflicts like an
Executive Committee Member’s spouse running a football coaching
academy – Whereas, Art.73.5 broadly prohibits the individual from
holding two posts - a more direct conflict - and does not speak of his
interest through related parties – On plain reading of both Arts.73.1
and 73.5, it is clear that both cover different fields of conflict – The
judgment in BCCI has also approved of disqualifications based on
indirect conflicts – No reason to arrive at a different conclusion.
[Para 63]

Sports – Applicability of AIFF Constitution to State Associations:
Held: In view of the chequered history of Indian football
administration, and also that governance of football trickles down
from the superstructure to the base, i.e., National Sports Federations
(NSFs) conform to FIFA, it is important that the state associations
and local bodies conform to the NSFs – First, the office bearer(s) of
the state association will acquire with time an invaluable experience
of football governance in the same manner as the institutional history
of the AIFF – This will happen because the governance model of
both the NSF and state associations will overlap – Compliance
and application of best practices formulated in consultation with
FIFA at the local levels will ensure that the sport of football
remains organised, both in principle and in practice – In view of
the FIFA Statute, the relevant comments of Justice L N Rao and
on analysis of the far-reaching implications of this provision, the
argument that the AIFF Constitution ought not be extended to the
state associations and local bodies, not accepted. [Paras 70, 71]

Sports – Delegation of powers, functions, and exploitation of
rights by AIFF to third parties – Permissible extent of – Football
Sports Development Limited (FSDL) suggested few changes
to the proposed Constitution namely, a relevant amendment
to Art.1.21 to make the definition of ‘essential aspects’ less
1150 [2025] 9 S.C.R.

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restrictive; an amendment to Art.63 to expand the role of private
parties in exploitation of rights under sports’ contracts and;
also submitted that ‘promotion and relegation’ should not be
a criteria to satisfy the definition of ‘seniormost top division
league’, as defined under Art.1.54:
Held: Though there was agreement at the bar on FSDL’s
suggestions on the addition of the word ‘ownership’ in Article
63.1, the expression is superfluous and unnecessary – AIFF has
objections to the use of the word ‘organisation’ and ‘promotion and
relegation’ in the definition of essential aspects u/Art.1.21 – Art.1.21
which had no equivalent in the Constitution drafted by the CoA,
is in the nature of a membrane separating the rights and duties
of the federation and third parties with whom the federation might
enter into contract(s) – It does not create any harm to the private
interest, except for the fact that it will impact the working of the
text of the Master Rights Agreement (MRA) – While this Court is
satisfied with the provision u/Art.1.21, and it has been apprised
that the term of the ongoing extended MRA will expire in 2025, it
is made clear that it shall be open for the federation to enter into
contractual settings, but in complete obedience to the boundary
as laid down in Art.1.21 – FSDL’s suggestions qua Art.63 as well,
which are premised and expand upon the definitional clause in
Art.1.21, not adopted. [Para 79]

Sports – Whether promotion and relegation should form part
of the AIFF Constitution:
Held: After going through the literature on the principles of promotion
and relegation, the arguments of the counsels, as well as the written
material placed on record, it is held that the proposed provisions
do not necessitate any amendment. [Para 87]

Sports – Applicability of principles laid down in BCCI Judgment
to the present case concerning football administration:
Held: The BCCI series of cases envisaged and embarked on a new
dawn of Indian sports governance, and also developed principles
and best practices which can be imbibed in letter and spirit –
Distinguishing BCCI judgments only on the ground that BCCI is not
an NSF, while AIFF is, does not yield any good –The arguments
advanced by AIFF and State association are rejected. [Paras 88, 90]
[2025] 9 S.C.R. 1151

All India Football Federation v. Rahul Mehra & Ors.

Sports – Amendments to the AIFF Constitution, if should be
approved by the Supreme Court and the need for the Supreme
Court to retain control:
Held: The suggestion regarding insertion of “Article 23.3 – Any
such amendment shall not be given effect to without the leave
of the Hon’ble Supreme Court” is accepted for the present –
However, it is not appropriate to have continuous monitoring of
a sports federation by any forum, including the Supreme Court
– Having taken up the matter and ensured that the Constitution
is brought to this stage, it is necessary to take it to its logical
end – Supreme Court’s monitoring will only be that far and no
further. [Para 94]

Sports – Whether the current AIFF administration is a
permanent or interim body:
Held: The current executive committee can be treated as a
permanent body which shall discharge its function in accordance
with the relevant laws as well as the AIFF Constitution. [Para 101]
Sports – Draft Constitution of the appellant-Federation (AIFF) –
Certain objections/suggestions with respect to other clauses,
viz. On the definition and criteria of the Candidate; Definition
of ‘immediate family’; Obligation of member associations;
Suspension and Resignations; Executive committee and
concurrent memberships; Acting President etc. – Considered.
[Paras 103-121]

Case Law Cited
Public Interest Foundation v. Union of India [2018] 10 SCR 141 :
(2019) 3 SCC 224; BCCI v. Cricket Association of Bihar [2016]
8 SCR 606 : (2016) 8 SCC 535; N.P. Ponnuswami v. Returning
Officer, Namakkal Constituency [1952] 1 SCR 218 : AIR 1952 SC
64; Jagan Nath v. Jaswant Singh [1954] 1 SCR 892 : AIR 1954
SC 210; Dr. N. B. Khare v. Election Commission of India [1958] 1
SCR 648 : AIR 1958 SC 139; BCCI v. Cricket Association of Bihar
[2022] 14 SCR 519 : (2022) 19 SCC 30; Damyanti Naranga v.
Union of India [1971] 3 SCR 840 : (1971) 1 SCC 678; BCCI v.
Cricket Association of Bihar [2018] 9 SCR 526 : (2018) 9 SCC
624 – referred to.
1152 [2025] 9 S.C.R.

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Indian Olympic Association v. Union of India, 2014 SCC OnLine
Del 2967; Rahul Mehra v. Union of India, 2022 SCC OnLine Del
2438 – referred to.

Books and Periodicals Cited
Mihir Bose, A History of Indian Cricket (London: Andre Deutsch
Ltd, 1990), pp.16–17; Boria Majumdar & Kausik Bandyopadhyay,
‘A Social History of Indian Football: Striving to Score’ (Sport in
the Global Society, Routledge, 2008, Taylor and Francis), pg.
109; M. Dutta Ray, ‘Playing Experience Needed in our Football
Administration’, in WIFA Golden Jubilee Souvenir (Bombay: WIFA,
1961); Annexure II (Guidelines for the Recognition of National Sports
Federation) of the NSC 2011; C Boillat and R Poli, ‘Governance
Models Across Football Associations and Leagues’ in Réflexions
sportives, vol 4, International Centre for Sport Studies (2007);
Electoral Disqualifications, Report No. 244 (Law Commission of
India; February, 2014); Jasina, John and Rotthoff, Kurt W., A Model
of Promotion and Relegation in League Sports (November 1,
2009). Journal of Economics and Finance, Volume 36, Issue 2,
Pages 303-318.

List of Websites
https://cdnbbsr.s3waas.gov.in/s3ca0daec69b5adc880fb4
64895726dbdf/uploads/2022/0 8/2022081612.pdf; https://ssrn.
com/abstract=1512144; https://inside.fifa.com/fifa-world-ranking/
IND; https://inside.fifa.com/legal/judicial-bodies.

List of Acts
National Sports Development Code of India, 2011; Constitution
of India; National Sports Governance Act, 2025; FIFA Statutes,
2022; Representation of the People’s Act, 1951; FIFA Statute,
2024; Penal Code, 1860.

List of Keywords
All India Football Federation; Draft of the Constitution of All
India Football Federation; Draft of the Constitution of AIFF; AIFF
Constitution; Eminent players; Sports federations; AIFF’s election;
Committee of Administrators (CoA); National Sports Federation
(NSFs); FIFA; Continuous monitoring of a sports federation;
Constitution of AIFF, 2017.
[2025] 9 S.C.R. 1153

All India Football Federation v. Rahul Mehra & Ors.

Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No(s). 12591-
12592 of 2025
From the Judgment and Order dated 31.10.2017 of the High
Court of Delhi at New Delhi in CM No. 46919 of 2016 and CM
No. 19815 of 2012

Appearances for Parties
Advs. for the Appellant(s):
Ranjit Kumar, Sr. Adv., Siddhesh Shirish Kotwal, Ms. Manya Hasija,
Ms. Ana Upadhyay, T.illayarasu, Ms. Vaidehi Kolhe, Saurabh Guha,
Mrs. Rasika Jalan, Nagarkatti Kartik Uday.
Advs. for the Respondent(s):
Gopal Sankaranarayanan, Sr. Adv./Amicus Curiae, Samar Bansal,
Amicus Curiae.
Tushar Mehta, Solicitor General, K. M. Nataraj, A.S.G.,
Ms. Swarupama Chaturvedi, Neeraj Kishan Kaul, Ritin Rai, Dr.
Menaka Guruswamy, Ms. Anitha Shenoy, Raghenth Basant, Sr.
Advs., Apoorv Kurup, Sharath Nambiar, Vinayak Sharma, Vatsal
Joshi, Ms. Indira Bhakar, Chitransh Sharma, Anuj Srinivas Udupa,
Ms. Satvika Thakur, Ms. Nikita Capoor, Ms. Yogya Rajpurohit,
S. Subramaniam, Ayush Ranjan, Ms. Ritika Ranjan, Kanu Agrawal,
Rajat Nair, Arkaj Kumar, Padmesh Mishra, Dr. N. Visakamurthy,
Nar Hari Singh, Sanjeev K. Kapoor, Sahil Narang, Dhritiman Roy,
Ayushman Kacker, Vidush Sinha, Raghav Agarwal, Madhavam
Sharma, M/S. Khaitan & Co., Prateek K Chadha, Utkarsh
Pratap, Sreekar Aechuri, Aniket Chauhaan, Ms. Bhumika Yadav,
Ms. Shaswati Parhia, Ms. Kashish Jain, Kotla Harshavardhan,
Raghav Kohli, N. Sai Vinod, Anmol Gupta, Shuvodeep Roy,
Siddharth Nath, Asjad Hussain, Ms. Anunaya Chowdhary, Vedant
Kapur, Tushar Shrivastava, Ms. Jhanvi Dubey, Ms. Shreya Nair,
Vishal Sinha, Ms. Trisha Chandran, Nagarkatti Kartik Uday, Ms.
Hetu Arora Sethi, Shivam Singh, Anirudh Bhat, Nirmal Prasad,
Yoshit Jain, Shubham Janghu, Ishwar Singh, Sravan Kumar
Karanam, Akshay Mann, Kumar Abhishek, Sadhana Madhavan,
Divyanshu Rai, Ms. Kaushitaki Sharma, Kshitij Maheshwari, Ms.
Purnima Krishna.
1154 [2025] 9 S.C.R.

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Judgment / Order of the Supreme Court

Judgment

Contents*

1. Establishment of All India Football Federation and its history
thereafter ............................................................................... 5
2. Issues for Consideration ....................................................... 20
i. Re: Eminent Players in the General Body ..................... 22
ii. Re: Eligibility Criteria for Eminent Players ..................... 29
iii. Re: The definition of “Office-Bearers” ............................ 31
iv. Re: Number of Vice-Presidents ...................................... 33
v. Re: On Disqualification Event(s) .................................... 36
a) Disqualification on Criminal Charge and Conviction . 38
b) Disqualification on being or becoming a Public Servant
or holding any office in a sports or athletic association
or federation apart from Football, except the IOA ... 40
c) Disqualification of persons who has served as an
office-bearer of any NSF from holding a post in the
AIFF .......................................................................... 43
vi. Re: On retaining ‘indirect interest’ in the definition of
‘Conflict of interest’ .......................................................... 44
vii. Re: On the applicability of AIFF Constitution to State
Associations .................................................................... 46
viii. Re: AIFF and Third Parties: Extent of delegation of powers,
functions, and exploitation of rights ................................ 51
ix. Re: Promotion and Relegation in Indian Football .......... 56
x. Re: Applicability of principles laid down in BCCI Judgment
to the present case concerning football administration .. 60
xi. Re: Amendments to the AIFF Constitution and the need
for the Supreme Court to retain control ......................... 61
* Ed. Note: Pagination as per the original Judgment.
[2025] 9 S.C.R. 1155

All India Football Federation v. Rahul Mehra & Ors.

xii. Re: Whether the current AIFF administration is a permanent
or interim body? ............................................................. 63
3. Other objection(s)/suggestion(s)- .......................................... 67
i. On the definition and criteria of the Candidate: ............. 67
ii. Definition of ‘immediate family ....................................... 69
iii. Obligation of member associations ................................ 69
iv. Suspension and Resignations ........................................ 70
v. Executive committee and concurrent memberships ...... 70
vi. Acting President ............................................................. 72
vii. Quorum ........................................................................... 72
viii. Disciplinary Committee ................................................... 73
ix. Appeal Committee .......................................................... 74
x. Dispute Resolution and Grievance Redressal ............... 74
xi. Schedule III: Election Bye-Laws of All India Football
Federation ....................................................................... 76
4. Conclusion ............................................................................. 77

1. Leave granted.
2. Recounting the social history of Indian Football, learned authors1
have observed that;
“While the Indians were fighting the British for their
independence, one of the most popular games in the
country was football. Logically, after independence,
football should have become India’s number one sport. It
is cheaper, it certainly permeated more layers of Indian
society – even down to the semi-rural areas – than cricket
and, as in other parts of the world, could have been a
metaphor for nationalism.”

1 Mihir Bose, A History of Indian Cricket (London: Andre Deutsch Ltd, 1990), pp.16–17.
1156 [2025] 9 S.C.R.

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“But as freedom drew close, football’s erstwhile role as
a nationalist symbol sharply diminished owing to the
game’s increasing communal and regional overtones.
Despite the Indian national team’s worthy performances
at international level in the first fifteen years after 1947,
gradually, regionalism seemed to become a more distinct
and viable alternative in Indian football”.2
3. Unlike rights that can be enforced through law, fraternity is not
amenable to judicial command; it must be nurtured through lived
experiences of unity, trust, and shared endeavour. National,
international, regional or even mohalla sports in India serve as the
Karmabhumi where cohesion and collective purpose take tangible
form. They bring together individuals from diverse social, linguistic,
and cultural backgrounds under a common pursuit, embodying the
Constitutional value of fraternity. Here, individual and collective
aspirations find a way to coalesce.
3.1 On the field, teamwork compels individuals to set aside personal
distinctions and work together, cultivating habits of cooperation,
solidarity, and mutual respect. Accessibility of sports is important,
for when opportunities to participate are open to all—irrespective
of race, caste, religion, sex, or economic status—the unifying
power of sport is amplified. This inclusiveness ensures that
sports become not a privilege of the few but a medium through
which fraternity is strengthened across society. In this way,
sports operationalise what the framers envisioned: an intangible
yet indispensable force that holds us together through shared
effort and common purpose.
3.2 It is high time we recognize that sporting “facilities and
opportunities”3 are “material resources of the community” 4, and
their organizers are “the institutions of the national life” 5. As
“places of public resort” 6, sporting institutions and bodies must

2 Boria Majumdar & Kausik Bandyopadhyay, ‘A Social History of Indian Football: Striving to Score’ (Sport
in the Global Society, Routledge, 2008, Taylor and Francis), pg. 109.
3 Article 38(2), Indian Constitution.
4 Article 39(b), Indian Constitution.
5 Article 38, Indian Constitution.
6 Article 15(2), Indian Constitution.
[2025] 9 S.C.R. 1157

All India Football Federation v. Rahul Mehra & Ors.

remain accessible, not just for pursuing sport, but also for its
administration. It should be the deeper Sadhana (endeavour)
of the State, and it is also our Constitutional duty to ensure
that sporting facilities and opportunities flourish with institutional
efficiency, integrity, professionalism, and expertise.
3.3 It is also necessary to ensure that sporting facilities and
opportunities are not concentrated in the hands of the urban
economic elite and that the revenues from sporting events,
intellectual property and media rights are so distributed to
subserve and encourage accessible and affordable sport in
our country.
4. Establishment of All India Football Federation and its history
thereafter: The AIFF, a National Sports Federation (NSF), was
formed as the governing body of association football in the country
in 1937. It has been observed that AIFF failed to evolve with time,
took eleven years for its affiliation with the global apex body FIFA,
and struggled to manage Indian football efficiently. As a result, the
sport remained distributed in fragments, so much so that players
were alienated from the administration and with time, politics and
regionalism appeared on the centre stage. Taking into account
the lapses in organisational control around Indian football, the
commentators make a few observations, some of which are squarely
applicable to the issues in the present appeals:
“The Indian Soccer Administration
Corruption and lack of professionalism go hand in hand in
Indian football. The sport’s apex body in India, AIFF, has
not played it expected role to perfection…So far as the
question of professionalism is concerned, it (AIFF) fares
little better. Since its birth in 1937, AIFF showed an utter lack
of professional attitude towards the game. It took eleven
long years to get affiliated with the world apex body, FIFA.
It played its flawed part in India’s failure to participate in
the 1950 World Cup. The unresolved dichotomy of national
and club football has been, to a great extent, a result of
its failure and amateurish duplicity. Moreover, factionalism,
favouritism and infighting within the Federation are plain to
see since its inception. As one of the better administrators
of Indian soccer/ AIFF argued in 1961:
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In our country, however, things are absolutely
different. Whether it be in the All India sphere or
in the State sphere, you will find very few people
in the administration who could claim to be players
themselves. Unless this vital change is introduced
in the selection of the administrative personnel,
I am afraid, our football will never attain its rightful
stature. I have travelled throughout the world and had
an opportunity to see the football set-up in all those
places … There football is guided by experts; here
by all sorts of people, and the difference is there for
all to see”.7
5. The present appeals arise out of a challenge to the order dated
31.10.2017 passed by the Hon’ble High Court of Delhi in CM No.
46919/2016 and CM No. 19815/2012 in W.P. (C) No. 195/2010
(“Impugned Order”).
6. The short facts relevant to the present appeals are that Mr. Rahul
Mehra, respondent no. 1 (in person), preferred a writ petition W.P.
(C) No. 195/2010 raising questions on the working of various sports
federations and their election process, and prayed for issuance of
various writs directing the Union of India to interfere in the same. Amid
the pendency of the writ petition, the Government of India, through
the Ministry of Youth Affairs and Sports, issued a comprehensive code
amalgamating all previous guidelines and notifications in the form
of the National Sports Development Code of India, 2011 (“National
Sports Code”/“NSC”).
7. It is in this context that the respondent no. 1 filed an interlocutory
application C.M. No. 19815 of 2012, specifically praying for a direction
to postpone or stay the proposed elections to the various offices of
the AIFF, as the elections were allegedly being held in violation of
NSC 2011. On 18.12.2012, the High Court passed an order, finding
prima facie merit in the averments of the interlocutory application and
directing the Union of India to examine the holding of AIFF’s elections
and pass a reasoned order deciding if the elections are being held

7 Supra 1 at pg. 173 quoting M. Dutta Ray, ‘Playing Experience Needed in our Football Administration’, in
WIFA Golden Jubilee Souvenir (Bombay: WIFA, 1961). Incidentally Dutta Ray was the president of AIFF
at that time.
[2025] 9 S.C.R. 1159

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in consonance with the regulatory framework. On 23.08.2013, the
Union of India filed an affidavit before the High Court highlighting
that it had examined the validity of elections held on 20.12.2012 and
arrived at the conclusion that the elections “were free and fair and
therefore the body elected in pursuance of the said election is liable
to be accorded recognition”. In that manner, the proceedings before
the High Court qua 2012 elections stood concluded.
8. In 2016, when the election to the AIFF’s executive council again
became due, the High Court on 15.12.2016 passed an order staying
the election on the ground that the proposed election exercise
violated the orders passed during the last elections in 2012. It is in
these facts that the appellant filed an interlocutory application CM
No. 46919/2016 seeking vacation of the order dated 15.12.2016 so
that the elections may be concluded. On 20.12.2016, the High Court
took up the application and vacated the stay order to the extent that
the elections may proceed, but the result shall be subject to the final
outcome of the application.
9. After the election process concluded, the matter was again taken up
with the passing of the impugned order. Vide the impugned order,
the High Court set aside the results of the elections of the appellant
federation on grounds of non-compliance with the sports code and
other regulations and also:
a) appointed Dr. S.Y. Quraishi, Former Chief Election Commissioner
of India as the Administrator – cum – Returning Officer for the
conduct of elections of the AIFF,
b) directed that the elections of the AIFF were to be held after the
preparation of an Electoral College, and
c) directed that the elected body so constituted was to carry out
the requisite amendments to the AIFF Constitution to bring it
in conformity with the NSC 2011 as well.
10. The relevant directions contained in paragraph 22 of the impugned
judgment are extracted below:
“22. The Court is of the view that insofar as the Rules of
the AIFF are in breach of the National Sports Code and the
Model Guidelines for the conduct of elections, the results
of the elections of the AIFF declared on 21.12.2016 would
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have to be set aside. It is so ordered. Fresh elections shall
be conducted in accordance with the Model Guidelines.
Additionally, nominations would be required to be proposed
and seconded by one member association each and with
clear notice, as required by the Model Election Guidelines
read with rules of AIFF. Furthermore, the Electoral College
shall be first prepared after addressing the complaints of
various members who may have grievances in this regard.
This exercise should be carried out by a person who has
experience in sports affairs, public administration and
the conduct of elections. Accordingly, this Court directs
Mr. S.Y. Quraishi, former Chief Election Commissioner of
India, who has also served as Secretary in the Ministry
of Youth Affairs and Sports, Government of India, to be
appointed as the Administrator-cum-Returning Officer for
the conduct of the elections of the AIFF in the following
manner:
i. To resolve the issue of disaffiliation of members/
units of AIFF as on 30th November, 2016 and to
prepare the Electoral List, within a month by giving
the concerned parties two weeks’ notice;
ii. Elections shall be held in six weeks after the
preparation of the Electoral college. This elected
body shall carry out the requisite amendments to
the AIFF Constitution to bring it in conformity with
the National Sports Code.
iii. Once the AIFF Constitution has been amended, a
fresh round of elections shall be carried out in terms
of the National Sports Code, to ensure that age
and tenure restrictions along with the provision for
due representation of the sports-persons are strictly
complied with.
iv. The AIFF shall make available to the Administrator an
appropriate office space and facilities for the discharge
of the aforesaid directions and make available such
staff and personnel as the Administrator may express
the need for. Alternatively, the Administrator may
appoint such personnel to assist him in the aforesaid
[2025] 9 S.C.R. 1161

All India Football Federation v. Rahul Mehra & Ors.

matter and expenses towards the same shall be
borne by the AIFF.
v. Till the elections are conducted and results declared
in consonance of the National Sports Code and in
compliance with the preceding directions, the AIFF
shall not make any new financial commitments except
with the prior approval of the Administrator. Routine
expenses of AIFF too shall be defrayed, only with
the prior approval of the Administrator. The entire
exercise will be completed within five months from
the date the Administrator assumes charge;
vi. However, to obviate any impediment in the conduct
of any competitive tournament that may have been
scheduled by the applicant, this order shall come
into effect after two weeks from today.”
11. AIFF preferred the present appeals against the High Court’s order.
On 10.11.2017, this Court stayed the operation of the impugned
order and, in particular, the directions given by the High Court in
paragraph 22. This Court further directed that Dr. S.Y. Quraishi and
Mr. Bhaskar Ganguly, former Indian captain and international football
player, would act as the Committee of Administrators (“CoA”) for the
formulation of the Constitution of the Federation in consonance with
the NSC and Model Guidelines. The relevant paragraphs of the order
dated 10.11.2017 are extracted below:
“Considering the rival submissions, we are inclined to stay
the operation of the impugned judgment and, in particular,
the directions given by the High Court in paragraph 22
of the impugned judgment. We issue following interim
directions:-
(i) Mr. S. Y. Qureshi, former Chief Election Commissioner
of India, who has also served as Secretary in the
Ministry of Youth Affairs & Sports, Government
of India and Mr. Bhaskar Ganguly, former Indian
Captain and International Football Player, 38, Nalta
Mahajoti Road, Kolkata-700028, are appointed as
the Committee of Administrators (Ombudsmen) for
formulation of Constitution of the Federation which
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will be in consonance with the National Sports Code
and the Model Guidelines for the conduct of its
business, constitution of the Executive Committee
and elections thereto whilst ensuring that the status
and membership of Petitioner Federation is not
undermined in any manner in the International Body.
They shall prepare the draft Constitution and submit
the same within eight weeks along with their report,
in a sealed cover before this Court.
(ii) While formulating the proposed Constitution, the
Committee of Administrators (Ombudsmen) may take
into account the suggestions given by Respondent
No.1, if any.
(iii) After the report of the Committee of Administrators,
along with the proposed Constitution, becomes
available, further directions as may be necessary
can be issued.
We place on record the stand taken by the Petitioner
before us that the present elected body of the Petitioner-
Federation is committed to extend its full cooperation
to the Committee of Administrators for formulation of
the ·proposed Constitution of the Federation which will
be compliant in all respects and ensure transparency,
accountability and observance of democratic values in the
conduct of the business of the Federation.
As aforementioned, the directions issued in paragraph 22
of the impugned judgment shall remain in abeyance until
further orders, subject to the above directions.”
12. The appeals again came up for hearing on 18.05.2022, wherein
the composition of the CoA was reconstituted, with the inclusion
of Mr. Justice Anil Dave, Former Judge, Supreme Court of India.
While re-constituting the CoA, the Court also noted the finalisation
of the report by the CoA after eliciting and receiving responses from
the relevant stakeholders. The Court further directed the counsel
appearing on behalf of CoA to collate the objections to render
facilitative assistance to this Court. The CoA was further requested
to assess the suggestions/objections of the stakeholders and provide
[2025] 9 S.C.R. 1163

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inputs on the proposed suggestions/objections. The relevant portion
of the order is as follows:
“4. The CoA, acting under the authority assigned to it by this
Court in terms of the above order has sought the permission
to place the Constitution for further consideration. The
request of the CoA is allowed.
5. The proposed Constitution of the All India Football
Federation which has been directed to be presented to
court in a sealed cover in the earlier interim order shall be
circulated to all the parties. Any objection or suggestion to
the Constitution, as proposed, shall be filed only before
this Court on or before 30 June 2022. Any party desirous
of obtaining a copy of the proposed Constitution would
be at liberty to email its request to Mr. Samar Bansal,
counsel appearing on behalf of CoA. Mr. Bansal will
circulate the proposed Constitution to the parties and to
any other constituent unit. Thereafter, all objections and
suggestions shall also be emailed to Mr. Bansal who
shall collate the objections for the purpose of rendering
facilitative assistance to this Court. Counsel is requested
to prepare a tabulated statement of:
(i) The Parties submitting suggestions/objections:
(ii) The nature of the suggestions/objections; and
(iii) The inputs of the CoA on the proposes suggestions/
objections
6. This exercise shall be carried out by the CoA on or
before 15 July 2022 and a tabulated statement shall be
placed on the record. The tabulated statement shall also
be circulated to all the parties so as to apprise them of
the position.
7. The elections of the Executive Committee which
were held on 21 December 2016 were set aside by the
judgment of the Division Bench of the High Court of Delhi
dated 31 October 2017. During the pendency of these
proceedings, by the interim order dated 10 November
2017, the operation of the judgment of the High Court
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was stayed, including the directions which were issued in
paragraph 22 of the judgment. The normal tenure of the
elected body would, in any event, have come to an end
on 20 December 2020. The consequence of the order of
stay is that despite the expiry of its four year term, the
Executive Committee has continued to govern the affairs
of the Federation. This state of affairs is not in the interest
of the proper governance of the Federation. Hence, the
two member CoA which was appointed by the order of this
Court dated 10 November 2017 with a specific mandate
to prepare the Constitution and hold elections to the
Executive Committee, is reconstituted to consist of the
following members:
(i) Mr Justice Anil R Dave, former Judge of the Supreme
Court;
(ii) Dr S Y Qureshi, former Chief Election Commissioner;
and
(iii) Mr Bhaskar Ganguly, former captain of the Indian
Football Team.
8. The CoA shall take charge of the affairs of the Federation
and shall carry out the following functions:
(i) The CoA shall assist this Court and provide its inputs
in the course of the present proceedings so as to facilitate
the adoption of the Constitution after the objections/
suggestions are considered;
(ii) The CoA shall prepare the electoral roll/college for
the purpose of conducting the elections to the Executive
Committee in accordance with the provisions of the
Constitution, as proposed, subject to such further directions
as may be issued by this Court after hearing the parties;
(iii) The CoA shall carry out the day to day governance
of the Federation;
(iv) In discharging its task in terms of (iii) above, the CoA
would be at liberty to take the assistance of the erstwhile
Committee of the Federation which has continued till the
date of this order in order to facilitate decisions being
[2025] 9 S.C.R. 1165

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taken, inter alia, on the holding of tournaments, selection
of players and all other matters necessary for the proper
governance of the Federation;
(v) The erstwhile Committee which shall forthwith hand
over the charge to the CoA; and
(vi) The CoA would be at liberty to make all appropriate
arrangements, for the governance of the Federation, until
elections are held.
9. The present direction is a temporary arrangement in
order to facilitate the holding of elections and the handing
over of the affairs to a democratically elected body in terms
of the Constitution which will be adopted.
10. It is expected that the process of conducting the
elections should be completed expeditiously after the
Constitution is finalized.”
13. When the matter was next listed before this Court on 21.07.2022,
this Court was apprised by CoA that the CoA received nearly 215
comments from objectors, out of which nearly 98% of the objections
have been accepted. The Court also noted the concerns expressed
by the Union Government regarding the proposed Constitution and
observed that the objections would be considered expeditiously
by the Court. To that effect, the Court also directed that all parties
prepare a brief note of submissions and circulate them to the counsel
appearing on behalf of the CoA.
14. Thereafter, on 03.08.2022, in view of the then-scheduled FIFA
Under-17 Women’s World Cup, 2022 and the indication of FIFA to
CoA that the inaugural of the Under-17 tournament should be carried
out under the auspices of a democratically elected body of AIFF,
this Court observed that the elections of the executive committee
of AIFF should be held expeditiously, consistent with provisions of
Article 26 of the draft Constitution. The relevant portion of the said
order is under:
“For the above reasons, we order and direct that:
(i) The elections to the Executive Committee of AIFF
should be held expeditiously and shall be concluded in
terms of the time schedule which has been indicated in
the tabulated statement set out above;
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(ii) The elections shall be conducted in a manner consistent
with the provisions of Article 26 of the draft Constitution.
The persons chosen as representatives shall have to
conform to Article 26.
(iii) This would be an interim arrangement without prejudice
to the rights and contentions of the parties;
(iv) The interim Body would continue for a period of three
months subject to further orders of this Court till the
Constitution is finalized;
(v) The interim Body shall not claim any equities on the
basis of this order and the present arrangement would be
subject to further orders;
(vi) The CoA shall be apprised of the decisions of the
elected Body; and
(vii) Each of the associations representing the State/
UTs would nominate one representative to the electoral
college. The 36 member electoral college of eminent
football players shall consists of 24 male and 12 female
players. Each of them would be subject to the requirement
of having represented India in at least one international
match and should have retired from international football
at least 2 years prior to the date of the notification of the
elections……”
15. Unfortunately, when the matter was listed on 22.08.2022, this Court
was informed that the FIFA Council on 14.08.2022 had taken a
decision to suspend AIFF from membership of FIFA. The immediate
impact of the suspension would have been i) jeopardising the under-17
women’s World Cup 2022, which was to take place in October
2022, and ii) the inability of Indian teams selected by the AIFF and
its affiliated clubs to take part in international football matches or
competitions as long as the suspension continued.
16. In view of the submissions made by the Ld. Solicitor General that
it was needful that the administration and management of AIFF
is performed by a duly elected body, this Court directed that the
elections be held as soon as possible to “facilitate the revocation of
the suspension which has been imposed on AIFF by FIFA and the
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holding of the Under-17 Women’s World Cup 2022 in India”. The
Court further noted the termination of the mandate of CoA and, while
recording its appreciation of the sustained and remarkable efforts of
CoA, requested Mr. Gopal Sankaranarayanan, Ld. Senior Counsel
and Mr. Samar Bansal, Ld. Counsel to assist the court as Amici.
17. Pursuant to the Court’s order, elections were held. On 02.09.2022,
the newly elected Executive Committee of the AIFF took charge
and has been carrying out the functions of the AIFF to date.
In the meantime, the Ld. Amici tabulated the provisions of the
draft Constitution alongside the stakeholders’ objections to each
clause and comments on the proposal. Since the objections and
suggestions were extensive, the Court found it necessary to refer
the exercise of carrying out preliminary scrutiny and relevant
modifications to the Constitution drafted by the CoA to an eminent
jurist. In its order dated 02.05.2023, this court noted that many of
the objections did not implicate pure issues of law but also policy.
In this view of the matter, the Court entrusted the task of finalising
the Constitution of AIFF to Hon’ble Mr. Justice L Nageswara Rao, in
view of his experience in BCCI matters as well as a similar exercise
undertaken by him under the orders of this Court in relation to
the Indian Olympic Association (IOA). The relevant extract of the
02.05.2023 order is as under:
“11. Ordinarily, we would have embarked upon the exercise
of finalizing the draft constitution by hearing all the
stakeholders. We, however, are of the view that it would
be appropriate at this stage to defer the above exercise.
Many of the objections which have been addressed by
the stakeholders do not strictly implicate the issues of law,
but, also trench into issues of policy including the proper
modalities for running the sport of football in the country.
12. A similar exercise has been carried out under the orders
of this Court in relation to IOA by Mr Justice L Nageswara
Rao, former Judge of this Court. Many of the objections
which have been raised here would find a considerable
degree of overlap in the proceedings which took place
before the Hon’ble former Judge. Hence, it would be
appropriate to entrust the task of finalizing the Constitution
of AIFF to Mr Justice L Nageswara Rao.
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13. We request Mr Justice L Nageswara Rao, former
Judge of this Court, to take up the task of finalising the
draft constitution as was proposed by the CoA and which
has now been propounded by the Amicus Curiae.
14. In preparing his report, Mr Justice L Nageswara Rao
is requested to hear all the stakeholders, some of whom
have already been referred to in the earlier part of this
order. The exercise of considering the draft constitution
and of submitting a comprehensive report bearing in
mind the objections which have been addressed by all
the stakeholders, may preferably, be carried out by 31
July 2023…..”
18. Taking all suggestions into account, Justice L N Rao prepared a report
and suggested amendments to the erstwhile Constitution drafted by
the CoA. On 11.09.2023, this Court permitted the stakeholders to file
objection(s) as they deem fit. On 19.03.2024, this Court permitted
AIFF to file its objections to the draft Constitution proposed by Mr
Justice L N Rao and requested the amici to update the existing chart
to reflect the objections of AIFF.
19. It is in the above-referred background that the matter was listed
before this bench on 25.03.2025, when it was decided to hear the
contesting parties and pass final orders. The matter was heard in detail
on 02.04.2025, 16.04.2025, 22.04.2025, 23.04.2025, 29.04.2025,
and 30.04.2025.
20. The Court benefited from detailed and incisive submissions made
by the Ld. Counsels on significant issues permeating Indian football.
We heard Mr. K. M. Nataraj, Ld. Additional Solicitor General for the
Ministry of Youth Affairs and Sports, Mr. Ranjit Kumar, Ld. Senior
Counsel for the AIFF, Dr. Menaka Guruswamy, Ld. Senior Counsel
representing State associations, Mr. Prateek Chadha, Ld. Counsel for
the Karnataka State Football Association, Mr. Abhimanyu Bhandari,
Ld. Senior counsel for the Western India Football Association (‘WIFA’),
Mr. Neeraj Kishan Kaul, alongside Mr. Ritin Rai, Ld. Senior Counsel
for the intervenor Football Sports Development Limited (‘FSDL’), Mr.
Raghenth Basant, Ld. Senior Counsel appearing on behalf of Mr.
Bhaichung Bhutia, Intervenor, Mr. Kotla Harshavardhan, Ld. Counsel
on behalf of Mr. Ranjit Bajaj, Intervenor and Director of Delhi Football
Club and Minerva Football Academy, Mr. Shivam Singh, Ld. Counsel
[2025] 9 S.C.R. 1169

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representing Mr. Shaji Prabhakaran (Intervenor), and Ms. Anitha
Shenoy, representing Mr. Gopala Krishna Kosaraju, Founder and
Former President, Andhra Pradesh Football Federation.
21. We also heard Mr. Rahul Mehra, respondent no. 1, in person. All
through the hearing, we were ably and effectively assisted by Mr.
Gopal Sankaranarayanan and Mr. Samar Bansal, learned amici who
have rendered effective assistance to this court.
22. The amici had previously submitted a tabulated chart containing a list
of objections from all stakeholders. During the course of submissions,
the counsels for the respective parties submitted written submissions,
accompanied by rejoinders on the final day of hearing as well.
23. After hearing all the parties, our consideration was confined to
approving or modifying the draft Constitution on the basis of the
report of Justice L N Rao, coupled with the submissions and written
notes of all the parties on the clauses of the draft Constitution. In the
meantime, a significant development occurred with the enactment of
the National Sports Governance Act 2025,8 and this prompted the Ld.
Amici to mention the matter before this Court. We listed the appeals
for hearing on 01.09.2025 and heard the parties about the advent
of the 2025 legislation. As the legislation has not yet been notified,
we proceed to deliver this judgment filling up the legislative void in
the interregnum. The Amici and other counsels have also informed
us that the draft Constitution, as per the amendments suggested by
Justice L N Rao is more or less in consonance with the provisions
of the legislation, to be notified. Be that as it may, we now proceed
to examine the following issues and give our judgment.
24. Issues for Consideration: The objections made by the parties to
the draft Constitution fall primarily under the following domains:
i. Should Eminent Players be in the General Body; if so, to what
extent?
ii. What should be the Eligibility criteria to be designated an
Eminent Player?
iii. Whether ‘Office bearers’ should be limited to President,
Treasurer, Secretary?

8 Hereinafter “NSGA 2025”/“2025 Act”.
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iv. Whether the number of VPs should be increased to ensure
regional representation?
v. Whether public servants should be included under disqualification
events?
vi. Whether ‘indirect interest’ should be retained in the definition
of ‘conflict of interest’?
vii. Should the AIFF Constitution apply to state associations?
viii. What is the permissible extent of delegation of powers, functions,
and exploitation of rights by AIFF to third parties?
ix. Whether promotion and relegation should form part of the AIFF
Constitution?
x. To what extent are BCCI judgements applicable to football?
xi. Should Amendments to the Constitution be approved by the
Supreme Court?
xii. Whether the current AIFF administration is a permanent or
interim body?
We have dealt with the above issues in seriatim. Other miscellaneous
suggestions/objections to the draft Constitution have been dealt with
at a later stage.

i. Re: Eminent Players in the General Body.
25. Under the draft Constitution, the composition of the general body
is dealt with under Article 20. As per Article 20.2, the General Body
shall comprise:
“(a) 1 (one) representative from every Member Association;
(b) 15 (fifteen) ‘Eminent Players’ elected from a national
player body. Out of the 15 (fifteen) Eminent Players,
minimum 5 (five) shall be women
(c) 3 (three) Club representatives, one each from ISL,
I-League and Indian Women’s League
(d) 2 (two) representatives from Referees, 1(one) male
and 1 (one) female; and
(e) 2 (two) representatives from Coaches, 1 (one) male
and 1 (one) female.”
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26. AIFF, as well as State associations, have argued against the
prescribed composition of the General body. Mr. Ranjit Kumar,
learned Senior counsel on behalf of AIFF, has emphasised that the
composition of member associations is restricted to almost 60%
because of the prescription as provided under Article 20.2. This,
he would submit, is not in consonance with Clause 3.20 of NSC
2011, which contemplates about 75% composition for the member
associations. The said provision is extracted hereunder:
“3.20 Inclusion of prominent sportspersons of outstanding
merit as members of the respective sports federations on a
tenure basis. The strength of such prominent sportspersons
with voting rights should be a certain minimum percentage
(say 25%) of the total members representing the
federation, and selection of such sportspersons should
be in consultation with this Department.”9
(emphasis supplied)

27. State associations, on the other hand, strongly oppose the voting
rights to eminent players, referring to NSC 2011 (annexure 2), read
with FIFA Statutes, and submitted that presence of eminent players’
can at most be on a tenure basis.
28. The State associations also submit that while Eminent players,
coaches, referees and club representatives may be allowed be a part
of the executive committee, they cannot be a part of the general body
of the AIFF and are not entitled to vote in general body meetings,
as the NSC 2011 and the FIFA Statutes grant voting rights solely
to member associations. On the other hand, AIFF does not dispute
that eminent players should be part of the General Body; however,
AIFF disagrees only on how many eminent players should form part
of the General Body.
29. To buttress their submission, state associations have relied on FIFA
Statutes, 2022, particularly Article 26 read with Article 14(1)(a-d), to
argue that the FIFA Statutes do not envisage individuals becoming
members of national football associations. Further, State associations
refer to clauses 3.9 and 3.10 of NSC 2011, arguing that there is no

9 Annexure II (Guidelines for the Recognition of National Sports Federation) of the NSC 2011.
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prescription under NSC 2011 for players to be part of the executive
committee with voting rights. The said provisions are extracted below:
“3.9 The membership of the Federation should be confined
to the corresponding State/UT and other special units
affiliated (like Sports Control Boards etc.) and where
Federation grant membership to individual clubs or
individual persons, such membership does not confer on
such members the right to vote in any of the Federation’s
meetings.
3.10 At the National level, there will be only one recognised
federation for each discipline of sport. Only the duly
recognised National Sports Federation would be entitled
to financial grants as admissible. Only one State/UT
Association from each State/UT shall be admitted as a
member of the Federation, provided it has a minimum of
50% of the District level Associations affiliated to it. Any
organisation of an all India standing and connected with
the Sport may be given the status as that of a State or
that of a U.T. and admitted as affiliated Member. Other
categories of membership may also be given, but while
each affiliated State/UT Unit shall have a right to cast
vote in the General Body Meetings, no other class of
Member(s) shall have any right to vote, in the Federation’s
meetings. While granting recognition/affiliation to a State
/UT Association, the National Federation should take into
consideration the representative character of the State/UT
Association so as to ensure that only truly representative
body of the game gets the recognition/affiliation.”
(emphasis supplied)

30. To counter the above submissions, the following facts were brought
to our attention:
a) Firstly, the FIFA Statutes 2022 and their most recent iteration
in 2024 contemplate the inclusion of individuals in the body
of the national federation. This is clear from Article 11(1),
which recommends that “all member associations involve all
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relevant stakeholders in football in their own structure”10, the
term stakeholder being defined in definition 18 as “a person,
entity or organisation which is not a member association and/or
body of FIFA but has an interest or concern in FIFA’s activities,
which may affect or be affected by FIFA’s actions, objectives
and policies, in particular clubs, players, coaches, professional
leagues and football fan”.
b) Secondly, Article 10 of the FIFA Standard Statute, which is
a model Statute prescribed by FIFA to aid National Football
Associations in drafting their own constituent documents, while
dealing with admission to member associations, states that
the members can be, inter alia, clubs, player groups, referee
groups, and coach groups.11 Following from this, Article 12
defines members’ rights and Article 12(1)(a) explicitly grants all
members the right to take part in the Congress (equivalent to
the general body) and to “exercise their voting rights”.12
c) Thirdly, the inclusion of individual categories of members,
such as eminent players, coaches, and referees, is also
supported by the practice followed by a large number of national
associations affiliated to FIFA, which permit the same. This has
been documented and confirmed in a study conducted by the
‘International Centre for Sport Studies’, an independent study
centre created as a foundation in 1995 by FIFA in conjunction
with the University of Neuchâtel.13 A perusal of the findings
of this report shows that different national associations grant
membership to a variety of stakeholders, including Eminent

10 “11. Admission: 1. Any association which is responsible for organising and supervising football in all
of its forms in its country may become a member association. Consequently, it is recommended that
all member associations involve all relevant stakeholders in football in their own structure. Subject to
paragraph 5 below, only one association shall be recognised as a member association in each country.
(…)” (emphasis supplied)
11 “10. Admission 1. The Members of X are: a) Clubs; b) Regional Associations; c) Leagues; d) Player
groups; e) referees’ groups; f) coaches’ groups; g) … [to be completed by the Association]. (…)”
3. The application must be accompanied by the following mandatory items: (…)
b) a declaration that it will always comply with the Statutes, regulations and decisions of X, FIFA and ...
[abbreviation or acronym of the relevant Confederation] and ensure that these are also respected by its
own Members, Clubs, Officials and Players;”
12 “12. Members’ rights 1. The Members of X have the following rights: a) to take part in the Congress of X,
to know its agenda in advance, to be called to the Congress within the prescribed time and to exercise
their voting rights; (…)”
13 C Boillat and R Poli, ‘Governance Models Across Football Associations and Leagues’ in Réflexions
sportives, vol 4, International Centre for Sport Studies (2007).
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Players, coaches, and referees. The above data simply does
not support the proposition that it is a standard practice to
exclude individual players from membership of associations.
31. Taking the aforementioned into account, it was submitted that the
inclusion of Eminent Players, clubs, and coaches in the proposed
Constitution is in consonance with the very FIFA Statutes relied upon
by state associations.
32. Commenting on this provision, Justice L N Rao has stated that the
“article has been finalised in consultation with FIFA and considering
the requirements of player representation under the Sports Code.”
33. We have read 3.9, 3.10 and 3.20 of the NSC 2011 in conjunction.
On a holistic reading of the provision, we find that no conflict or
contradiction appears to arise. While it is correct that clauses 3.9
or 3.10 of the NSC 2011 do not confer voting rights on individual
members of an association, it is equally true that clause 3.20
explicitly grants voting rights to a specific sub-category of individual
members, i.e., “prominent sportspersons of outstanding merit”.
A harmonious and conjoint reading of clauses 3.9, 3.10 or 3.20
would thus show that clause 3.20 is essentially a carve-out from
clauses 3.9 or 3.10, and grants voting rights to the class of persons
indicated therein, i.e., “prominent sportspersons of outstanding
merit.” Reading the provisions conjointly, it therefore appears that
the substantive composition of the organisational structure should
consist of member associations, and it is contemplated to be an
ideal situation to have eminent sportspersons having voting rights.
We find that the percentage indicated in clause 3.20 of the NSC
2011 is not transgressed by clause 20.2 of the draft Constitution.
34. The argument of State associations regarding transgression of FIFA
Statute lacks merit inasmuch as the Standard Statutes 2005 itself
suggests the inclusion of experienced players with voting rights. The
relevant provisions have already been extracted above. The study
conducted under the aegis of the University of Neuchâtel also points
towards the practice of inclusion of players in the organisational
structure. It is also important for us to note that clause 20.2 was
also subjected to scrutiny, as indicated by Justice L N Rao, who
stated that he had a meeting with officials of FIFA in Zurich, and
the provision was finalised in consultation with the officials of FIFA.
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35. We are of the opinion that the freedom of choice to form an association
is not in any way compromised by the requirement to incorporate
15 eminent players. The democratic setup of the federation is not
destabilised as the elected member associates certainly continue to
hold more than 62% as the NSC 2011 under clause 3.20 only suggests
that the number of prominent sportspersons should be a minimum of
25% which means that model provision has not prohibited a number
larger than 25%. It is not probable but certain that the inclusion of
eminent players, coaches, referees, and club representatives in the
general body, with only further good governance, heralds transparency
and fair play.
36. In this view, we are not inclined to interfere with the draft provision.

ii. Re: Eligibility Criteria for Eminent Players
37. The issue of eligibility criteria for eminent players is important. Three
important yet divergent submissions have been made in this regard.
It is important to note that while the preliminary CoA draft of the
AIFF Constitution (2017) did not define the word eminent player,
the later draft by CoA kept the criterion that participation in 15
competitive matches was a minimum to be considered an ‘eminent
player’. Article 1.19 of the latest draft, as finalised by Justice L N
Rao, defines an ‘eminent player’ to be a past player, who has been
retired for at least 2 years, and has represented India (senior) in at
least 7 competitive matches (men)/ 3 competitive matches (women)
sanctioned by FIFA/AFC14.
38. AIFF has submitted that, in addition to international matches
sanctioned by FIFA/AFC, domestic matches sanctioned by AIFF
should also be counted for determining whether a player meets
the experience cut-off. The state associations, however, submit
that the threshold be kept as it was in the preliminary draft, i.e., 15
sanctioned matches for male players and 5 sanctioned matches for
female players, with further dilution to 3 matches in case the pool
of qualified candidates is not adequate.
39. Though there is justification to include an eminent player in the general
body, there is a practical problem. We are informed that we do not

14 Asian Football Confederation.
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have a sufficient pool of eminent players who have participated in
15 competitive matches. Even as per the suggestion of Justice L N
Rao, we may not have sufficient numbers to fill up the position of 10
male and 5 female eminent players in the general body. We either
reduce the number of eminent players in the general body or reduce
the criteria for qualifying as an eminent player. This issue needs to
be resolved on the basis of the current position of the availability
of past players. The Ld. Amici have informed us that the CoA could
collect a list of 236 male and 3 female players who had played at
least one official match for India. However, no official data on this
point is maintained by AIFF. We do not have further details.
40. The draft Constitution already prescribed a criterion, and we have
examined it carefully. After examining the whole conspectus in the
foregoing analysis, we are of the opinion that it will be reasonable to
reduce the criteria suggested by Justice L N Rao, to 5 matches for
men and from 2 matches for women. We hope that such a modification
will ensure a wider pool and participation by retired players who will
prove themselves to be efficient administrators and guiding lights for
Indian football. So far, the submission of AIFF qua counting domestic
experience for eminence status is concerned, we are not inclined to
accept it. Domestic experience might not yield the result sought to be
achieved with the adoption of the Constitution, which is formulated
to project Indian football on the international panorama.

iii. Re: The definition of “Office-Bearers”
41. Under Article 1.43 of the proposed draft, an office bearer shall “mean
all elected members of the Executive Committee as indicated in
Article 25”. Article 25.1 provides that AIFF shall have the following
office-bearer(s). The Article is extracted for ready reference.
Article 25: Office-Bearers of AIFF and Composition of the
Executive Committee:
25.1 AIFF shall have the following Office-Bearers who
shall all constitute the Executive Committee:
(a) 1 (one) President
(b) 2 (two) Vice Presidents
(c) 1 (one) Treasurer
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(d) 10 (ten) members, out of whom at least 5 (five) shall
be Eminent Players. Further, out of the Eminent Players,
at least 2 (two) shall be female Eminent Players (…).
42. With respect to the above definition, State associations have argued
that, as per NSC 2011, the term office bearer can only encompass
President, Treasurer, and Secretary. It is argued that while the NSC
provides for the executive committee to have other members, including
Vice-Presidents, the term office-bearer itself may not include any other
position. To make this submission, the State associations refer to a
letter to the President, Indian Olympic Association, by Joint Secretary
to the government of India dated 20.09.1975, which forms a part of
NSC 2011 and mentions the above three posts as being included
in the term ‘office-bearers’. We have examined the letter. Having
examined the letter, we are of the opinion that it has no bearing on
the definition of office bearer. Office bearers must be understood in
the context of the functioning of the AIFF and the reform that needs
to be brought about. This definition will have a direct bearing on the
applicability of cooling-off, the term, tenure and age limit. On the
other hand, the inclusive definition will be consistent with the reforms
that have been introduced and applied as independent measures for
the vibrant working of the federation. Having examined the clause,
Justice L N Rao has not considered it necessary to alter the same.
In this view, we are not inclined to accept the suggestion.

iv. Re: Number of Vice-Presidents
43. As reproduced above, the definition of office-bearer(s) includes
2 vice-presidents. While State associations have suggested that
there should be five VPs to represent each zone, AIFF suggests
that there should be three VPs, one of which should be a female.
State federations cite that the FIFA council has VPs from all different
continental federations and that increasing the number of VPs will
be compliant with NSC. AIFF argues for an increase in the number
of VPs to 3, providing for one woman vice-president.
44. Many stakeholders have opposed the above submissions, arguing
that a) the number of VPs has been restricted to prevent influential
persons from accommodating themselves or their supporters, b)
that under the AIFF Constitution, it is the President and Secretary
General who are primarily responsible for the management and day-
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to-day affairs of the AIFF, and c) the judgement in BCCI v. Cricket
Association of Bihar15 (“BCCI-I”), particularly paragraph 1816, is clear
and categorical in its rejection of accommodating regional interests.
45. Per Contra, Mr. Mehra submits that the number of executive committee
members cannot exceed 12 persons in terms of the NSC 2011. We
gave serious consideration to the issue, and we find that no harm is
caused by exceeding the membership of the executive committee.
We believe both CoA and Justice L N Rao have taken into account
the NSC 2011 and balanced it with the demands of the sport. The
order of this Court dated 22.08.2022 provided that the EC of the
federation will consist of 23 persons as an arrangement at that time,
a higher number than the 12-person committee.17 Therefore, we are
not inclined to reduce the size of the executive committee.
46. At this juncture, Ld. Amici has directed our attention to Section 4(1)
(b) of the NSGA, 2025.18 It was argued that the provision under the
2025 Act only contemplates that there should be no more than 15
members in the executive committee. While the draft Constitution
already provides for 14 members, there is no conflict. Taking all
factors into account, we are of the opinion that the suggestion(s)
made by the State Associations to increase the number of VPs to
five would not be possible in the present statutory scheme.
47. However, we are inclined to accept the arguments of Mr. Ranjit Kumar,

15 (2016) 8 SCC 535.
16 “18. (….) (d) Zonal considerations - There seems to be no rational basis for the Presidency to be rotated
as per Zones, which has the effect of forsaking merit. A person who has the support of as few as two
or three members in his Zone may end up as the President, if it is the turn of that Zone for election of
President. Recent amendments to the Rules have permitted individuals who are not even from the zone
in question to be nominated to the post. For the same reason, the Vice-Presidents who are elected from
each of the five zones seem to be merely ornamental without any specific functions.”
17 “11. (…) (vii) The EC of AIFF shall consist of 23 persons: (i) 17 members (inclusive of the President, a
Treasurer and one Vice President) will be elected by the electoral college consisting of 35 Associations
representing States/Union Territories; (ii) 6 members shall be drawn from eminent players in the manner
indicated in paragraph 7 above (…)”
18 “S. 4 (1)(b) Executive Committee
(1) Every National Sports Body shall have, —
(b) an Executive Committee which shall consist of not more than fifteen members, of whom—
(i) at least two shall be sportspersons of outstanding merit;
(ii) two shall be from the Athletes Committee to be elected from amongst themselves; and
(iii) such number of ex officio and other members shall be nominated or elected, as the case may be, as
per the International Charters and Statutes and the bye-laws:
Provided that at least four members shall be women:
Provided further that the voting rights of elected representatives of the Athletes Committee in the
Executive Committee shall be as determined by the bye-laws;”
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Ld. Senior Counsel representing AIFF for the increase in the number
of VPs to 3, which shall include one woman. We are of the opinion
that such an amendment will enable women’s representation and,
at the same time, confine the number of the executive committee
to fifteen members.

v. Re: On Disqualification Event(s)
48. There is more than one contentious aspect of the provision regarding
disqualification in the proposed Constitution, all of which were argued
before us at length. These relate to a) disqualification on criminal
charge and conviction, b) disqualification by virtue of being a public
servant, and c) disqualification of persons who have served as an
office-bearer of any NSF from holding a post in the AIFF.
49. It shall befit to begin by reproducing the provision as it finds itself
in the amended Constitution by Justice L N Rao. Article 1.17 of the
Constitution defines disqualification event(s) as the occurrence of
any of the following events with respect to a person:
(a) Not being or ceasing to be a citizen of India;
(b) Attainment of the age of 70 (seventy) years;
(c) Having charges framed or being convicted by a court of
competent jurisdiction in India for an offence punishable
by imprisonment for 2 (two) or more years.
Provided that where charges are framed the person shall
be disqualified until acquittal and where the person is
convicted he shall be disqualified for a further period of
6 (six) years from the date of conviction. If such person
prefers an appeal or an application for revision and the
Court stays the trial or conviction as the case may be,
such person shall not be disqualified during the period
such stay is in operation. However, in regard to an appeal
by a convicted person, the disqualification will not cease
if only a stay of sentence is ordered and not a stay of the
conviction itself;
(d) Being banned from participation in any footballing activity
by any AIFF Judicial Body, till the date of culmination of
the ban;
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(e) Being declared of unsound mind;
(f) Being declared insolvent under applicable law;
(g) Being or becoming a Public Servant or holding a public
office or holding any office or post in a sports or athletic
association or federation apart from Football, except the
Indian Olympic Association; or
(h) Completion of the maximum term of office of any particular
office-bearer as specified in Article 26.3, without serving
the specified cooling-off period of 4 (four) years where
applicable.
(emphasis supplied)

50. Clauses (c), (g), and (h) of Article 1.17 have been contested by
multiple stakeholders. It is primarily argued with respect to clause
(c) that framing of charges per se does not invite culpability so as
it disqualifies a person from holding an office. With regard to clause
(g), it is argued that NSC 2011 does not, by itself, bar public servants
from being members of the General body of the NSFs/State Units.
State associations have sought that the clause (g) be modified to
include only ministers and government servants. In this light, the
State associations seek deletion of the definition of the term public
servant under Article 1.46, which defines public servant “as a person
defined as such under Section 21 of the Indian Penal Code, 1860”.
51. Clause (h), on the other hand, has been suggested for modification
to envisage and include situations where office-bearers of different
NSFs, despite completion of tenure in those NSFs, try to occupy
the position of an office-bearer in AIFF. This suggestion intends to
prevent “persons from rendering tenure restrictions otiose by simply
switching to another sport after finishing tenure in one NSF”.
52. We take the above issues in succession.

a) Disqualification on Criminal Charge and Conviction
53. Mr. Nataraj, appearing for Ministry of Youth Affairs and Sports
submitted that there is a clear distinction between convicted persons
and charge-framed persons; the latter cannot be put on the same
pedestal as the former. During the course of the hearing, a hypothetical
argument was made that in cases of minor offences like dishonour of
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a cheque, the court may frame charges, but the very fact of framing
charges should not preclude a person from contesting and taking
positions of responsibility in the federation. It was suggested that
the disqualification event/termination of membership should only
be for convicted persons who have been sentenced for 2 years or
more. A parallel was drawn to section 8(3) of the Representation of
the People’s Act, 1951 (“RPA”), which speaks of disqualification for
a period of six years only on the event of conviction and sentence
of imprisonment for not less than two years.19 In this regard, our
attention was directed to the 244th Report of the Law Commission
of India,20 which, on discussing disqualifications in the context of
RPA, observes, inter alia:
“Since the stage of framing of charges is based on
substantial level of judicial scrutiny, a totally frivolous charge
will not stand this scrutiny. Therefore, given the concern
of criminalisation of politics in India, disqualification at the
stage of charging is justified having substantial attendant
legal safeguards to prevent misuse.
The framing of charges is therefore not an automatic step
in the trial process, but one that requires a preliminary
level of judicial scrutiny. The provisions in the CrPC require
adequate consideration of the merits of a criminal charge
before charges are framed by the Court. The level of
scrutiny required before charges are framed is sufficient to
prevent misuse of any provision resulting in disqualification
from contesting elections.21
54. It is not in dispute that the above suggestion, qua disqualification
premised on framing of charge, never saw the light of day. While
expressing anguish over the increasing criminalisation of politics,
this Court, in the Constitutional bench judgement of Public Interest
Foundation v. Union of India,22 noted that though disqualification from

19 8. Disqualification on conviction for certain offences.—
(3) A person convicted of any offence and sentenced to imprisonment for not less than two years [other
than any offence referred to in sub-section (1) or sub-section (2)] shall be disqualified from the date of
such conviction and shall continue to be disqualified for a further period of six years since his release.]
20 Electoral Disqualifications, Report No. 244 (Law Commission of India; February, 2014) <https://cdnbbsr.
s3waas.gov.in/s3ca0daec69b5adc880fb464895726dbdf/uploads/2022/08/2022081612.pdf>.
21 N.P. Ponnuswami v. Returning Officer, Namakkal Constituency, AIR 1952 SC 64; Jagan Nath v. Jaswant
Singh, AIR 1954 SC 210; Dr. N. B. Khare v. Election Commission of India, AIR 1958 SC 139.
22 (2019) 3 SCC 224.
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contesting elections upon framing of charges may be desirable, the
Law Commission’s recommendations had not yet fructified into law,
and accordingly, it would be ideal if Parliament examines the issue.
55. We have perused the referred material and arguments in detail. In
view of the fact that the recommendations of the law commission of
India have not adopted by legislature yet, and also in view of the fact
that no relevant parallel has been brought to our notice regarding any
other NSF’s Statutes containing such a provision, we are inclined to
modify the provision of disqualification based on framing of charge
to the standard as envisaged in the later judgement of BCCI i.e.,
“conviction followed by a sentence of imprisonment”.23

b) Disqualification on being or becoming a Public Servant or holding
any office in a sports or athletic association or federation apart
from Football, except the IOA
56. AIFF submits that public servants should not be excluded from
holding office in the federation. It is submitted that being a “Public
Servant” should not be a disqualification event because NSC 2011
does not mandate so. Further, the stringent BCCI Constitution
limits disqualification to “Ministers or Government Servants” only.
The same should not be extended to Members of Parliament or
Members of the Legislative Assembly. It is also submitted that in the
event Sportspersons and coaches serve as Members of Parliament
(MPs), Members of Legislative Assemblies (MLAs), or hold other
public offices, disqualifying them on grounds of holding public office
would create an unjustified restriction on their participation in the
administration of the sport as well as contributing to the public.
Ministry of Youth Affairs and Sports and State associations have
supported the above contentions, with State associations suggesting
that the provision be revised to provide for disqualification only on
the ground of being a minister or Government Servant.

23 BCCI v. Cricket Assn. of Bihar, (2022) 19 SCC 30. “19. The stipulation that the disqualification should
attach on a conviction of an offence may be accepted. However, the further condition that a disqualification
would follow upon a sentence of imprisonment of three years or more cannot be accepted. During the
hearing, BCCI agreed that the disqualification would govern a conviction and sentence of imprisonment.
The reasons set out for the other amendments are acceptable. Subject to what has been observed
above, the amendment as tabulated in Column 3 above does not detract from the basic purpose and
object underlying the judgment of this Court. The amendment, as proposed in Column 3 above, is hence
permitted to be effected.”
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57. At this juncture, we may note that similar arguments were raised before
this Court in the BCCI-I24 wherein the Court discussed and rejected
the contentions raised by the BCCI to the effect that bureaucrats
and ministers should not be disqualified from holding a position on
the Board of Cricket. Referring to the arguments and suggestions,
the Court observed as follows:
“79. The Lodha Committee has, in its meetings, held
extensive interactive sessions and deliberations with a
cross-section of stakeholders…The Committee has in its
wisdom found that the holding of office by the Ministers and
civil servants in the State Associations or in BCCI is not
conducive to the health and promotion of the game (…).
80. The Committee has while making that recommendation
observed:
“… Any elected Councillor shall stand automatically
disqualified after nine years as an office-bearer, and
shall also be disqualified from contesting or holding
the post if he has completed the age of 70 years,
is charged under the penal law, is declared to be of
unsound mind, is a Minister or government servant or
holds any post of another sports body in the country.
***
81. In light of the above we see no compelling reason
for us to reject the recommendation which disqualifies
Ministers and public servants from holding offices in the
State Associations or BCCI.
83. The contention that favours which BCCI receives will
disappear just because a Minister or civil servant is not
an office-bearer in the State association or BCCI has no
real basis to commend itself to us. So also, the contention
that it should be permissible to hold office simultaneously
in BCCI and the State association has not commended
itself to us.”
(emphasis supplied)

24 Board of Control for Cricket v. Cricket Assn. of Bihar, (2016) 8 SCC 535.
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58. However, when the matter again reached before this Court, an
amendment was passed by the BCCI, which was approved by
this Court, restricting the disqualification from being a “minister or
government servant or holding a public office” to being “a minister or
government servant”.25 In agreement with the view of BCCI (supra),
we are inclined to modify the provision in Article 1.17(g) to “being a
minister or government servant”.
59. Further, even if such a person is a public servant, if he or she has
the necessary approval of the government, there should not be a
problem under section 4(2)(e) of the newly enacted NGSA 202526.
The rules and regulations applicable to a government servant provide
a particular standard to be maintained. The standard requires the
public servant to obtain necessary permissions. If these permissions
are taken, perhaps there is no justification to restrict or disqualify a
public servant altogether.

c) Disqualification of persons who has served as an office-bearer
of any NSF from holding a post in the AIFF
60. A suggestion has been made by Mr. Rahul Mehra to amend Article
1.17 (h) to include situations where a person who has served as
an office-bearer of any NSF shall be disqualified from holding a
post in the federation. This argument is supposedly grounded in
the objective to prevent persons from “rendering tenure restrictions
otiose by simply switching to another sport after finishing tenure in
one NSF”. We find that accepting this suggestion might not benefit
the federation and could be too onerous on sports administrators.
A similar provision, which was part of the earlier adopted BCCI
Constitution, was later amended with the approval of this Court in
the following words:
“18. BCCI has submitted that the disqualification from
holding any office or post in a sports or athletic association
or federation apart from cricket needs to be modified since
several cricketers of eminence are associated with other
sporting activities such as football and golf after retirement

25 BCCI v. Cricket Association of Bihar, (2022) 19 SCC 30.
26 “A person shall not be qualified to contest for election or seek nomination to, the Executive Committee
unless such person, if he is a government servant, has necessary approvals from the Government, as
applicable”.
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from cricket and there is no reason to disqualify them on
that ground (…)
19. (…) The reasons set out for the other amendments are
acceptable. Subject to what has been observed above,
the amendment as tabulated in Column 3 above does
not detract from the basic purpose and object underlying
the judgment of this Court. The amendment, as proposed
in Column 3 above, is hence permitted to be effected.”27
61. In this view, we are not inclined to accept this suggestion.

vi. Re: On retaining ‘indirect interest’ in the definition of
‘Conflict of interest’
62. AIFF submits that a conflict of interest, as defined in Article 73.1,
should not include indirect interest. In fact, AIFF argues that while
Article 73.5 adequately covers the scenarios of conflict, it renders
Article 73.1 otiose and unnecessary. To appreciate the contentions,
the relevant provisions are produced hereunder:
“Article 73: Conflict of Interest
73.1. A Conflict of Interest may take any of the following
forms as far as any individual associated with the AIFF
is concerned:
(a) Direct or Indirect Interest: When the AIFF or a Member
or an Affiliated Unit enter into contractual arrangements
with entities in which an individual concerned or his/
her relative, partner or close associate has an interest.
This includes cases where family members, partners or
close associates are in positions that compromise, or
may be seen to compromise an individual’s participation,
performance and discharge of roles.
(b) Roles compromised: When the individual holds two
separate or distinct posts or positions under the AIFF, the
functions of which would require the one to be beholden
to the other, or in opposition thereof.

27 BCCI v. Cricket Association of Bihar, (2022) 19 SCC 30.
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(c) Commercial conflicts: When the individual enters into
endorsement contracts or other professional engagements
with third parties, the discharge of which would compromise
the individual’s primary obligation to the game or allow for a
perception that the purity of the game stands compromised.
(d) Prior relationship: When an individual has a direct or
indirect independent commercial engagement with a vendor
or service provider or commercial partner or broadcast
partner or sponsor in the past, which is now to be engaged
by or on behalf of the AIFF or its Member.
(e) Position of influence: When the individual occupies a
post that calls for decisions of governance, management
or selection to be made, and where a friend, relative or
close affiliate is in the zone of consideration or subject to
such decision-making, control or management. Also, when
the individual holds any stake, voting rights or power to
influence the decisions of a Club / team that participates
in any League(s) under AIFF.
(…)
73.5. It is clarified that no individual may occupy more
than one of the following posts and/or be a part of more
than one of the following at a single point of time except
where prescribed under this Constitution:
(a) Player (Current)
(b) Team Official
(c) Match Official
(d) Member of the Election Committee
(e) Ethics and Disputes Resolution Committee
(f) Auditor
(g) Service Provider (Legal, Financial, etc.)
(h) Contractual entity (Broadcast partner, Commercial
Partner, Sponsor, Security, Contractor, etc.)”
63. On this issue, Ld. Amici submits that the suggestion of AIFF fails
to account for the fact that Articles 73.1(a) and 73.5 cover entirely
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different fields. Article 73.1(a) is focused on indirect conflicts of interest,
conflicts through relatives, partners, or close associates; conflicts
like an Executive Committee Member’s spouse running a football
coaching academy. Article 73.5, on the other hand, broadly prohibits
the individual from holding two posts - a more direct conflict - and
does not speak of his interest through related parties. We are in
agreement with these arguments. On plain reading of both Articles
73.1 and 73.5, it is clear that both cover different fields of conflict.
This Court’s judgment in BCCI has also approved of disqualifications
based on indirect conflicts.28 We see no reason to arrive at a different
conclusion.

vii. Re: On the applicability of AIFF Constitution to State
Associations
64. The state associations have vehemently opposed application of AIFF’s
Constitution to state associations on multiple grounds, inter alia: a)
the original Constitution of AIFF (2017) did not mandate compliance
of NSC 2011 on State associations, b) Societies and Sports, fall in
entries 32 and 33 of the State List (List II, 7th Schedule), respectively
and an NSF’s Constitution should not bind State associations and
local bodies, c) Delhi High Court has upheld the validity of NSC
2011 in Indian Olympic Association v. Union of India,29 confirming
non-extension of NSC on State bodies, d) NSC is to be applied only
on national sports federation, e) this Court in Constitution bench
judgement of Damyanti Naranga v. Union of India30 had held that
right to autonomous functioning is a part of “freedom of association”
guaranteed under Article 19(1)(c). It is argued that the benefit of the
very liberty shall be extended to the state associations and local
sports bodies.
65. This court had the opportunity to scrutinise the arguments qua
Damyanti (supra) in detail in a similar factual conspectus in BCCI-I31
wherein the Court observed that the judgment in Damyanti (supra)
was inapplicable to the case of BCCI because the proposed BCCI
Constitution “did not interfere with or alter the composition of the

28 (2016) 8 SCC 535, para 35.
29 2014 SCC OnLine Del 2967.
30 (1971) 1 SCC 678.
31 (2016) 8 SCC 535.
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State Associations”. However, the present case of Indian Football,
which benefits immensely from a pyramidical structure, is placed on
a different footing than the game of cricket.
66. It shall help to extract Article 2.3 of the proposed Constitution, which
reads as:
“Article 2: Name, Headquarters and Affiliation
Article 2.3- The AIFF is a member of FIFA, AFC and Indian
Olympic Association (IOA) and is recognized as the sole
National Sports Federation of India for Football by FIFA,
AFC, IOA and the Ministry of Youth Affairs and Sports,
Government of India. Accordingly, it is self-obliged to
maintain this recognition and good standing and respect
the statutes, regulations, directives and decisions of FIFA
and AFC as well as the provisions of the Sports Code and
all applicable laws, and to ensure that these are likewise
implemented and respected by its Members”.
(emphasis supplied)

67. Further, Article 15.1 puts an obligation on member associations of
AIFF to conform to AIFF’s Constitution. Article 15.1 reads as under:
“Article 15: Obligations of Member Associations
Article 15.1 Member Associations shall ensure that their
own constitutions/memorandum of association/articles
of association are framed strictly in accordance with this
AIFF Constitution and all applicable laws including but not
limited to provisions relating to composition of governing
body / executive committee, minimum representation of
female players in the respective governing body/ executive
committee, eligibility criteria for appointment to an executive
committee and other bodies, including age and tenure
restrictions and cooling off period, appointment of an
electoral officer and procedure for conduct of elections as
set out in Schedule III to this Constitution, prohibition of
creating titular or honorary posts in Executive Committees
by whatsoever name other than the Executive Committee
Members, disqualification events for membership,
transparency and disclosure obligations, formation of an
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All India Football Federation v. Rahul Mehra & Ors.

Ethics and Disputes Resolution Committee and related
dispute resolution mechanisms including AIFF Judicial
Bodies, CAS, ICAS, creation of Standing Committees,
dispute resolution by way of arbitration as set out in this
Constitution, etc. Members are required to get these
documents verified by the AIFF every 2 (two) years”.
(emphasis supplied)

68. The intervenors and other stakeholders submitted that if the provisions
of the AIFF Constitution are not extended to the State associations
and local sports bodies, then the loophole will be exploited by the
administrators for circuitous exchange of officials, thereby bypassing
well-thought-out provisions of the cooling-off period and term limits.
To this effect, reliance was placed on the judgment of the Delhi High
Court in Rahul Mehra v. Union of India,32 wherein it was observed
that the interest of a national federation in terms of a particular legal
framework will not harm local/state associations if they adopt that
very framework.33
69. Further, it is important to note that the pyramidical structure of
Indian football makes it necessary that all the constituent units and
associations lower in hierarchy must observe and implement the
same level of discipline, fairness, transparency, and good governance
quotients which are applied at the very top. This submission, it was

32 2022 SCC OnLine Del 2438
“114. Consequently, this Court is of the view that the Sports Code must be made applicable to every
constituent of every NSF, including IOA as well as its constituents….Be that as it may, as a matter of
Basic Principles of Good governance and International Best Practices including restrictions on age and
tenure as mandated in the Olympic Charter, what is good for the parent NSF’s including IOA should
also be good for their Members State/District Level Federations and/or Associations.” Accordingly,
respondent No. 1/Union of India is directed not to grant recognition or any facility (monetary or otherwise)
to the IOA or to any NSF and/or any of its affiliated Associations, if they refuse to comply with the Sports
Code as directed by this Court.”
33 See also, BCCI v. Cricket Assn. of Bihar, (2018) 9 SCC 624
“45.1. The Registrar of Societies under the Tamil Nadu Societies Registration Act, 1975 shall upon the
presentation of the said Constitution by the CEO, register the documents forthwith and report compliance
by way of a report to the Secretary General of this Court within four weeks;
45.2. Upon the registration of the said Constitution of BCCI, each of the members shall undertake
registration of their respective Constitutions on similar lines within a period of 30 days thereafter. A
compliance certificate must be furnished to the CoA, which shall file a status report before this Court with
reference to the compliance undertaken by the State Associations; and
45.3. In the event that any State Association does not undertake compliance with the abovesaid
directions, the directions contained in the orders of this Court dated 7-10-2016 [BCCI v. Cricket Assn.
of Bihar, (2016) 10 SCC 23] and 21-10-2016 [BCCI v. Cricket Assn. of Bihar, (2016) 10 SCC 231] shall
revive”. (emphasis supplied)
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argued, needs to be appreciated also in terms of Article 10(3)(b)
of the FIFA Standard Statutes, 2005 which mandate that “when a
regional association applies for membership of a national football
association, its application must mandatorily contain a declaration that
it will always comply with the statutes, regulations, and decisions of
(national association), FIFA, and (relevant confederation) and ensure
that these are also respected by its own members, clubs, officials,
and players”.34 In this regard, our attention was drawn to Article 20.1
of the FIFA Statute 2024, which provides as under:
“20. Status of clubs, leagues and other groups of clubs
1. Clubs, leagues or any other groups affiliated to a
member association shall be subordinate to and
recognised by that member association. The member
association’s statutes shall define the scope of
authority and the rights and duties of these groups.
The statutes and regulations of these groups shall
be approved by the member association.”
70. It is important to note that in view of the chequered history of Indian
football administration, and also that governance of football undisputedly
trickles down from the superstructure to the base, i.e., NSFs conform
to FIFA, it is important that the state associations and local bodies
conform to the NSFs. We see multiple advantages in this approach.
First, the office bearer(s) of the state association will acquire with time
an invaluable experience of football governance in the same manner
as the institutional history of the AIFF. This will happen because
the governance model of both the NSF and state associations will
overlap. Compliance and application of best practices formulated in
consultation with FIFA at the local levels will ensure that the sport of
football remains organised, both in principle and in practice.
71. In view of the FIFA Statute, the relevant comments of Justice L N
Rao and on analysis of the far-reaching implications of this provision,
we are not inclined to accept the argument that the AIFF Constitution
ought not be extended to the state associations and local bodies.

34 FIFA Standard Statutes 2005, “13. The Members of X have the following obligations:
a) to comply fully with the Statutes, regulations, directives and decisions of FIFA, ... [abbreviation or
acronym of the relevant Confederation] and X at all times and to ensure that these are also respected
by its members;
b) to ensure the election of its decision-making bodies; (…)”
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viii. Re: AIFF and Third Parties: Extent of delegation of powers,
functions, and exploitation of rights
72. FSDL suggests a few changes to the proposed Constitution. They
are, namely: a) a relevant amendment to Article 1.2135 to make the
definition of ‘essential aspects’ less restrictive, b) an amendment
to Article 63 to expand the role of private parties in exploitation of
rights under sports’ contracts, and c) also submitted that ‘promotion
and relegation’ should not be a criteria to satisfy the definition of
‘seniormost top division league’, as defined under Article 1.54.
73. Before we examine the tenability of the above prayers in detail,
it shall be useful to understand the context in which the FSDL’s
suggestions emerge.
74. FSDL is a company, incorporated with the objective of improving
and popularising football in India. On 09.12.2010, a Master Rights
Agreement (‘MRA’) was entered into between FSDL and AIFF,
resulting in the establishment of the Indian Super League in 2014,
which, since 2019, has been India’s senior-most top division league.
Under the MRA, FSDL was allegedly granted “exclusive commercial
rights to the National Football Team, all football competitions organized
by AIFF in India, as well as to the ISL, which include advertising
rights, broadcast rights, film rights, franchise rights, merchandising
rights, sponsorship rights, video rights, data rights etc”.36
75. FSDL submits that private participation in the sport of football is an
internationally acclaimed concept and utilising the rights given to it
under the MRA, FSDL has only furthered the growth and development
of Indian football. FSDL is rather concerned that despite its contributions
and achievements, the proposed Constitution will put an embargo on
agreed structures of commercial arrangements by way of a prohibition.
It is submitted that Constitutional provisions should not circumscribe and
put fetters on the commercial wisdom of AIFF to enter into contracts
suitable to its interest. In other words, commercial exploitation of
sports per se cannot be said to be detrimental to the interests of sport.

35 “1.21. “Essential Aspects” shall mean the organisation, supervision, maintenance of rules and regulations,
promotion of the sport, approval of authority and scope of rights of stakeholders, preservation of the
sanctity of promotion and relegation, and ensuring of compliance with FIFA/AFC statues with respect to
the sport of football.”
36 As submitted before this Court and Justice L N Rao.
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FSDL also relied on FIFA Statutes which, in FSDL’s understanding
contemplate that “commercial rights can be utilised either by the
federation exclusively (in this case, AIFF), jointly with a third party or
entirely by a third party”.37 Thus, while the MRA will expire in 2025, its
operation can be renewed and FSDL’s interest ought to be protected.
76. Other stakeholders have countered the above submissions, arguing
that there is no objection to AIFF’s collaboration with private
parties; rather, it is the extent of the collaboration and delegation
of essential functions that is being sought to be regulated by the
proposed Constitution. A few provisions of the MRA were highlighted
to demonstrate that such abdication of responsibility by a national
federation cannot be countenanced. For instance, clause 5.25 of
MRA permitted FSDL to set up the senior-most league of football in
India and decide on its own wisdom the “format, rules, and structure
of the league and the teams and players which will compete in it”. In
this view, FSDL had virtually acquired the right to commercialise each
and every aspect of the new league which should not be permitted.
77. It was therefore suggested that defining essential aspects shall put
in place a boundary to ensure healthy future partnerships between
private players and the federation. Such boundary will fall in line with
clause 6.1(b) of the NSC 2011, which proscribes delegation in the
nature of MRA and rather envisages AIFF to be “fully responsible
and accountable for the overall management”.38
78. In terms of the above, Ld. Amici has reflected on the suggestions
in the following manner:
“8.8. Regarding Article 63, FSDL first proposes the addition
of the word ‘ownership’ to Article 63.1 to further clarify
that ownership rights of the league will rest with AIFF;
this suggestion, which only serves to clarify a pre-existent
position, may be accepted.

37 As submitted before Justice L N Rao.
38 National Sports Development Code of India, 2011, Clause 6.1 (b) “(b) National Sports Federations:
NSFs are fully responsible and accountable for the overall management, direction, control, regulation,
promotion, development and sponsorship of the discipline for which they are recognized by the concerned
International Federation. They are expected to discharge these responsibilities in consonance with the
principles laid down in the Olympic Charter or in the charter of the Indian Olympic Association or the
relevant International Federation, as the case may be while being compliant with Government guidelines
applicable to NSFs.”
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All India Football Federation v. Rahul Mehra & Ors.

8.9. FSDL additionally suggests that Article 63.3 be
amended to take away a clause that says AIFF “shall not
be bound by any request/demand of any third party in this
regard” - language inserted to ensure that AIFF is always
able to prioritize the interests of football in India over
private interests. FSDL’s suggestion that this be removed
to enable private participation in football is incoherent -
there is no reason given why private participation cannot
thrive in the presence of such a clause. This suggestion
must therefore be rejected.
8.10. Lastly, FSDL suggests that Article 63.4 be amended
to add “or entirely through a third party”, which would have
the effect of enabling AIFF to divest itself completely of
involvement - far from maintaining primacy, this could
mean AIFF may have no role at all in the organization of
certain competitions etc. There is already no bar on the
participation of third parties - FSDL’s proposed change
would serve only to allow AIFF to relieve itself completely
of responsibilities it must have under the NSC, 2011. This
must therefore be rejected.”39
79. Though there was agreement at the bar on FSDL’s suggestions on
the addition of the word ‘ownership’ in Article 63.1, we are of the
opinion that the expression is superfluous and unnecessary. It is
evident that AIFF has objections to the use of the word ‘organisation’
and ‘promotion and relegation’ (which we have discussed later) in
the definition of essential aspects under Article 1.21. Article 1.21,
which had no equivalent in the Constitution drafted by the CoA, is
in the nature of a membrane separating the rights and duties of the
federation and third parties with whom the federation might enter
into contract(s). On a holistic reading of the provision, we do not
find it creating any harm to the private interest, except for the fact
that it will impact the working of the text of the MRA. We are mindful
of our duty that the task of Constitutional finalisation will pave the
way into a new era of Indian football, one that is based on fairness,
transparency, and accountability. While we are satisfied with the
provision under Article 1.21, and we have been apprised that the

39 Extracts, Written Submissions on behalf of Amici Mr. Gopal Sankaranarayanan and Mr. Samar Bansal.
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term of the ongoing extended MRA will expire in 2025, we make it
clear that it shall be open for the federation to enter into contractual
settings, but in complete obedience to the boundary as laid down in
Article 1.21. We believe that it is the only way a national federation
can be held accountable towards its duty to the prosperity of the
vibrant game of football. In this view, we are not inclined to adopt
FSDL’s suggestions qua Article 63 as well, which are premised and
expand upon the definitional clause in Article 1.21.

ix. Re: Promotion and Relegation in Indian Football
80. Article 1.54 of the proposed draft defines the terms ‘senior-most top
division league’ as follows:
Article 1.54 – “Seniormost Top Division League” shall mean
the league competition owned, operated and recognized by
the AIFF, that implements the principles of promotion
and relegation, and meets all requirements prescribed
by the AFC for being eligible to obtain a direct slot in the
Asian Champions League.
(emphasis supplied)

81. FSDL has objected to the words ‘operated’ and ‘that implements
the principles of promotion and relegation’ and sought their deletion
mainly on the grounds that the use of these words in an important
provision, coupled with Articles 1.21 and 63 as discussed in the
preceding section, impinges upon the autonomy of FSDL as originally
secured under the MRA.
82. Many intervenors argued that the suggestions of FSDL run contrary
to FIFA Statutes, which adopt the principles of promotion and
relegation. Ld. Amici have supported their submission by placing
reliance on Article 11 of FIFA Statutes 2024 which provides that a
“club’s entitlement to take part in a domestic league championship
shall depend principally on sporting merit. A club shall qualify
for a domestic league championship by remaining in a certain
division or by being promoted or relegated to another at the end
of a season.”40

40 Article 11(1), FIFA Statutes 2024.
[2025] 9 S.C.R. 1195

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83. It was further highlighted that decisions adopting principles of
promotion and relegation were taken way back in 2019 in a meeting
between the AFC, AIFF and FSDL; however, only the principle of
promotion has been introduced and not the aspect of relegation.
84. To support its case, FSDL cited the judgment of the Court of Arbitration
for Sport (‘CAS’) in Miami FC v. FIFA,41 which admittedly observed
that while the principles of promotion and relegation are ordinarily the
norm, their implementation cannot be made compulsory for national
federations which have never implemented them before. FSDL’s
submissions were countered at the bar citing the 2019 decision
regarding the implementation of the principles of promotion and
relegation from the 2024-25 season.
85. Ld. Amici submitted that the FSDL’s reliance on Miami (supra) is
misplaced as the said judgment actually held that the principle of
promotion/relegation is ordinarily the norm, but may not be compulsory
for those national federations which have never implemented any form
of promotion/relegation and were being called upon to do so for the
first time. Since ISL already permits promotion and has committed to
implementing relegation as well from the 2024-25 season, the said
CAS judgement is inapplicable.
86. Before deliberating on the abovementioned aspects, it is beneficial
to understand the principle of promotion and relegation itself. In one
academic work,42 the principle and its benefits are discussed in the
following words:
“Promotion and relegation serves as a means of entry into
the open leagues. Any person could start his or her own
team, begin competing at the bottom of the league and
gain promotion to the major league over time. Entry could
also be achieved by purchasing an existing minor league
team and hire quality players and coaches to achieve the
same result. Entry in an open league does not require
approval by a franchise fee or existing team owners. (…)

41 CAS 2017/O/5264.
42 Jasina, John and Rotthoff, Kurt W., A Model of Promotion and Relegation in League Sports (November
1, 2009). Journal of Economics and Finance, Volume 36, Issue 2, Pages 303-318, Available at SSRN:
https://ssrn.com/abstract=1512144.
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Promotion and relegation add an additional dimension to
league play that is not present in closed leagues. In order
to avoid relegation, teams must play at the highest level
all season long. Competition among top division teams to
avoid relegation produces more spending on player talent
than large market teams in a closed league. Teams in lower
divisions will spend more on player talent than small-market
teams in a closed league since the prospect of promotion
means higher expected profit. Higher spending on player
talent at each hierarchical level means that the overall
quality of play will be higher in an open league. If fans
derive utility from the quality of on-field play, fans of open
leagues will have higher utility than fans of closed leagues.”
(emphasis supplied)

87. As of 03.04.2025, the Indian men’s football team’s international
ranking is 127.43 Taking into account the fact that Indian football
began way back in time and also the fact that Indian sports have
flourished with time, it is an opportune moment to decide that hereon,
Indian football will not be played in silos. Healthy competition in
Indian football shall only benefit and take the sport to new heights.
After going through the literature on the principles of promotion and
relegation, the arguments of the counsels, as well as the written
material placed on record, we are of the opinion that the proposed
provisions do not necessitate any amendment.

x. Re: Applicability of principles laid down in BCCI Judgment
to the present case concerning football administration
88. The judgments and orders concerning the management and
organisation of BCCI had far-reaching impacts. The BCCI series
of cases envisaged and embarked on a new dawn of Indian sports
governance, and also developed principles and best practices which
can be imbibed in letter and spirit. AIFF and state associations have
submitted that the BCCI judgment cannot be applied to football
governance because BCCI is not an NSF and therefore does not
fall within the contours of NSC 2011 as well.

43 See, World Ranking (India) <https://inside.fifa.com/fifa-world-ranking/IND> (last accessed on 05 June
2025).
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All India Football Federation v. Rahul Mehra & Ors.

89. This argument cannot be accepted for more than one reason. While
the validity of NSC 2011 has been previously upheld, this Court’s
order dated 03.08.2022 in the present appeals aptly clarifies that
NSC 2011 must be read to effectuate its intent and purpose and not
in a manner of Statute.
90. This present exercise is primarily about football, but on a broader
level, is also an exercise to instil professionalism, efficiency, and
fairness in sports administration, which shall take Indian football to
greater heights. Distinguishing BCCI judgments only on the ground
that BCCI is not an NSF, while AIFF is, does not yield any good. In
this view, the arguments advanced by AIFF and State association
are rejected.

xi. Re: Amendments to the AIFF Constitution and the need for
the Supreme Court to retain control
91. Article 23 of the proposed Constitution deals with the mode of
amendment to the AIFF Constitution. The Article reads:
“Article 23: Amendments to the Constitution
23.1. The AIFF Constitution, Schedules thereto and
Regulations can be amended at a Meeting of the AIFF,
provided that such provisions shall not be repealed, added
to, amended or altered except when a resolution to that
effect is passed and adopted by a 75% (seventy five
percent) majority of the members present and entitled to
vote at a Special General Meeting of the General Body
convened for the purpose or at any Annual General
Meeting. The quorum for any such Meeting shall be 75%
of the total strength of the General Body.
23.2. Any proposals for an amendment to this Constitution
must be submitted in writing by at least 3 (three) members
jointly with a brief explanation to the AIFF General
Secretariat by a Member or by a member of the Executive
Committee 25 (twenty five) days before the date of the
concerned meeting.”
92. In his suggestion to the aforesaid Article, Mr. Rahul Mehra submits
that the Article be amended to provide that “no amendments to the
Constitution must take effect without leave of the Hon’ble Supreme
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Court as mandated by BCCI-II”.44 Other intervenors have supported
the suggestion and sought that Article 23 be amended to insert that
“Article 23.3 - Any such amendment shall not be given effect to
without the leave of the Hon’ble Supreme Court.”
93. In BCCI-II, this Court approved a similar suggestion by holding as
under:
“43. Clauses 29, 33(1), 33(2) and 45 of the draft Constitution
with the modifications suggested by the Amicus Curiae
read as follows:
(…)
Clause 45.—These Rules and Regulations of
BCCI shall not be repealed, added to, amended or
altered except when passed and adopted by a 3/4th
majority of the members present and entitled to vote
at a Special General Meeting of the General Body
convened for the purpose or at the Annual General
Meeting. Any such amendment will not be given effect
to without the leave of the Hon’ble Supreme Court.”
44. We approve the above clauses. We are emphatically
of the view that once the draft Constitution has been
approved by this Court, any amendment should not be
given effect to without the leave of this Court.”
(emphasis supplied)

94. We have considered the above submissions. The anxiety and
concerns of the stakeholders that the approved Constitution might be
given a go-by by the federation officials if safety valves are not put
in place are justified. In this view, the suggestion regarding insertion
of “Article 23.3 - Any such amendment shall not be given effect to
without the leave of the Hon’ble Supreme Court” is accepted for the
present. However, we are of the clear view that it is not appropriate
to have continuous monitoring of a sports federation by any forum,
including the Supreme Court. Having taken up the matter and ensured
that the Constitution is brought to this stage, it is necessary to take it
to its logical end. Our monitoring will only be that far and no further.

44 BCCI v. Cricket Association of Bihar, (2018) 9 SCC 624.
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All India Football Federation v. Rahul Mehra & Ors.

xii. Re: Whether the current AIFF administration is a permanent
or interim body?
95. The erstwhile Constitution drafted by the CoA contained Article 84 as
the transitory provision, which provided for a fresh election after the
approval of the Constitution by this Court. The said provision read:
“Article 84.1. Once the AIFF Constitution is approved by the
Hon’ble Supreme Court, an emergent Special General Body
Meeting may be convened by any 3 Full Members with a
notice of 7 days to adopt the AIFF Constitution as approved
by the Hon’ble Supreme Court of India, and the necessary
particulars of time and date of the same will be entered in
Article 85. However, in accordance with the order dated
18.05.2022 of the Hon’ble Supreme Court, the first Election
under this Constitution will be conducted by the Committee
of Administrators appointed by the Hon’ble Court.”
96. While the draft Constitution formulated by the CoA was in place,
elections to the federation were conducted and the current executive
committee was elected, pursuant to the order of this Court dated
03.08.2022. The said order specifically mentioned that the election
was only an interim arrangement and no equity based on the
03.08.2022 order shall be claimed in the future. The relevant portion
of the said order is set out in paragraph 17, which is as under:
“17. For the above reasons, we order and direct that:
(i) The elections to the Executive Committee of AIFF
should be held expeditiously and shall be concluded in
terms of the time schedule which has been indicated
in the tabulated statement set out above;
(ii) The elections shall be conducted in a manner
consistent with the provisions of Article 26 of the draft
Constitution. The persons chosen as representatives
shall have to conform to Article 26.
(iii) This would be an interim arrangement without
prejudice to the rights and contentions of the parties;
(iv) The interim Body would continue for a period of
three months subject to further orders of this Court
till the Constitution is finalized;
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(v) The interim Body shall not claim any equities on
the basis of this order and the present arrangement
would be subject to further orders;
(vi) The CoA shall be apprised of the decisions of
the elected Body; and
(vii) (…)”
(emphasis supplied)

97. The above order was modified by the order dated 22.08.2022, wherein
the court issued certain directions as elections to the federation
were delayed, specifically taking into account the then-commencing
under-17 Women’s World Cup 2022 tournament as well as the
decision of FIFA to suspend AIFF from its membership. The relevant
portion of the 22.08.2022 order is as under:
“11. Bearing in mind the importance of the Under-17
Women’s World Cup 2022 tournament being held in India,
the following directions are issued on the IA:
(i) The election programme, which was fixed in
pursuance of the order dated 3 August 2022, is
permitted to be modified by extending the date of
election by one week;
(…)
(vi) Time for the completion of the elections which
were scheduled to take place on 28 August 2022
shall stand extended by a period of one week. The
Returning Officers shall, within the said period, refix
the modalities for the filing of nominations from the
stage which was reached on 13 August 2022 and
ensure that the elections are completed on schedule;
(…)
12. The above directions have been issued in modification
of the previous orders of this Court to facilitate the
revocation of the suspension which has been imposed on
AIFF by FIFA and the holding of the Under-17 Women’s
World Cup 2022 in India. In the event that the above
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process is not taken to its logical conclusion, the Court
would consider any further order at the subsequent stage.”
(emphasis supplied)

98. After the executive Committee was put in place as a result of the
elections held pursuant to orders dated 03.08.2022 and 22.08.2022,
the modified version of the Constitution formulated by Justice L N
Rao deletes Article 84; Justice L N Rao has commented on the
deletion, observing that:
“…Owing to the fact that the existing Executive Committee
and the General Body of the AIFF were elected following
due process, the need has not been felt to immediately
end their terms and to impose fresh elections.
The transitory provision laid down in the draft Constitution
stands deleted. The existing elected members of the
Executive Committee shall stay in power and serve their
permitted full term(s) of 4 (four) years, subsequent to
which fresh elections shall be conducted in the manner
prescribed in this amended Constitution.”45
99. Mr. Bhaichung Bhutia (intervenor), Mr. Rahul Mehra and other
intervenors argue that the transitory provision should be reinstated
in order to ensure that fresh elections are conducted after the
approval of the Constitution by this Court. Ld. Amici has supported
the suggestion, arguing, inter alia, that a) fresh elections be held as
electoral college pursuant to this Court’s earlier order will witness a
shift in terms of the latest draft of the Constitution, b) that the order
dated 22.08.2022 only altered the schedule of elections and no
comment was made regarding the arrangement being an interim
arrangement as order dated 03.08.2022 envisaged, c) that there are
serious irregularities and lapses committed by interim administrators.
100. Having given out serious consideration to the above arguments, we
are of the opinion that even if we assume that the current AIFF is
a permanent body, its functioning would always be subject to the
orders passed by this Court. Though they were elected for a term
of four years, their term will expire in 2026, which means that the

45 LNR Report, para 20.
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current executive committee will continue only till September 2026,
which is less than a year from today.
101. In the facts and circumstances of the case, we are of the opinion that
the current executive committee can be treated as a permanent body
which shall discharge its function in accordance with the relevant
laws as well as the AIFF Constitution.
102. Other objection(s)/suggestion(s)-: Till here, we have dealt with
objections to certain clauses of the draft Constitution which were
specifically raised and argued before us. As regards other clauses,
there is no contest in the court. However, we have noted that certain
objections/suggestions do exist with respect to other clauses in written
submissions filed by various parties. The Amici have compiled those
objections. We will now consider them.
103. On the definition and criteria of the Candidate: Mr. Rahul Mehra
submits that there is an inconsistency between Articles 1.11 and
25.4 so far as the dual requirement of citizenship and residence
is concerned. While the former requires only Indian citizenship for
being a candidate of the executive committee, the latter reads as
“a candidate for the post of an AIFF Office-Bearer must be a citizen
and resident of India”. Mr Mehra suggested that the requirement in
Article 25.4 be accepted and Article 1.11 be modified accordingly.
We are in agreement with the suggestion as it brings certainty and
clarity to the provision. The provision is to be amended accordingly,
requiring a candidate to be a citizen and resident of India.
104. Further, it is important to note that in the draft Constitution, there is
no prescription of the minimum age for contesting the elections. We
are of the opinion that Articles 1.11 and 25.4 relating to ‘candidate’
and the condition for a candidate for the post of AIFF office bearer
be amended to read as follows:
“Article 1.11: “Candidate” is any person standing for
elections to the AIFF Executive Committee who has been
proposed and seconded in the manner laid down in Art.
5.2 of Schedule III to this Constitution. The candidate
shall be a citizen and resident of India who has attained
at least twenty-five years of age and be a voting member
of AIFF’s General Body.
[2025] 9 S.C.R. 1203

All India Football Federation v. Rahul Mehra & Ors.

Article 25.4: A candidate for the post of an AIFF Office-
Bearer must be a citizen and resident of India who has
attained at least twenty-five years of age. Such a person
shall also be a voting member of the General Body.”
105. We have introduced this in view of the fact that Section 4(2) of
the NSGA 202546 prescribed twenty-five years as a condition for
participating in the election.
106. We also agree with the suggestion to insert a new provision 25.4 (A)
in the draft Constitution in terms of the mandate of the 4th proviso
to Section 4(2) of the 2025 Act. Article 25.4 (A) will read as follows:
“Article 25.4(A): A person shall not be qualified to contest
for election or seek nomination to, the posts of the
President or the Vice Presidents or the Treasurer, unless
such person is a sportsperson of outstanding merit or, has
previously served as a member for at least one full term
in the Executive Committee of the AIFF or as an office
bearer in its affiliate unit.”
107. Definition of ‘immediate family’: In Article 1.32, the definition of
“immediate family” or “immediate family member” does not include
sibling(s). It was suggested that the word be added in the interest
of resolving conflicts of interest, administrative ethics, and fairness.

46 Section 4: Compliance with certain requirements by National Sports Bodies
(1) (…)
(2) A person shall not be qualified to contest for election or seek nomination to, the Executive Committee,
unless—
(a) such person is a citizen of India who has attained at least twenty-five years of age;
(b) the nomination of such person is duly proposed and seconded by a voting member of the General
Body;
(c) such person is not declared to be of unsound mind;
(d) such person complies with the International Charters and Statutes and bye-laws relating to age and
term of the Executive Committee:
Provided that such person shall not be more than seventy years of age on the last date of nomination
for election:
Provided further that any person, aged between seventy and seventy-five years, may contest elections
or seek nominations, if permitted by the International Charters and Statutes and the bye-laws and in case
such person is elected, he shall serve for a full term;
Provided that such person, if he is a government servant, has necessary approvals from the Government,
as applicable:
Provided that a person shall not be qualified to contest for election or seek nomination to, the posts of the
President or the Secretary General or the Treasurer, unless such person is a sportsperson of outstanding
merit or, has previously served as a member for at least one full term in the Executive Committee of the
National Sports Body or as the President, or the Secretary General or the Treasurer in its affiliate unit
(…).
(emphasis supplied)
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We are in agreement with the suggestion. The Article is amended
accordingly.
108. Obligation of member associations: We have previously held that
the AIFF Constitution can be extended to member associations and
local bodies. In the same vein, it was submitted that Article 15 must
include the word ‘disqualification event(s)’ as one of the domains to
be looked after by the member associations, alongside age, tenure,
and cooling-off period, etc. We accept the suggestion.
109. Suspension and Resignations: AIFF suggests that while Article
17 requires 75% votes to revoke a suspension, no mirror provision
requiring a minimum percentage of votes for imposing the suspension
in the first place is given. It is suggested that an equivalent voting
requirement for suspension be given. We are of the view that such
a requirement will be in the interest of fairness and certainty. It is
therefore directed that the provision be amended to include an
equivalent percentage of votes for imposing the suspension.
110. Executive committee and concurrent memberships: The original
draft Article 25 by CoA read as under:
“Article 25.3. At any given point of time:
(a) (….)
b) In the event a person is elected as an Office-Bearer
in the Executive Committee of the AIFF and holds a
position of an Office-Bearer in a Member Association,
he/she shall automatically be deemed to have vacated
his/her position in the Member Association.
c) Similarly, in the event that a person is elected
as an Office-Bearer in a Member Association and
holds a position of an Office-Bearer in the Executive
Committee of the AIFF, he/she shall automatically
be deemed to have vacated his/her position in the
Member Association.
d) In case of suspension / expulsion of the Member
of which the individual is a representative, the office
held by its representative shall be deemed to have
been vacated.
e) (….)”
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All India Football Federation v. Rahul Mehra & Ors.

111. The aforesaid clauses (b) to (d) were deleted by the Constitution
formulated by Justice L N Rao with insertion of an unrelated clause
(b), noting that while “no direct conflict of interest could be assumed
qua clauses (b) and (c), clause (d) is an unjust disqualification given
that “when a Member of General body gets elected to EC, the member
is not only representing his/her member association but also acting
in his administrative capacity in the EC”.
112. Some stakeholders have sought reinstatement of the deleted
clauses in the latest draft of the proposed Constitution. On prima
facie analysis, clauses (b) and (c) of the erstwhile provision seem
very important. Firstly, they are against holding two offices at the
same time. Second, they will ensure that an official at the national
federation is not overworked with responsibilities at a member
association and vice versa.47 In this view of the matter, we reinstate
the above extract clauses (b) and (c) as clauses (c) and (d) in the
proposed Article 25 of the Constitution.
113. So far, deletion of clause (d) is concerned, we find merit in the
observations of Justice L N Rao with respect to its deletion. A
member of the executive committee is primarily not for taking care
of her association’s interest, but rather for the AIFF at large. The
suspension of the member association of such an elected member
should not hamper her from discharging her duties as a member of
the executive committee. We are therefore not inclined to reinstate
the erstwhile clause (d) in the proposed provision.
114. Acting President: AIFF suggests that Article 25.6 be amended
to “include a scenario wherein the elected Senior Vice President
is also incapacitated from discharging his duties, along with the
President. In the absence of such Senior Vice President, one of
the other Vice Presidents or a member of the Executive Committee
elected by ballot with a simple majority, could serve as Acting
President, till the subsequent AGM.” We are inclined to accept
the suggestion and modify the provision to include that in the
absence of vice presidents, an executive committee member may
be elected with a simple majority to serve as acting president till
the subsequent AGM.

47 Board of Control for Cricket v. Cricket Assn. of Bihar, (2016) 8 SCC 535.
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115. Quorum: It was suggested that in Article 41.2, no business transaction
pertaining to “commercial arrangements and agreements pertaining
to commercial and other rights for a period of more than four years or
for an amount exceeding Rs. 5,00,00,000 (Indian Rupees Five Crore)”
be inserted. Such an insertion will bring Article 41.2 into consonance
with Article 20.9(m),48 it is argued. We accept this suggestion.
116. Disciplinary Committee: Article 46.1 of the AIFF Constitution
provides for a disciplinary committee to consist of a chairperson, a
deputy chairperson, and such other members as may be deemed
necessary. The provision requires all members of the committee to
have a legal background. AIFF has suggested that the provision be
modified to mandate a legal background only for the chairperson
and deputy chairperson. It is argued that such a change will bring
the provision into agreement with the structure of FIFA’s disciplinary
committee.49 We find merit in the contention. The objectives of the
disciplinary committee shall only be furthered if it is more inclusive,
consisting of persons from varied fields, spearheaded by legal minds
who will ensure due procedure in its decision. In this view, we accept
this suggestion.
117. Appeal Committee: On the same lines as the disciplinary committee,
we are inclined to modify Article 47 to provide that only the chairperson
and deputy chairperson shall be required to have a legal background.

48 “20.9. The General Body of the AIFF shall have the following powers and functions:
Subject to the provisions of this Constitution regarding manner of dealing with Rights and maintaining
overall control of the AlFF over its Competitions and Rights therein, to decide regarding whether to renew
existing commercial arrangements and agreements pertaining to commercial and other rights as well
as and to decide regarding whether to enter into any new commercial arrangements and agreements
pertaining to commercial and other rights as well as determining a transparent, judicious and equitable
process for the above keeping the best interests of Football in mind.
Provided that any decision regarding such agreement and/or arrangement for a period longer than 4
(four) years must be approved at an AGM/SGM by at least 75% (seventy five percent) of the Members
present and eligible to vote. Further, in the event that there is any decision to be made regarding such
agreement and/or arrangement exceeding amount Rs. 5,00,00,000 (Indian Rupees Five Crore), it must
be approved at an AGM/SGM by at least 75% (seventy five percent) of the Members present and eligible
to vote”
49 See, generally, <https://inside.fifa.com/legal/judicial-bodies> “Disciplinary Committee (Composition)
The Disciplinary Committee shall consist of a chairperson, a deputy chairperson and a specific number
of other members. The chairperson and deputy chairperson of the Disciplinary Committee must be
qualified to practise law. The committee shall act in accordance with the FIFA Disciplinary Code. It shall
take its decisions in the presence of at least three members. In special cases, the chairman may decide
alone. The Disciplinary Committee pronounces the sanctions described in the FIFA Statutes and the
FIFA Disciplinary Code on member associations, clubs, officials, players, intermediaries and licensed
match agents. The disciplinary competence of the Congress and the Executive Committee with regard
to the suspension and expulsion of members is reserved.”
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All India Football Federation v. Rahul Mehra & Ors.

This amendment will bring the provision into consonance with the
composition of the appeal committee of FIFA.50
118. Dispute Resolution and Grievance Redressal: It was suggested
that, as sports events are time sensitive for athletes, a time limit (of
no more than 30 days) must be prescribed for rendering decisions
by first instance and appellate bodies. Ld. Amici has supported
this argument and suggested that a proviso may be inserted
signifying that “when the decision would be concerning a matter
of expediency, the time limit would be 30 days”. Article 51.1 of the
draft Constitution provides that “Any and all disputes affecting or
involving the AIFF, Full, Associate or Provisional Members, including
the individual members thereof, Clubs or their members, Leagues
or other Competitions, and members of such Leagues, Officials,
Referees and Licensed Match Agents shall be referred by the AIFF
in the first instance for hearing and redressal to the Ethics and
Disputes Resolution Committee”.
119. The provision deals with various stakeholders, including individual
members and disputes pertaining to competitive events. We find
merit in the suggestion so far as the players’ case is concerned.
We direct that the Article 51 be modified to insert a proviso stating
that “Provided that when the decision would be concerning a matter
having a bearing on a player’s participation in an upcoming event/
competition or a case concerning a matter of expediency, the matter
be taken on priority and an expeditious decision be taken, preferably
within a period of 30 days”.
120. It was further suggested that the time limit of 3 months imposed in
Article 51.15 on the arbitral tribunal51 to conclude the proceedings

50 Ibid. “Appeal Committee (Composition) The Appeal Committee is composed of a chairman, a vice-
chairman and the number of members deemed necessary. The chairman and the vice-chairman must
have legal training. The Commission shall act in accordance with the FIFA Disciplinary Code Decisions
are made in the presence of at least three members. In special cases, the chairman may decide alone.
The Appeals Committee is responsible for the handling of appeals against decisions of the Disciplinary
Commission, which FIFA regulations do not define as final. The decisions of the Appeals Committee are
final and binding on all parties concerned. All rights to appeal to the Court of Arbitration for Sport (CAS)
are reserved”.
51 Article 51.15 - The Arbitral Tribunal shall make best efforts, if possible, to conclude the proceeding in
summary process at the earliest within 3 (three) months from reference being so made. The conclusive
award of the Tribunal shall be final and binding on all the parties including the AIFF. The seat and the
venue of the Tribunal shall be at New Delhi and appropriate jurisdictional Court, namely the Delhi High
Court, would have exclusive jurisdiction to entertain any proceeding as per the applicable provisions of
the Arbitration and Conciliation Act 1996, as amended from time to time.
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be reduced to 30 days. We find merit in the suggestion and direct
insertion of a proviso on a similar line of Article 51.1. The proviso
shall read: “Provided that when the decision would be concerning a
matter having a bearing on a player’s participation in an upcoming
event/competition or a case concerning a matter of expediency, the
matter be taken on priority and an expeditious decision be taken,
preferably within a period of 30 days”.
121. Schedule III: Election Bye-Laws of All India Football Federation:
It was suggested that the erstwhile Article 9.2 of the third schedule
drafted by CoA52 contained a provision of contesting candidates
nominating their agents during polls, the latest draft of the Constitution
deletes the provision of nomination and only allows contesting
candidates to submit the name of such persons to the returning
officer.53 The procedure for nomination remains, but the right to
nominate has been extinguished. We have considered the argument
and decided to restore Article 9.2 as it was drafted by CoA in its
original form.
122. Conclusion: Thus, we have approved the provisions of the
Constitution in the above terms. We direct the AIFF administration
to call for a special general body meeting and adopt the draft
Constitution with the modifications in this judgment. This shall be
done at the earliest, preferably within 4 weeks. We are of the firm
opinion that the Constitution, once adopted in terms of Article 84,
will mark a new beginning for Indian football and take the sport to
greater heights.
123. Before we part with the judgment, we must record our appreciation
for the assistance rendered by all counsels, accompanied by young
members of the bar, who argued their points with precision, passion
and patience. We also record our appreciation for the invaluable
assistance rendered by Ld. Amici, Mr. Gopal Sankaranarayanan and
Mr. Samar Bansal to this Court.

52 Article 9.2. Each contesting candidate can nominate one person (if he/she so desires) to be present at
the Poll (Polling station). All candidates must submitted the name of such person to the Returning Officer
within 2 days of publication of final list of contesting candidates in Form 6 along with valid government ID
proof of the same which must be carried by the representative on the polling day.
53 Article 9.2. All candidates must submit the name of such person to the Returning Officer within 2 (two)
days of publication of final list of contesting candidates in Form 6 along with valid government ID proof
of the same which must be carried by the representative on the polling day.
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124. Our country is brimming with promising sporting talent which seeks
suitable avenues and organisational support. We need to channelise
this talent efficiently – from village fields to international platforms.
We believe that the Constitution of AIFF is an important structural
foundation in this regard and the stakeholders of Indian sports will
have an important role in ensuring that Indian football remains thrilling,
competitive and value oriented and continue to make its mark in the
national and international landscape.
125. Order accordingly.

Result of the case: Directions issued.

†
Headnotes prepared by: Divya Pandey