Supreme Court of India
THE TIRUCHIRAPPALLI DISTRICT CRICKET ASSOCIATIONversusANNA NAGAR CRICKET CLUB & ANR. ETC.
- Citation
- 2026 INSC 154
- Decided
- 13 February 2026
- Disposal
- Case Partly allowed
Holding
The S. Nithya judgments are not applicable to cricket associations, and the BCCI judgment does not obligate district cricket associations to model their constitutions on the BCCI Constitution.
Summary
The Tiruchirappalli District Cricket Association (TDCA), a society registered under the Tamil Nadu Societies Registration Act, 1975, was challenged by a former office‑bearer (respondent No.2) who sought a fresh voters list and a free, fair election, invoking directions from the High Court that were based on the S. Nithya judgments concerning athletics governance. The High Court had also ordered the TDCA to amend its constitution to align with the BCCI Constitution and to ensure that 75% of its members be eminent sportspersons, as mandated in S. Nithya. The TDCA appealed, arguing that the S. Nithya directives were specific to athletics and not applicable to cricket, especially in view of the earlier Supreme Court decision in BCCI v. Cricket Association of Bihar which did not prescribe such requirements for cricket bodies. The Supreme Court held that the S. Nithya judgments are inapplicable to cricket associations because they address a different sport and that the BCCI judgment does not compel district cricket associations to model their constitutions on the BCCI Constitution. While the Court rejected the demand to restructure the TDCA’s constitution on the BCCI model, it emphasized that state associations may voluntarily adopt good‑governance reforms. Consequently, the Court set aside the High Court’s order to the extent indicated and directed the High Court to dispose of the pending writ appeals expeditiously so that the TDCA’s election can be conducted at the earliest.
Issues considered
- The applicability of the S. Nithya judgments, which pertain to athletics governance, to cricket associations such as the TDCA.
- Whether the BCCI Constitution must be adopted or mirrored by district cricket associations.
- Whether the requirement that 75% of members be eminent sportspersons, as ordered in S. Nithya, applies to cricket bodies.
- The appropriate procedure for conducting a free and fair election within the TDCA under the Tamil Nadu Societies Registration Act.
Legislation cited
Headnote
Issue for Consideration Issue as regards the applicability of the judgments in S.Nithya to the cricket associations; applicability of BCCI Constitution to the Appellant-District Cricket Association. Headnotes† Sports – Cricket – Applicability of the judgments in S.Nithya to the cricket associations – Respondent no.2-ex-office bearer of the appellant-association filed writ petition seeking directions that the appellant should conduct a free and fair election after preparation of a fresh voters list and impugned the
Subjects
CricketCricket associationsDistrict Cricket AssociationApplicability of the judgments in S. Nithya to cricket associationsS. Nithya judgmentsApplicability of BCCI Constitution to District Cricket AssociationReforms in athletics governance and championshipsJudgments in S. Nithya not applicable to cases concerning sport of cricketPresence of eminent sport person in federationBCCI judgmentConstitution of BCCISports organisations/clubs/associationsEminent sportspersonState sport federationNational Sports Development Code, 2011Election of District Cricket AssociationTamil Nadu Cricket Association
Judgment
[2026] 3 S.C.R. 160 : 2026 INSC 154
The Tiruchirappalli District Cricket Association
v.
Anna Nagar Cricket Club & Anr. Etc.
(Civil Appeal No(s). 1613-1614 of 2026)
13 February 2026
[Pamidighantam Sri Narasimha and Alok Aradhe, JJ.]
Issue for Consideration
Issue as regards the applicability of the judgments in S.Nithya to
the cricket associations; applicability of BCCI Constitution to the
Appellant-District Cricket Association.
Headnotes†
Sports – Cricket – Cricket Associations – Applicability of the
judgments in S.Nithya to the cricket associations – Respondent
no.2-ex-office bearer of the appellant-association filed writ
petition seeking directions that the appellant should conduct
a free and fair election after preparation of a fresh voters list
and impugned the decisions taken by appellant associations
in not complying with the norms as laid down by the High
Court in previous judgments in S.Nithya v. Union of India and
Secretary; Tamil Nadu Olympics Association v. S. Nithya (‘S.
Nithya’) directing that every state sport federation will comply
with the direction regarding mandatory presence of eminent
sport person in the federation – Writ petition allowed relying
upon the judgments in S.Nithya observing that directions in
Nithya’s case in respect of all sports organisations/clubs/
associations ought to be strictly adhered to – Challenge to:
Held: Petition in S.Nithya was only concerned with reforms in
athletics governance and championships – Judgments in S. Nithya
are not applicable to the factual conspectus of the present case –
When the judgment in S. Nithya was delivered, the judgment in
BCCI was already holding the field with the Constitution of BCCI
having received the stamp of approval by this Court – There
being no prescription or direction in the BCCI judgments on 75%
membership in an association to be filled by eminent sports persons,
coupled with no such direction providing that the qualification to
be member of district association will be concomitant on a person
being an eminent sportsperson, the directions in S. Nithya would
[2026] 3 S.C.R. 161
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
not be applicable to the fact of the present case concerning sport
of cricket – Judgment of the High Court set aside to the extent
indicated. [Paras 15, 26]
Sports – Cricket – Cricket Associations – Functioning of the
appellant-District Cricket Association in the existing legal
regime – Applicability of BCCI Constitution to the Appellant-
Association – Plea of the respondents that the appellant must
amend its Constitution in conformity with the Constitution of
the BCCI:
Held: The judgment in BCCI does not warrant District Associations
to model their regulations and bye-laws on exact lines of the BCCI
Constitution – No judgment or document was brought on record to
demonstrate any understanding across the cricketing associations
at the District Level to make their Constitution on exact lines as of
the BCCI, nor any judgment which directs such a prescription –
Impugned order, which directs the appellant association, also does
not place reliance on BCCI per se, but rather on the judgment in
S. Nithya which is distinguishable – Thus, the argument that the
appellant must be asked to restructure its functioning and laws in
terms of the BCCI Constitution, not accepted. [Para 20]
Sports – Cricket – Cricket Associations – Reformative
measures – Necessary for State Association to initiate reforms
to ensure that District Associations operate as professional,
transparent, and in the best interests of the sport:
Held: Though enforcement of reform as contemplated in the BCCI
judgment cannot be done through judicial review, it is open, rather
necessary, for the State Association to initiate reforms to ensure
that District Associations operate as professional, transparent,
and in the best interests of the sport – Such reforms may include
transparency in the selection of players and also the execution
of contracts – In fact, District Associations must volunteer to
adopt reformative measures such as good governance, refined
management, transparency, and the exclusion of conflicts of
interest. [Paras 21, 22]
Tamil Nadu Societies Registration Act, 1975 – Election of the
appellant-association – Issues concerning membership and
composition of the appellant pending before High Court and
the statutory authority:
162 [2026] 3 S.C.R.
Supreme Court Reports
Held: Such questions to be resolved as expeditiously as
possible – Judgment and order of the High Court set aside to the
extent indicated – High Court to dispose of the writ appeal(s) as
expeditiously as possible in order to enable the statutory authorities
to complete the enquiry, if necessary, and arrive at its logical
conclusion, so that the election of the appellant can be conducted
at the earliest. [Para 26]
Case Law Cited
BCCI v. Cricket Assn. of Bihar [2014] 6 SCR 322 : CA No.
4235/2014; AIFF v. Rahul Mehra, 2025 INSC 1131 – referred to.
S. Nithya v. Union of India, W.P. (MD) No. 3447 of 2019; Secretary,
Tamil Nadu Olympics Association v. S. Nithya, W.A. No. 1202 of
2022 – distinguished.
List of Acts
Tamil Nadu Societies Registration Act, 1975; Constitution of India.
List of Keywords
Cricket; Cricket associations; District Cricket Association;
Applicability of the judgments in S. Nithya to cricket associations;
S. Nithya judgments; Applicability of BCCI Constitution to District
Cricket Association; Reforms in athletics governance and
championships; Judgments in S. Nithya not applicable to cases
concerning sport of cricket; Presence of eminent sport person
in federation; BCCI judgment; Constitution of BCCI; Sports
organisations/clubs/associations; Eminent sportsperson; State sport
federation; National Sports Development Code, 2011; Election of
District Cricket Association; Tamil Nadu Cricket Association.
Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No(s). 1613-1614
of 2026
From the Judgment and Order dated 12.06.2024 of the High Court
of Judicature at Madras at Madurai in WAMD Nos. 896 and 915
of 2024
Appearances for Parties
V. C. Shukla, Amicus Curiae.
[2026] 3 S.C.R. 163
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
Advs. for the Appellant(s):
Amol Chitale, Mrs. Pragya Baghel, Ms. Shweta Singh Parihar,
Sarthak Sharma.
Advs. for the Respondent(s):
Mayank Mishra, Raghav Sabharwal, Kunwar Surya Pratap, Harsh
Vardhan Singh, Akshaj Chaturvedi.
Judgment / Order of the Supreme Court
Judgment
1. Leave granted.
2. The present appeal(s) are preferred by the appellant Cricket
Association against the final judgment and order of the Madurai
Bench of the Madras High Court dated 12.06.2024 disposing of a
clutch of Writ Appeals, namely Writ Appeal (MD) No. 896 of 2024
and Writ Appeal (MD) No. 915 of 2024.
3. The appellant is a district cricket association formed in 1958, registered
as a society under the Tamil Nadu Societies Registration Act, 1975,
and governed by its rules and bye-laws and is affiliated with the
Tamil Nadu Cricket Association (‘TNCA’), the State association.
The facts in both the appeals before the High Court were distinct in
content but analogous in form in the manner in which they sought
to impugn the alleged lapses in the workings of the appellant, and
are canvassed below in brief.
4. Facts in Writ Appeal (MD) No. 896 of 2024: The facts in this appeal
are that the respondent no. 1 cricket club preferred a writ petition
seeking direction against the appellant to grant the respondent no. 1
membership of the appellant association alongside voting rights and
also allow respondent no. 1 to participate in the knockout tournament
for the year 2021-2022. The appellant entered appearance and
brought on record the fact that the respondent no. 1 has already
been permitted to participate in the tournament, and in this view, the
cause does not survive. Noting the fact of the respondent no. 1’s
participation, the learned single judge disposed of the writ petition.
5. Since the writ petition was disposed of as allowed, on the issue
of voting and membership rights, the appellant herein impugned
the findings of the single judge in the writ appeal, which has been
164 [2026] 3 S.C.R.
Supreme Court Reports
dismissed by the division bench, observing that the Respondent
No. 1 club has the right to vote and membership in the appellant
association. Since then, the respondent club has actively participated
in tournaments organised by the appellant. The learned counsel
appearing for the appellant has submitted, on instruction, that insofar
as respondent no. 1’s voting rights are concerned, the appellant has
no objection towards the same, and the respondent no. 1 may be
allowed to vote. In view of these submissions, the issues in appeal(s)
are confined to the reliefs granted by the High Court qua respondent
no. 2 only, as outlined below.
6. Facts in Writ Appeal (MD) No. 915 of 2024: The facts relevant
to this appeal are that respondent no. 2, an ex-office bearer of the
appellant association, approached the High Court via writ petition,
seeking directions that the appellant should conduct a free and fair
election after preparation of a fresh voters list and sought to impugn
the decisions taken by appellant associations in not complying with
the norms as laid down by the High Court in previous judgments in
S. Nithya v. Union of India1 and Secretary, Tamil Nadu Olympics
Association v. S. Nithya2 (‘S. Nithya’) directing that every state sport
federation will comply with the direction regarding mandatory presence
of eminent sport person in the federation and other directions, so far
as amending the appellant association’s Constitution is concerned,
to bring them in line with the Constitutions of other similarly situated
federations. The said prayer(s) were allowed by the High Court in the
impugned order. Aggrieved, the appellant association has preferred
the instant appeal.
7. We heard Mr. Amol Chitale, learned counsel appearing for the
appellant, Mr. Mayank Mishra, learned counsel appearing for the
respondents, in the present appeal(s) and perused the records. Mr
Vikash Chandra Shukla, learned counsel, ably assisted the Court
as Amicus Curiae.
8. The learned counsel appearing for the appellant district association
has fairly submitted that, insofar as specific prayers of respondent no.
1 and respondent no. 2 are concerned, the appellant association has
no objections to them. In this view, while the respondent no. 1 club
1 W.P. (MD) No. 3447 of 2019.
2 W.A. No. 1202 of 2022.
[2026] 3 S.C.R. 165
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
would be permitted to vote in the appellant association, the prayer
of respondent no. 2 with respect to oversight of the future election
of the appellant association can also be allowed.
9. The appellant is aggrieved by the reliance of the High Court in
judgments in S. Nithya (supra) while allowing the writ proceedings,
which, in the view of the appellant, stand on a different factual-legal
conspectus and are inapplicable to cricket associations like the
appellant herein. It is learnt from the records as well as submissions
made before us that there are certain proceedings pending before the
High Court concerning membership of the appellant association, and
it was urged that the issue regarding membership of the appellant
association may not be dealt in the present appeals, and rather the
appropriate authorities can take up the pending proceedings and
decide them as expeditiously as possible. Since the primary grievance
of the appellant is restricted to the applicability of judgments in
S. Nithya (supra) to the cricket associations, we take up the very
issue first.
10. On applicability of Judgments in S. Nithya: The judgment in S.
Nithya (supra) was an outcome of a Writ Petition preferred before the
High Court of Judicature at Madras by an athlete, who had won several
medals in numerous Discus Throw events. The athlete’s grievance
was that, despite her noteworthy performance, she was denied entry
to participate in the Open National Championships in 2017 and 2018.
The writ petitioner, in turn, asked for the issuance of numerous writs
seeking the institution of multiple reform measures, including, inter
alia, strict implementation of National Sports Development Code,
2011, constitution of a Special Committee with eminent sports persons
for regularising athletics Championships, competitions, meets and
events in Tamil Nadu, direction to authorities to make appropriate
safety arrangements and provide proper places of accommodation
to women athletes for all State Level and National Level Athletics
Championships, Competitions, Meets and Event, and various other
transparency measures.
11. As apparent from the various prayers sought in the writ petition,
the petition in S. Nithya (supra) was only concerned with reforms
in athletics governance and championships. The learned Single
Judge allowed the writ petition on 19.01.2022 by passing a range of
directions in terms of the prayers of the writ petition, placing reliance
166 [2026] 3 S.C.R.
Supreme Court Reports
on judgments of this court in BCCI and the mandate and objectives of
the National Sports Code, 2011. A writ appeal was preferred through
the Secretary, Tamil Nadu Olympics Association, in W.A. No. 1202
of 2022, which was dismissed by the division bench on 26.04.2022.
12. The judgments in S. Nithya (supra) have been relied upon in the
order impugned before us, observing that directions in Nithya’s case
in respect of all sports organisations/clubs/associations ought to be
strictly adhered to, thereby confirming the judgment and order of the
learned single judge. Before adverting to the contentions raised by
the appellant, it would be beneficial to extract the relevant directions
in S. Nithya (supra), which are as under:
i. “The State government should consider for creating a
legal framework that imposes statutory regulation on the
functioning of every sports organisation/clubs/association,
including the state unit of the National Sports Federation in
respect of every field of sports. The said legal framework
should include as far as possible all the following aspects
and directions and which shall continue to be in force until
the passing of such a statute by the state legislature.
ii. Every Sports Association/organisation shall be compulsorily
registered with the State Government and it shall be
mandatory for the said organisation to provide its complete
details including its constitution and details of its members,
the sports persons registered with the said association, its
financial status as well as the contributions/funds received
by the said association, the number and details of events
conducted by the Association and the credentials of the
sports persons participating in every such event.
iii. Every Sports Association should have a record of all the
above stated details and it shall be within the power of the
State Government to inspect such records at any given
point of time.
iv. The State Government as well as the state unit of the
National Sports Federation of every sport which is
recognised by the Central Government shall have a
grievance cell, in order that deserving sports persons may
contact them directly in cases where the recognised sports
[2026] 3 S.C.R. 167
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
Association/affiliate does not forward a deserving athlete/
sports person’s name for participation at the national level
to the concerned National Sports Federation.
v. The positions of President, Vice President and
Secretary of every sports Association/organisation as
well as important functionaries of such organisations
including that of the state unit of the National sports
Federation shall be held only by sports persons and
it must be ensured that a minimum of 75% of the
members of any sports body/organisation/association/
NSF shall be composed of eminent sports persons
and they shall have voting rights.
vi. The selection of athletes shall be within the purview of
the decision-making powers of the selection committee
consisting only of sports persons in the respective
association as well as the sports Federation.
vii. No person shall be entitled to hold the position of President,
Vice President, Secretary or any other important functionary
in any association as well as Federation on the only
ground that he or she has contributed financially to the
said organisation. The holding of such a position shall
be strictly governed by the Constitution of the respective
organisation which shall clearly set out the procedure for
election to the office of President, Vice-President and
Secretary and other important functionaries, in accordance
with the previous direction in clause vi. above that such
positions can only be held by sports persons.
viii. Any reference to the term “sports persons‟ for the
purpose of holding the positions of any of the important
functionaries in any organisation/association or
Federation, would mean a person who has participated
in sports at least at the State level, with participation at
the national level and winning of awards and accolades
at the national level being a desirable qualification.
ix. An online registration system for all district level, state level
and national level athletic championships, competitions,
meets and events, similar to the model followed in
the Federation Cup Athletics Championships, shall be
168 [2026] 3 S.C.R.
Supreme Court Reports
effectuated immediately, which shall publish online the
amount allotted and spent on each athlete for such events.
x. It shall be mandatory for every association to have a
website where all its financial aid as sanctioned and granted
by the sports development authority of the respective State
as well as by the Union Government must be furnished
and the details of all the applicants with their respective
credentials must also be mentioned in a transparent
manner in the website.
xi. In cases where it is found after an enquiry that any
association/organisation or state unit of the National
sports Federation has acted against merit in respect of
the selection of participants, the State Government can
take penal action against such an organisation including
blacklisting of such an organisation for a minimum period
of two years during which the association/organisation will
not be in a position to sponsor candidates for national
events or receive grant from the State Government.
xii. In the event of any grievance made by any athlete/sports
person to the state unit of the National sports Federation,
the same shall be disposed of within a period of one
week from the date on which such a grievance has been
raised or before the upcoming event in respect of which
the grievance is made, whichever is earlier, in order that
the concerned athlete/sports person does not lose their
chance for the concerned year.
xiii. In the event of any grievance made with respect to any
state unit of the National sports Federation, the state
government shall dispose of the same within a period of
one week from the date on which such a grievance has
been raised or before the upcoming event in respect of
which the grievance is made, whichever is earlier.
xiv. The suggestions placed by the sixth respondent, which
are extracted in para 9(vi) of this order shall be considered
by the respondents 1, 4 and 5. Such compliance report
be filed within a period of three months.”
(emphasis supplied)
[2026] 3 S.C.R. 169
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
13. Mr. Chitale, learned counsel for the appellant has forcefully submitted
that the directions in judgment in S. Nithya (supra) as made applicable
on appellant by virtue of the single judge’s order and confirmed by the
impugned order by the division bench are inapplicable and unviable
as they cannot be applied to the sport of Cricket, with respect to which
the decision of this Court in BCCI v. Cricket Assn. of Bihar3 would
apply. It was argued that the judgment in BCCI (supra), which holds
the field of regulation in the context of cricket, does not prescribe
that the post of President, Vice President and Secretary, as well as
important functionaries of the BCCI and affiliated State Associations,
shall be held only by sports persons and that 75% of members shall
be eminent sportspersons. In this view, the directions in S. Nithya
(supra) do not apply. It was further argued that the direction no.
(viii) in S. Nithya (supra), regarding the eligibility criteria for ‘sports
persons’ is onerous and disproportionate to the object sought to be
achieved, given that posts at the district association should not be
expected to be filled by persons who have participated in sports
at the State level. Such a mandate would be counterproductive to
localisation and democratisation of sports, it was argued.
14. The learned amicus has supported the arguments of the appellant
and submitted that the law laid down in BCCI (supra) is a special law
governing the field of Cricket, and the judgment in S. Nithya (supra)
arising in peculiar facts and circumstances of athletics governance
may not be applied in the instant case.
15. We agree with the submissions advanced at the Bar regarding the
inapplicability of the judgments in S. Nithya (supra) to the factual
conspectus of the present case. When the judgment in S. Nithya
(supra) was delivered, the judgment in BCCI (supra) was already
holding the field with the Constitution of BCCI having received the
stamp of approval by this Court. There being no prescription or
direction in the BCCI judgments on 75% membership in an association
to be filled by eminent sports persons, coupled with no such direction
providing that the qualification to be member of district association
will be concomitant on a person being an eminent sportsperson, the
directions in S. Nithya (supra) would not be applicable to the fact of
the present case concerning sport of cricket.
3 CA No. 4235/2014.
170 [2026] 3 S.C.R.
Supreme Court Reports
16. Having clarified the legal position, our next inquiry concerns the
functioning of the appellant association in the existing legal regime
informed by the applicable regulatory framework. Mr Mayank Mishra,
learned counsel appearing for the respondents, has submitted that,
in any event, the appellant must amend its Constitution in conformity
with the Constitution of the BCCI, the structure of the sport being
pyramidical. We now take up this issue.
17. On applicability of BCCI Constitution to the Appellant, District
Cricket Association: Learned Amicus has highlighted the final
directions in BCCI (supra) to the effect that after registration of the
Constitution of BCCI, each of the members (State Associations)
was directed to bring their Constitutions in conformity with BCCI’s
Constitution by way of suitable amendments. The amicus submits
that while there was no direction in BCCI (supra) regarding the
amendment of Constitutions to be done by District Associations, there
was a consensus among the State Associations that their district
association would also amend their Constitution in conformity with the
BCCI’s Constitution. Stating so, it was submitted that the appellant
should grant membership only to its full members, as done by TNCA
and BCCI, and also make minor corrections, such as mentioning
the names of its members in its Constitution/bye-laws, which remain
unclear and are part of pending proceedings as well.
18. The appellant opposes the submission advanced by amicus and
respondents, arguing that the judgment in BCCI (supra) only concerns
the BCCI and its member associations and is not in any manner
applicable to the District Association. To this end, the appellant
places strong reliance on the judgment in BCCI itself, wherein the
Court concluded that the proposed Constitution of the BCCI did not
stifle upon the rights and internal composition of State associations
and, in turn, District Association4 and hence the argument advanced
by associations regarding violation of Article 19 of the Constitution
was rejected. The relevant extract of the said judgment is as under:
“55. With the above two aspects in mind, let us now
examine whether the recommendations of the Committee
have the tendency to violate Article 19(1)(c) or any other
provision of the Constitution.
(…)
4 (2016) 8 SCC 535, Para 57.
[2026] 3 S.C.R. 171
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
58. We regret our inability to accept the submission so
vehemently urged before us by the learned counsel for
BCCI and the State Cricket Associations. We say so,
firstly because no citizen has come forward in the present
proceedings or in the earlier round to complain of the
violation of any fundamental right guaranteed under Article
19(1)(c) of the Constitution. Secondly and more importantly
because the recommendations do not, in our opinion,
affect the composition of the State Cricket Associations
in any manner. Citizens who have come together to form
the State Associations continue to associate as before
with no change in their internal composition. If that be so
as it indeed is the right guaranteed under Article 19(1)
(c) stands exercised, which exercise would continue to
enjoy the protection of the constitutional guarantee till
the association/union or cooperative society, as the case
may be, continues to exist. What is, however, important
is that the right under Article 19(1)(c)does not extend to
guaranteeing to the citizens the concomitant right to pursue
their goals and objects uninhibited by any regulatory or
other control. The legal position in this regard is settled by
several decisions of this Court to which we may gainfully
refer at this stage.
(…)
64. There is, in the light of the above authoritative
pronouncements, no room for any doubt that the right
guaranteed under Article 19(1)(c) cannot be claimed by an
association or union or a cooperative society as is sought
to be done in the case at hand, even when the right to form
an association or union or cooperative society extends to
the continued existence of such association or union or
cooperative society with its original voluntary composition.
But the right does not extend so far as to include the right
of any such association or union or cooperative society to
achieve its objects or to conduct its business unhindered
by any regulatory or other control. Anything beyond the
protection of the original composition of the association or
union or cooperative society would fall outside Article 19(1)
(c) and shall be governed by other clauses of Article 19 of
the Constitution. For instance, the right of the association
172 [2026] 3 S.C.R.
Supreme Court Reports
or union or cooperative society to conduct its business or
pursue its objects shall be regulated under Article 19(1)
(g) read with clause (6) of the Constitution. So also, the
right to move freely throughout the territory of India shall
be governed by Article 19(1)(d) read with clause (5) of
the Constitution. Suffice it to say that so long as the initial
voluntary composition of the State Cricket Associations
which are complaining of the breach of their right under
Article 19(1)(c) remains unaffected, there is no violation
of what is guaranteed by Article 19(1)(c).
65. Seen in the backdrop of the above, the recommendations
made by the Committee in the instant do not interfere with
or alter the composition of the State Associations. Individual
citizens who came together to form the State Associations
have not been asked to discontinue their association nor
do the recommendations impose upon their members an
obligation to associate with others with whom they do
not wish to associate. Composition of the State Cricket
Associations remain unaffected, and so does the right of
those forming such associations under Article 19(1)(c). That
being so, the grievance sought to be made on behalf of
citizens who have formed the State Associations does not
stand scrutiny no matter none of those on whose behalf
the argument is advanced is before this Court to make
any such grievance. We have, in the light of the above, no
difficulty in rejecting the first limb of the submissions made
by the learned counsel opposing the recommendation of
the Committee that BCCI shall have the Cricket Association
from each State as a full member”.
19. In the recent judgment of this Court in AIFF v. Rahul Mehra,5 while
answering a similar argument, that the Constitution of All India
Football Federation shall not be made applicable to the State and
District Association, this Court has distinguished the judgment in
BCCI with the pyramidical structure of football and the International
legislative framework to the effect that the judgment in BCCI arose
out of a peculiar nature of Cricket as distinguished from Football and
therefore is not applicable on the football regime.6
5 2025 INSC 1131.
6 AIFF (supra), paras 64-71.
[2026] 3 S.C.R. 173
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
20. In simple words, the appellant wants the argument on the applicability
of BCCI’s Constitution on its functioning to be rejected in terms of the
ratio in BCCI itself. We have no difficulty in accepting this argument.
The relevant portions in BCCI extracted above are clear to the effect
that the judgment in BCCI does not warrant District Associations to
model their regulations and bye-laws on exact lines of the BCCI
Constitution. No judgment or document has been brought on record
to demonstrate any understanding across the cricketing associations
at the District Level to make their Constitution on exact lines as of
the BCCI, nor any judgment which directs such a prescription. The
impugned order, which directs the appellant association, also does
not place reliance on BCCI per se, but rather on the judgment in S.
Nithya (supra), which we have already distinguished and clarified in
the preceding section. In this view, the argument that the appellant
must be asked to restructure its functioning and laws in terms of the
BCCI Constitution cannot be accepted.
21. However, though enforcement of such a reform as contemplated in
the BCCI judgment cannot be done through judicial review, we must
clarify that it is open, rather necessary, for the State Association
to initiate reforms to ensure that District Associations operate as
professional, transparent, and in the best interests of the sport.
22. Such reforms may include transparency in the selection of players
and also the execution of contracts. In fact, District Associations must
volunteer to adopt reformative measures such as good governance,
refined management, transparency, and the exclusion of conflicts
of interest. Recognising the importance of sport to national life,
this Court has an occasion to observe that, 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. 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
174 [2026] 3 S.C.R.
Supreme Court Reports
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.
23. It is high time we recognize that sporting “facilities and opportunities”7
are “material resources of the community”8, and their organizers are
“the institutions of the national life”9. As “places of public resort”10,
sporting institutions and bodies must 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. 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.11
24. Returning to the facts of the present case, Mr. Amol Chitale has
submitted that the appellant association’s rules and bye-laws include
provisions for disqualification and dispute resolution, and in fact
promote fairness and accountability. He would further submit that the
association is inclined to carry out amendments to the following affect:
a) Any new inductee in the category of life member will not have the
right to vote for a period of 3 years from the date of induction.
b) The number of “life members” shall be frozen at 179, which is the
current strength of “Life Members” in the appellant association.
The number of “Life Members” shall not be increased beyond 179.
c) In order to give adequate representation to the Clubs/
Institutions, there would be no capping on the number of Clubs/
Institutions that can be conferred voting rights in accordance
with the provisions of the rules and regulations of the appellant
association.
7 Article 38(2), Indian Constitution.
8 Article 39(b), Indian Constitution.
9 Article 38, Indian Constitution.
10 Article 15(2), Indian Constitution.
11 2025 INSC 1131 : All India Football Federation v. Rahul Mehra.
[2026] 3 S.C.R. 175
The Tiruchirappalli District Cricket Association v.
Anna Nagar Cricket Club & Anr. Etc.
d) The category of “Family Members of the existing Life Members”
shall be deleted from the clause which prescribes the categories/
qualifications for grant of “Life Membership” in the rules and
regulations of the appellant association.
25. We have noted the submission of Mr. Amol Chitale, but have chosen
not to comment in view of the fact that certain proceedings are
pending before the High Court and the concerned authorities under
the Tamil Nadu Societies Registration Act. Through an affidavit dated
13.12.2025 filed by the Respondent, we are informed that certain
members of the appellant association initiated proceedings under
Section 36 of the Tamil Nadu Societies Registration Act against
the appellant, and while the enquiry was pending, they filed writ
petition(s), primarily seeking direction to forbear the appellant from
approving certain persons as life members of the Association. We
are also informed that the Registrar had initiated a suo-motu inquiry,
challenge to which is pending before the division bench of the High
Court, where there is an interim order. It is not necessary to refer
to the pending proceedings any further.
26. Since the issues concerning membership and composition of the
appellant association are pending before the High Court and the
statutory authority, we are of the opinion that such questions should
be resolved as expeditiously as possible. In this view, we allow the
appeal in part, set aside the judgment and order of the High Court
to the extent indicated hereinabove, and further direct that the High
Court shall dispose of the writ appeal(s) as expeditiously as possible
in order to enable the statutory authorities to complete the enquiry,
if necessary, and arrive at its logical conclusion, so that the election
of the appellant can be conduct at the earliest. The High Court, as
well as the authorities, shall take into account the spirit of our order.
27. The appeal(s) are disposed of accordingly. Pending applications, if
any, also stand disposed of.
Result of the case: Appeal partly allowed.
†
Headnotes prepared by: Divya Pandey
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