Indian Olympic Association vs. Ski and Snowboard India - Appeal of Single Judge Order

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President, Indian Olympic Association ... vs Ski And Snowboard India & Anr on 23 March, 2026

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* IN THE HIGH COURT OF DELHI AT NEW DELHI

                                                     Judgment reserved on: 09.03.2026.

                      %                              Judgment delivered on: 23.03.2026

                      +      LPA 104/2026, CM APPL. 14068/2026, CM APPL. 14069/2026 &
                             CM APPL. 14070/2026

                             PRESIDENT, INDIAN OLYMPIC ASSOCIATION & ANR.
                                                                           ..... Appellant

                                            Through:      Mr. Gopal Jain, Senior Advocate
                                                          along with Ms. Aashita Khanna, Ms.
                                                          Aanya Agarwal and Mr. Vidushpat
                                                          Singhania, Advocates.

                                            versus

                             SKI AND SNOWBOARD INDIA & ANR.                ..... Respondent

                                            Through:      Ms. Neha Singh, Advocate for
                                                          Respondent No.1.
                                                          Mr. Udit Dedhiya, SPC with Ms.
                                                          Apurva Sachdev, Mr. Preyansh
                                                          Gupta, Advocates & Mr. Amit Rana,
                                                          GP.

                             CORAM:
                             HON'BLE THE CHIEF JUSTICE
                             HON'BLE MR. JUSTICE TEJAS KARIA

                      LPA 104/2026                                                    Page 1 of 12

Signature Not Verified
Digiltally Signed
By:SREERAM L
Signing Date:23.03.2026
14:58:52
JUDGMENT DEVENDRA KUMAR UPADHYAYA, C.J.

1. Heard Shri Gopal Jain, learned senior counsel representing the
                     appellants, Ms. Neha Singh, learned counsel appearing for respondent No.1
                     and Shri Udit Dehiya, learned special panel counsel representing the
                     respondent No.2 and have perused the records available before us on this
                     Letters Patent Appeal.
   

2. This Intra-Court appeal seeks to challenge the judgment and order
                     dated 10.02.2023, passed by the learned Single Judge whereby the W.P.(C)
                     No. 3418 of 2025 instituted by the respondent No.1 has been allowed, and
                     the Office Order under challenge therein dated 13.10.2023 has been
                     quashed.
   

At this juncture itself, we may state that the Office Order dated
13.10.2023, that was under challenge in the proceedings of the writ petition
before the learned Single Judge, was passed by the appellant No.1 -
President, Indian Olympic Association whereby an ad hoc Committee
comprising of four members was appointed to manage the affairs of the
respondent No.1 - Ski and Snowboard India, including selection of the
athletes and making entries for participation of sportspersons in international
events. The said ad hoc Committee was also mandated to conduct the
elections of the executive committee of the respondent No.1.

1. The learned Single Judge, while allowing the writ petition by the
                     impugned judgment and order has held that the respondent No. 1 is an
   
                      independent body registered as a society under the [Karnataka Societies
                     Registration Act, 1960](https://indiankanoon.org/doc/154328389/), and that the appellant did not have any jurisdiction
                     or authority or power to replace the executive committee of the respondent
                     No.1 by appointing an ad hoc committee to manage its affairs.
   

2. By the impugned order, the learned Single Judge has also observed
                     that as a result of quashing of the Office Order dated 13.10.2023, the ad hoc
                     Committee stood dissolved with immediate effect. The learned Single Judge
                     has also appointed a retired Judge of this Court as the Returning Officer to
                     draw up the list of eligible members and thereafter conduct the election of
                     the respondent No.1, with a further direction that the exercise relating to
                     conducting the election shall be concluded expeditiously and in not later
                     than a period of 12 weeks.
   

3. The impugned judgment and order passed by the learned Single Judge
                     has been challenged by the appellants primarily on two counts - (a) [Article
                     17.5](https://indiankanoon.org/doc/1987997/) of the Rules and Regulations of the appellant permits appointment of an
                     ad hoc Committee of the respondent No.1 and (b) the direction issued by the
                     learned Single Judge for conducting the election of the respondent No.1 by
                     the impugned order is contrary to the provisions contained in the National
                     Sports Governance Act, 2025 (hereinafter referred to as 'Act, 2025') and the
                     Rules made thereunder, namely National Sports Governance (National
                     Sports Bodies) Rules, 2026 (hereinafter referred to as 'Rules, 2026').
   

4. It has been argued by learned senior counsel for the appellant that [Article 17.5](https://indiankanoon.org/doc/1987997/) of the Rules and Regulations of the appellant - Indian Olympic
                     Association vests ample power with the appellant to appoint an ad hoc
                     Committee for managing the affairs of any sports federation and further that
   
                      the ad hoc Committee was appointed by the Office Order dated 13.10.2023
                     having regard to certain differences within the respondent No.1 and on the
                     basis of various complaints received against it. [Article 17.5](https://indiankanoon.org/doc/1987997/) of the Rules and
                     Regulations of the appellant is extracted herein below:
   

"17.5 Other Commissions/Committees

All required Commissions/Committees will be formed by the
President to be ratified by the Executive Council or by the Annual /
Special General Meeting."
7. So far as the submission of learned senior counsel for the appellant
that Article 17.5 of the Rules and Regulations of the appellant, vests power
and authority with the appellant to appoint ad hoc Committee, we may
observe that such argument is highly misconceived and is based on a
complete misreading of the provisions contained in Article 17.5.

1. The Indian Olympic Association is a society registered under the [Societies Registration Act](https://indiankanoon.org/doc/1700055/) whose affairs are governed by the provisions
                     contained in the memorandum of association and the rules and regulations
                     framed by the Indian Olympic Association. We may also note that the rules
                     and regulations of the Indian Olympic Association have been framed by the
                     Association for the purposes of governing its own affairs, and it is only in
                     this context that the provisions contained in [Article 17.5](https://indiankanoon.org/doc/1987997/) have to be
                     interpreted and understood. [Article 17.5](https://indiankanoon.org/doc/1987997/), as quoted above, states that all
                     required Commissions/Committees will be formed by the President to be
                     ratified by the Executive Council or by the Annual /Special General
                     Meeting. In our opinion, the Commissions and Committees referred to in [Article 17.5](https://indiankanoon.org/doc/1987997/) refer to the Commissions and Committees of the Indian
   
                      Olympic Association and by no stretch of imagination, the phrases
                     'Commissions' and 'Committees' occurring in the said Article can be
                     interpreted to bring in its fold the Committees in relation to any other society
                     or body. The Commissions and Committees referred to in [Article 17.5](https://indiankanoon.org/doc/1987997/) are
                     necessarily to be the Commissions and Committees formed by the President
                     of the Indian Olympic Association to transact certain businesses assigned to
                     such Commissions/ Committees of the Indian Olympic Association alone
                     and not those of any other body or society like the respondent No.1. Such
                     an argument thus, is absolutely untenable, which merits rejection.
   

2. The second argument made by learned senior counsel for the
                     appellant to impeach the impugned judgment and order passed by the
                     learned Single Judge is also absolutely misconceived for the simple reason
                     that the respondent No.1 is not a National Sports Federation recognised by
                     the Ministry of Youth Affairs and Sports, Government of India, as has been
                     admitted by learned counsel representing the Ministry. It is not even a
                     National Sport Body in terms of Section 3 of the Act, 2025 and, accordingly,
                     the provisions of the Act, 2025 are neither applicable to the respondent
                     No.1; nor the affairs of the respondent No.1 can be said to be governed by
                     the Act, 2025 unless it gets itself established as a National Sports Body in
                     terms of the requirement of the provisions of the Act, 2025. It is also to be
                     noticed that prior to enactment of the Act, 2025, the affairs relating to
                     National Sports Federations were governed by the National Sports
                     Development Code of India, 2011 (hereinafter referred to as 'the Code,
                     2011') where any body or society to be termed as a National Sports
                     Federation was required to be recognised by the Ministry. As already stated
   
                      above, learned counsel for the respondent No. 2 has categorically stated at
                     the bar that the respondent No.1 is not recognised as a National Sports
                     Federation even under the old regime of the Code, 2011.
   

3. The fact that the respondent No.1 was not a recognised National
   Sports Federation under the provisions of the Code, 2011, has been recorded
   by the learned Single Judge in the impugned judgment and order, and the
   said fact is not disputed by the learned counsel representing the Ministry.

4. Learned senior counsel for the appellant has referred to certain
   provisions of the Act, 2025 and the Rules framed thereunder and has stated
   that, the direction issued by the learned Single Judge by passing the
   impugned judgment and order for holding the election, creates a situation of
   impossibility for the reason that unless and until in fulfilment of requirement
   of Rule 18 of Rules 2026, the respondent No. 1 amends its by-laws in
   conformity with the provisions of the Act, 2025, no such elections of the
   respondent No.1 could be ordered to be held. It has further been argued by
   learned senior counsel for the appellant that Section 4(4) of the 2025 Act
   provides that the mode of election to different bodies, committees and
   offices etc., shall be such as may be prescribed. He has also drawn our
   attention to Section 16 of the Act, 2025 which provides that on the
   recognition of the National Sports Board (to be established under Section 5
   of the Act, 2025), the Central Government shall notify a National Sports
   Election Panel which will conduct the elections and since till date Section 16
   of the Act, 2025 has not been notified to come into force as such, in absence
   of National Sports Election Panel to be established under Section 16 of the
   Act, 2025, no elections can be held. In this view, the submission is that the

                      direction issued by the learned Single Judge for holding the elections of the
                     respondent No.1 is not only untenable, but if the same is allowed to be held,
                     it will be in infringement of the aforesaid provisions of the Act, 2025.
   

5. The aforesaid submission has been considered by us only to be
   rejected out rightly for the following reasons:

(a) Admittedly, the respondent No.1 is not a recognised National Sports
Federation or a National Sports Body either under the provisions of the
Code, 2011 or the Act, 2025 and, therefore, the question of applicability of
the Act, 2025, over the affairs of the respondent No.1 does not arise at all.

(b) The respondent No.1 is an independent body duly registered as a
society under the Karnataka Societies Registration Act, 1960, affairs of
which, including the election of the executive body, are, thus, to be
governed by the provisions of the memorandum of association and by-laws
and rules and regulations of the respondent No.1.

(c) The requirement of amendment of by-laws of every National Sports
Body in conformity with the provisions of the Act, 2025 as per the
provisions contained in Rule 18 of Rules, 2025, is only in relation to a
National Sports Body and since the respondent No.1 till date is not a
National Sports Body as per the Act, 2025 or even a National Sports
Federation in terms of the provisions of the Code, 2011, the reliance placed
by learned senior counsel for the appellant on Rule 18 of the said rules is
highly misplaced. Rule 18 of the Rules made under the Act, 2025 is
extracted herein below:

"18. Miscellaneous
(1) Every National Sports Body shall, within a period of six months,
amend its bye-laws in conformity with the provisions of the Act.

(2) The Central Government may, on receipt of the application from a
National Sports Body, relax the provisions of these rules for a period of
twelve months from the commencement of these rules and reasons for
such relaxation to be recorded in writing."
(d) It is also to be noticed that the Act, 2025 has been enacted by the
Parliament with a view to giving effect to the emphasis of the Olympic
Charter and the Paralympic Charter, which emphasise impeccable ethical
behaviour in sports governance and necessitates the national sports
governing bodies to align with such global governance standards. The Act,
2025, also aims to ensure that the sports bodies in the country manage their
internal and external affairs in an open, fair and transparent manner in public
interest. The Act also aims to provide for accessible, fair and effective
measures for the resolution of grievances and disputes relating to sports.

(e) Prior to the enactment of the Act, 2025, the affairs of National Sports
Bodies were governed and regulated by the Code, 2011, which contains
certain non-statutory Rules. By enacting the Act of 2025 now, a statutory
regime or framework for sports grievances in the country has been
introduced. With a view to aligning the affairs of the National Sports Bodies
with the provisions of the Act, 2025, certain provisions have been made in
the said Act. Section 2(p) defines 'National Sports Body' to mean a national
sports governing body such as the National Olympic Committee or the
National Paralympic Committee or the National Sports Federation or the
Regional Sports Federation, established under section 3. Section 2(p) of the
Act, 2025 is quoted herein below:

"2. Definitions.-- (1) In this Act, unless the context otherwise
requires,--

(p) "National Sports Body" means a national sports governing
body such as the National Olympic Committee or the National

Paralympic Committee or the National Sports Federation or the
Regional Sports Federation, established under section 3;"
(f) Section 3 of the Act, 2025, provides that the National Olympic
Committee, the National Paralympic Committee, a National Sports
Federation for each designated sport and a Regional Sports Federation for
each designated sport shall be established as National Sports Governing
Bodies.

(g) Section 4 of the Act, 2025 requires that every National Sports Body
shall have certain provisions in their constitution governing their affairs,
including the constitution of a general body, the executive committee and
other related affairs.

(h) For the purposes of transition from the old non-statutory regime
governed by the Code, 2011, to the statutory regime regulated by the Act,
2025, Rule 18 of the Rules, 2025, framed under the said Act provides that
every National Sports Body shall amend its by-laws in conformity with the
provisions of the Act within a period of six months. The Ministry of Youth
Affairs and Sports, Government of India has issued a circular dated
22.12.2025 emphasising therein that in accordance with the provisions of the
Act, 2025, every National Sports Federation will be required to undertake
appropriate measures to restructure its General Body to ensure that all their
voting members and affiliate units are fully align with the provisions of the
Act, 2025. The said circular also provides that in order to facilitate smooth
transition under the new governance framework as also to allow adequate
time for implementation of the statutory requirements under the Act, 2025, it
has been decided that those National Sports Federations whose elections are
scheduled to be held in the coming months, except the cases where there are

                       specific directions by the Courts of law, will stand deferred till up to
                      31.12.2026 as a transitional measure.

(i) Much emphasis though was laid by learned counsel for the appellant
on the aforesaid circular dated 22.12.2025 and Rule 18 of the Rules, 2025 as
aforementioned, however, in view of the categorical statement made by the
learned counsel for the Ministry that the respondent No.1 is not a recognised
National Sports Federation, in our opinion, the affairs of the respondent
No.1 are to be governed by the provisions of its memorandum of association
and by-laws and the rules and regulations registered with the Registrar of
Societies of the State of Karnataka in terms of the provisions of the Karnataka Societies Registration Act, 1960, till the respondent No.1 itself
decides to seek registration or recognition under the new statutory regime
introduced by enacting the Act, 2025.

(j) Even if respondent No.1 is treated to be an affiliate of the appellant -
Indian Olympic Association, learned senior counsel for the appellant has not
been able to show any provision of law which permits the Indian Olympic
Association to appoint an ad hoc Committee to manage the affairs of its
affiliate body. The reliance placed by learned senior counsel for the
appellant on Article 17.5 of the rules and regulations of the Indian Olympic
Association has already been negated in the preceding paragraphs.

1. For the reasons aforesaid, in our opinion, the very premise of the
   argument of learned senior counsel for the appellant is based on an absolute
   misreading of the provisions of the Act, 2025 and the Rules made thereunder
   in view of the statement of learned counsel representing the Ministry of
   Youth Affairs and Sports that the respondent No.1 is not a recognised

                      National Sports Federation either in terms of the Code, 2011 or a National
                     Sports Body in terms of the Act, 2025.
   

2. We have already noticed that the respondent No.1 is a society
   registered under the Karnataka Societies Registration Act, and therefore, it is
   an independent body whose affairs are to be governed only by the
   memorandum of association, its by-laws and the rules and regulations.

3. The need to fulfil the statutory requirements under the Act, 2025, and
   the rules made thereunder by the respondent No.1 would arise only once the
   respondent No.1 intends to be recognised or registered as a National Sports
   Body in terms of Section 3 of the Act, 2025, which stage has not yet arisen.

4. The learned Single Judge, placing reliance on a judgment of this
   Court in Bihar Olympic Association vs. President Indian Olympic
   Association and Anr., (2025) SCC OnLine Del 1224, has held that the
   Indian Olympic Association is not vested with any authority or power to
   appoint any ad hoc Committee in relation to the functions of an independent
   body or association.

5. We are in complete agreement with the reasoning given and
   conclusion drawn by the learned Single Judge in the impugned judgment
   and order.

6. Our attention has lastly been drawn by learned senior counsel for the
   appellant that the learned single Judge impugned judgment and order has
   directed the appellant to pay the fee of the returning officer for conducting
   the election of respondent No.1. In this respect, we are of the opinion that
   since the respondent No.1 is an independent body whose affairs are to be
   governed by the provisions of its own memorandum of association, by-laws

                      and rules and regulations, saddling the responsibility of bearing the expenses
                     of conducting the elections on the appellant cannot be justified.
   

7. Accordingly, while upholding the judgment and order under appeal
   herein passed by the learned Single Judge to the extent it has quashed the
   Office Order dated 13.10.2023 and has observed that the ad hoc Committee
   stood dissolved with immediate effect and further directed for conducting
   the elections of the respondent No.1, we set aside the direction issued to the
   appellant for payment of the fee to the returning officer. The fee to the
   Returning Officer shall be paid by the respondent No.1.

8.    The impugned judgment and order dated 10.02.2026, thus, stands
                     modified to the aforesaid extent, and the appeal stands disposed of
                     accordingly.
   

9. There shall be no order as to costs.

(DEVENDRA KUMAR UPADHYAYA)
CHIEF JUSTICE

                                                                       (TEJAS KARIA)
                                                                           JUDGE
                      MARCH 23, 2026
                      N.Khanna