LPA 697/2025 with connected matters Page 1 of 26

* IN THE HIGH COURT OF DELHI AT NEW DELHI

Judgment Reserved on: 05.08.2026

% Judgment Delivered on: 02.09.2026

# CNR No. DLHC010893532025

+ LPA 697/2025, CM APPL. 71335/2025, CM APPL. 71336/2025,

CM APPL. 79570/2025, CM APPL. 12729/2026, CM APPL.

43412/2026 & CM APPL. 50005/2026

ALL INDIA CARROM FEDERATION .....Appellant

Through:

versus

UNION OF INDIA & ANR. .....Respondents

Through: Mr. Udit Dedhiya, SPC along with Mr.

Rajat Mohan Dwivedi, G.P., Mr.

Vishal Sharma, Ms. Apurva Sachdev,

Mr. Preyansh Gupta, Mr. Shivam

Dubey & Mr. Yash Singh, Advocates

for R-1/UoI. Mr. Aseem Mehrotra &

Ms. Deeksha Mehrotra, Advocates for

R-2, 3 & 4.

# CNR No. DLHC010976002025

+ LPA 739/2025, CM APPL. 76777/2025, CM APPL. 76778/2025,

CM APPL. 76779/2025 & CM APPL. 42824/2026

MAHARASHTRA CARROM ASSOCIATION .....Appellant

Through: Mr. Aseem Mehrotra & Ms. Deeksha

Mehrotra, Advocates.

versus

UNION OF INDIA & ORS. .....Respondents

Through: Mr. Udit Dedhiya, SPC along with Mr.

Rajat Mohan Dwivedi, G.P., Mr. Bipul

Kumar, G.P., Mr. Vishal Sharma, Ms.

Apurva Sachdev, Mr. Preyansh Gupta,

Mr. Shivam Dubey & Mr. Yash Singh,

Advocates for R-1/UoI.

LPA 697/2025 with connected matters Page 2 of 26

# CNR No. DLHC010980792025

+ LPA 744/2025, CM APPL. 77079/2025, CM APPL. 77080/2025 &

CM APPL. 77081/2025

UNION TERRITORY PONDICHERRY CARROM

ASSOCIATION .....Appellant

Through: Mr. Aseem Mehrotra & Ms. Deeksha

Mehrotra, Advocates.

versus

UNION OF INDIA & ANR. .....Respondents

Through: Mr. Ankit Raj, SPC with Mr. Bipul

Kumar, G.P. & Mr. Digvijay Singh,

Advocate for Union of India.

CORAM:

HON’BLE THE CHIEF JUSTICE

HON’BLE MR. JUSTICE TEJAS KARIA

JUDGMENT

TEJAS KARIA, J

1.The presentintra-courtAppeals assail the common order dated

29.10.2025 (“Impugned Order”) passed in the writ petitions filed before

learned Single Judge of this Court by Maharashtra Carrom Association

(“MCA”) bearing W.P. (C) No. 12805/2023 and W.P. (C) No. 8665/2025, by

Union Territory Pondicherry Carrom Association (“PCA”) bearing W.P. (C)

No. 17077/2024 and by one Ravi Kumar bearing W.P. (C) No. 3099/2025

(“Writ Petitions”).

2.The Writ Petitions raised common issues pertaining to the election held

on 27.08.2023 (“2023-Election”) of the All India Carrom Federation

(“AICF”), a society registered under the Societies Registration Act, 1860,

which claims to be the National Sporting Federation (“NSF”) for the sport of

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Carrom and has been a member of the International Carrom Federation

(“ICF”) since 1988.

3.W.P. (C) No. 17077/2024 filed by the PCA prayed for a) quashing

2023-Election result dated 27.08.2023; b) a direction to the UOI not to

approve 2023-Election; c) a direction to AICF not to use the title ‘India’ or

‘Indian’ on the basis of letters dated 05.07.2011 and 16.10.2018 whereby UOI

directed all NSFs which are not recognised by the Ministry of Youth Affairs

and Sports (“Ministry”) not to use the title ‘India’ or ‘Indian’ in all events

(National / International) and also not to function or control and regulate the

game of Carrom in the country in violation of clause 3.6 (3) of National Sports

Development Code of India (NSDCI), 2011 (“Sports Code”) till Government

recognition is granted to AICF; and d) directions for holding of fresh elections

of AICF on the basis of electoral college of 2012, which is compliant with the

Sports Code, under the supervision of a Retired Judge of this Court as the

Returning Officer.

4.The reliefs sought in W.P. (C) No. 17077/2024 filed by PCA and W.P.

(C) No. 8665/2025 filed by MCA were identical, save and except that W.P.

(C) No. 8665/2025 additionally sought a declaration that Respondent No. 3

therein, namely, Vidarbha Carrom Association, could not form part of AICF

on account of violation of Clause 3.10 of the Sports Code.

5.The learned Single Judge,videthe Impugned Order, disposed of the

Writ Petitions by observing that: (i) in the absence of renewal of AICF’s

recognition by the UOI, AICF shall change its name so as to delete the word

‘India’ from its nomenclature; (ii) whenever any team is sent by AICF, such

team shall be sent only under its changed/amended name, and AICF shall

specify that the team is from India and shall not project such team as the

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Indian Team recognised by the Government of India; and (iii) AICF shall not

use the expression ‘India’ or ‘Indian’ in any manner, whether in its name,

logo, or in competitions conducted by it.

6.The learned Single Judge,videthe Impugned Order, further granted

liberty to AICF to use the expression ‘Team from India’ to indicate that the

representation was from India and to make a representation to the UOI for

recognition as an NSF, having regard to the fact that AICF had earlier been

recognised by the UOI as an NSF. The learned Single Judge further directed

that, in the event such representation was made by AICF, the same would be

duly considered by the UOI; that AICF would comply with all directions

issued by the UOI in relation to the grant of recognition; and that, if the UOI

was satisfied with the compliances made by AICF, it could proceed to grant

recognition to AICF in accordance with law and after following due

procedure.Insofar as the 2023-Election was concerned, the learned Single

Judge did not examine the said issue, in view of the stand taken by the UOI

that AICF was not a recognised NSF.

FACTUAL MATRIX

7.In 2011, the Ministry framed the Sports Code, consolidating the

guidelines on recognition of NSFs, eligibility conditions, affiliation with the

concerned International Federation, representation of eminent sportspersons,

the One State One Unit principle, suspension and withdrawal of recognition,

and the Model Election Guidelines for NSFs (“Guidelines”).

8.After implementation of the Sports Code, AICF held its first election

on 22.07.2012 (“2012-Election”). The 2012-Election was challenged in W.P.

(C) No. 110/2013, titledV.D. Narayan v. Union of India, on the ground of

violation of Clause 3.10 of the Sports Code. In those proceedings, the UOI

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filed an affidavit dated 06.07.2013 clarifying that the 2011 Guidelines applied

only to NSFs seeking recognition after their issuance and not retrospectively

to NSFs already existing and recognised. Thereafter, the writ petition was

withdrawn.

9.On 29.11.2015, AICF held elections at Guwahati (“2015-Election”).

The UOI,videletter dated 04.02.2016, declared the 2015-Election invalid for

violation of the Guidelines and directed fresh elections. AICF challenged the

said letter in W.P. (C) No. 3314/2016, titledAll India Carrom Federation v.

Union of India. The learned Single Judge,videjudgment dated 06.08.2018,

upheld the direction to conduct fresh elections.

10.On 30.10.2018, AICF notified the election programme, pursuant to

which MCA and other State associations filed nominations for the AICF

election scheduled on 18.11.2018 (“2018-Election”). The electoral college

was prepared on 04.11.2018, listing 53 candidates. The Returning Officer

thereafter prepared Form-3 on 09.11.2018 and Form-4 containing the list of

validly nominated candidates on 10.11.2018.

11.Thereafter, thirteen State carrom associations filed C.S. (OS) No.

576/2018, titledHaryana Carrom Association & Anr. v. All India Carrom

Federation, before this Court on 14.11.2018, seeking a declaration that the

electoral college published by AICF on 04.11.2018 and the Returning

Officer’s order dated 10.11.2018, along with the list of valid nominations,

were illegal, null and void; directions to include the plaintiffs’ nominees in

the electoral college; and injunctions for constitution of a valid electoral

college, conduct of elections in accordance with the Sports Code, AICF Rules

and Government notifications, and restraint against certain defendants from

contesting the 2018-Election.

LPA 697/2025 with connected matters Page 6 of 26

12.The Ministry,videletter dated 07.03.2019, granted AICF provisional

recognition until 31.03.2019 or the decision in C.S. (OS) No. 576/2018,

whichever was earlier. By letter dated 17.01.2020, the Ministry accepted the

2018-Election, took the elected office bearers and Managing Committee on

record for 2018-22, and renewed AICF’s recognition with immediate effect,

subject to the outcome of C.S. (OS) No. 576/2018.

13.By letter dated 07.12.2020, the Ministry raised violation of Clause 3.10

of the Sports Code, noting that AICF had two units in Maharashtra, namely

MCA and Vidarbha Carrom Association, both of whose members had voting

rights and were elected, contrary to the One State One Unit principle.

14.AICF replied on 22.12.2020, relying upon the Ministry’s stand in W.P.

(C) No. 110/2013 concerning Clause 3.10 of the Sports Code and the One

State One Unit principle in relation to the 2012-Election.

15.This Court,videjudgment dated 06.04.2023 inHaryana Carrom

Federation Association(supra), declared the 2018-Election illegal and

directed AICF to conduct fresh elections within six months under the

Ministry’s supervision.

16.AICF,videcommunications dated 11.04.2023, 30.04.2023 and

19.05.2023, informed the Ministry of the judgment dated 06.04.2023 in

Haryana Carrom Federation Association(supra) and sought compliance

therewith.

17.For the 2023-Election, AICF notified the election notice and

programme on 01.08.2023. PCA, by e-mail dated 04.08.2023, stated that it

had not received an invitation to submit nomination forms.

18.MCA, by e-mail dated 11.08.2023, recommended its representatives.

On 15.08.2023, it requested AICF and the Returning Officer to correct the

LPA 697/2025 with connected matters Page 7 of 26

voter list by adding Ajit Sawant, who intended to contest the 2023-Election,

and sent reminders on 18.08.2023, 20.08.2023 and 24.08.2023.

19.AICF notified the electoral college for the 2023-Election on

22.08.2023. On the same date, several associations informed AICF that they

had not received invitations to submit nomination forms.

20.Meanwhile, AICF, by e-mail dated 17.08.2023, requested the UOI to

nominate a Ministry observer for the Annual General Meeting (“AGM”) and

the 2023-Election under Clause 3.13 of the Sports Code. At the AGM held on

27.08.2023, the Returning Officer, Mr. Justice S.S. Chauhan, former Judge of

the Allahabad High Court, declared the 2023-Election results unanimous. The

President, ICF attended through video conferencing.

21.AICF,videletter dated 30.08.2023, submitted the Election Officer’s

Report and the 2023-Election results to the Ministry.

22.On 04.09.2023, PCA represented the UOI that the 2023-Election

involved inclusion of over 20 ineligible persons in the electoral college and

the election of 7 to 8 members contrary to the Sports Code. PCA requested

the Ministry not to approve or take the 2023-Election on record, to declare it

null and void, and to direct fresh elections.

23.The UOI,videletter dated 15.01.2024, sought clarifications from AICF

regarding,inter alia, Government employees elected at the AGM, their past

elected posts, sportspersons in the Executive Committee, and the tenure of

AICF President, Shri Rakibul Hussain.

24.AICF replied on 06.02.2024 and furnished the information sought.

Subsequently, in response to PCA’s RTI application, the Ministry, by letter

dated 17.12.2024, stated that no federation had been recognised for Carrom

and that the 2023-Election was not in accordance with the Sports Code.

LPA 697/2025 with connected matters Page 8 of 26

25.On 29.10.2025, the learned Single Judge passed the Impugned Order,

against which AICF, MCA and PCA filed the present Appeals.

26.Pursuant to this Court’s orders dated 17.11.2025 and 30.01.2026

directing the Ministry to decide on the Returning Officer’s report dated

30.08.2023, the Ministry, by letter dated 06.02.2026, held that the 2023-

Election was not in accordance with the Sports Code, the Guidelines and other

extant Ministry guidelines; accordingly, it could not be taken on record and

annual recognition based thereon could not be considered.

27.AICF, by letter dated 09.02.2026, objected to the Ministry’s letter dated

06.02.2026 and challenged it in W.P. (C) No. 3513/2026. By order dated

11.05.2026, the learned Single Judge directed that the Ministry’s letter be

treated as a show-cause notice and AICF’s reply as its response and directed

the UOI to pass a fresh order on AICF’s recognition within eight weeks.

28.Pursuant thereto, the Ministry passed order dated 10.07.2026 holding

that the 2023-Election could not be taken on record,inter alia, because two

associations from Maharashtra, namely MCA and Vidarbha Carrom

Association, were included in the electoral college in violation of Clause 3.10

of the Sports Code.

29.AICF has filed W.P. (C) No. 10610/2026 challenging the order dated

10.07.2026. The learned Single Judge issued notice in the said writ petition

on 30.07.2026 and the next date is on 14.09.2026.

SUBMISSIONS ON BEHALF OF AICF

30.The following submissions were made on behalf of AICF:

30.1.AICF has represented India in nearly fifty international

championships and has consistently selected and fielded Indian

teams. Its legal identity, international affiliation, event records,

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contractual rights, registrations, goodwill, bank accounts and

consequential rights are inseparably linked to its existing name. A

compulsory change of name would jeopardise its international

affiliation and seriously prejudice Indian sportspersons. No

statutory provision empowers the Ministry to compel AICF to

delete the word ‘India’ from its long-standing name.

30.2.Annexure III of the Sports Code permits suspension or withdrawal

of recognition only after following the prescribed procedure and

affording the concerned NSF an opportunity of hearing. No such

proceedings have been initiated or concluded against AICF.

Absent any order of suspension or withdrawal, AICF continues to

function as the NSF for Carrom. The Ministry’s affidavit dated

30.01.2025 in W.P. (C) No. 17077/2024 also does not state

otherwise, and the learned Single Judge proceeded principally on

oral submissions and an RTI response dated 17.12.2024, neither

supported by pleadings on oath.

30.3.InUnion of India v. Taekwondo Federation of India & Anr.,

LPA 5/2026, a Division Bench of this Court held that non-renewal

of annual recognition does not result in automatic withdrawal or

de-recognition, and that suspension or withdrawal can occur only

in accordance with Annexure III of the Sports Code after due

process.

30.4.Clause 3 of Annexure II of the Sports Code requires an

organisation seeking recognition to be already registered, have

affiliated State associations across India, conducted National

Championships for the prescribed period, and to be affiliated with

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the concerned International Federation. International affiliation is

also an independent requirement under Clause 3.15 and is not

dependent on Government recognition. Recognition therefore

acknowledges an existing NSF; it does not create the federation or

confer its name. The Ministry consequently lacks statutory

authority to direct deletion of the word ‘India’ from AICF’s name,

which predates recognition by decades.

30.5.The 2023-Election was held unanimously with participation of all

members, under the supervision of a Returning Officer who was a

former High Court Judge and was also observed electronically by

ICF.

30.6.The Ministry failed to comply with the directions inHaryana

Carrom Federation Association(supra). Although the Returning

Officer’s report was submitted on 30.08.2023, the Ministry

remained silent for nearly 889 days and issued its communication

only on 06.02.2026 pursuant to this Court’s orders dated

17.11.2025 and 30.01.2026 in LPA 697/2025. While Clause 3.10

of the Sports Code was initially relied upon to decline renewal of

recognition, the communication dated 06.02.2026 introduced six

new allegations.

30.7.The Ministry’s order dated 10.07.2026 substantially departed from

its letter dated 06.02.2026 and ignored its affidavit dated

06.07.2013 in W.P. (C) No. 110/2013, pursuant to which the 2012-

Election was accepted despite two units each representing

Maharashtra/Vidarbha and Andhra/Hyderabad. After the said

affidavit was filed, W.P. (C) No. 110/2013 was withdrawn.

LPA 697/2025 with connected matters Page 11 of 26

30.8.Videorder dated 11.05.2026 in W.P. (C) No. 3513/2026, the

learned Single Judge directed that the communication dated

06.02.2026 be treated only as a show-cause notice, in view of

violation of the principles of natural justice.

30.9.The aforesaid sequence demonstrates arbitrariness and absence of

a fair decision-making process, with the Ministry taking

inconsistent stands at different stages of the same dispute.

30.10.After the 2023-Election, AICF conducted nine National

Championships involving approximately 2,705 sportspersons

from 25-26 States/UTs and major Government institutions, and

Indian teams selected by AICF achieved overall medal success in

major international championships.

30.11.Thousands of players, particularly from economically weaker

sections, depend on such championships for sports-quota

appointments, scholarships, promotions, cash awards and other

Government benefits. Owing to the Impugned Order, only one

National Championship could be conducted in 2025-26 and

certificates remain unissued, seriously prejudicing numerous

sportspersons.

30.12.The directions in the Impugned Order are contrary to the Sports

Code, inconsistent with the autonomy of sports bodies, and

incapable of implementation in view of AICF’s international

affiliation.

30.13.Accordingly, LPA 697 / 2025 deserves to be allowed in the

interests of certainty in sports administration and the welfare of

Indian sportspersons.

LPA 697/2025 with connected matters Page 12 of 26

SUBMISSIONS ON BEHALF OF MCA AND PCA:

31.The following submissions were made on behalf of MCA and PCA:

31.1.LPA 697 / 2025 filed by AICF is not maintainable, as AICF has

challenged the Impugned Order only in W.P. (C) No.

17077/2024; consequently, the order passed in the other writ

petitions has attained finality. In any event, AICF’s case that it

continues to be an NSF, retains recognition, and complies with

the Sports Code is misconceived. AICF was granted annual

recognition from 2010 to 2015 and, thereafter, no recognition was

granted in 2016. Recognition granted on 29.09.2017 pursuant to

the order dated 25.08.2017 in Review Petition No. 325/2017 in

LPA No. 407/2017 was stayed by the Supreme Court in SLP (C)

No. 35735/2017. Thereafter, AICF received only provisional

annual recognition on 07.03.2019 and 17.01.2020, subject to the

final decision in C.S. (OS) No. 576/2018. The UOI notified AICF

of violation of the One State One Unit principle on 07.12.2020,

and no annual recognition has been granted thereafter.

31.2.As regards the 2023-Election, the UOI, by order dated

06.02.2026, held that the said election was unacceptable. AICF

challenged that order in W.P. (C) No. 3513/2026, which was

disposed of on 11.05.2026 with a direction to the UOI to consider

AICF’s reply dated 09.02.2026 on recognition. The UOI

thereafter passed a fresh order dated 10.07.2026 assigning

reasons. AICF has challenged that order in W.P. (C) No.

10610/2026, which is pending and is not the subject of the present

Appeals. Further, AICF itself issued a letter dated 04.11.2025 to

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all State associations stating that its name stood changed to

Carrom Federation and that no State association should hold any

event.

31.3.AICF’s last three elections, namely the 2015-Election, 2018-

Election and 2023-Election, were all contrary to the Sports Code.

The UOI declined to accept the 2015-Election on account of

serious illegalities, and that decision was upheld by this Court in

All India Carrom Federation v. Union of India, 2018 SCC

OnLine Del 10337.

31.4.Despite the judgment inHaryana Carrom Federation

Association(supra), AICF altered the electoral college for the

2023-Election and excluded the beneficiary State associations

despite e-mails to AICF and the Returning Officer. Consequently,

the UOI declined to accept the 2023-Election.

31.5.The 2023-Election suffered from material violations of age and

tenure requirements, Clause 3.10 of Annexure II to the Sports

Code incorporating the One State One Unit principle, andRahul

Mehra v. Union of India, 2022 SCC OnLine Del 2438, which

mandates fair, transparent and Code-compliant NSF elections,

including 25% representation of eminent sportspersons.

Recognition cannot be granted to a non-compliant NSF.

31.6.Given that AICF’s last three elections were unlawful, this Court

may appoint a retired High Court Judge as Administrator, assisted

by a senior Ministry official, to conduct fresh elections on the

undisputed 2015 electoral college and amend AICF’s Rules in

conformity with the National Sports Governance Act, 2025

LPA 697/2025 with connected matters Page 14 of 26

(“NSG Act”) and the NSG (National Sports Bodies) Rules, 2026

(“NSG Rules”).

31.7.Before finalising the electoral college, the Administrator may

decide the One State One Unit issue by merging Vidarbha Carrom

Association with MCA. A similar merger of Hockey Vidarbha

with Hockey Maharashtra was upheld by the Bombay High Court

inVidarbha Hockey Association v. Hockey India, W.P. No.

2052/2020, and the SLP was dismissed on 26.05.2025.

31.8.Fresh AICF elections may be conducted under the amended

Constitution and in compliance with the NSG Act and NSG

Rules. AICF may bear 50% of the Administrator’s expenses, with

administrative assistance from one AICF representative and one

representative of MCA/PCA or their nominee.

31.9.As to selection trials for Nationals and the World Cup, AICF has

produced no material showing that Italy was awarded the World

Cup or identifying the city, venue, accommodation or other

arrangements. In the absence of such particulars, players may face

financial and logistical risk. It is also submitted that Shri V.D.

Narayan is Secretary General of ICF, and 71 players have e-

mailed objections to ICF with copies to the UOI.

31.10.Without prejudice, if a team is to be sent, the Administrator and

Ministry official may hold selection trials by inviting all State

associations in the 2015 electoral college and those presently on

AICF’s rolls. No eligible player should be excluded due to alleged

illegal removal of a State association. Entries may be forwarded

by AICF’s Executive Committee; players shall bear participation,

LPA 697/2025 with connected matters Page 15 of 26

airfare and visa costs. No AICF official shall accompany the team

at federation expense. MCA is willing to bear 50% of trial

expenses, with the balance by AICF.

31.11.Administrators have been appointed by the Court in the past in

several sports, including football, basketball, judo and lawn

tennis. Reliance is placed onPondicherry Basketball Assn. v.

Union of India, 2023 SCC OnLine Del 2495, andAll India

Tennis Assn. v. Somdev Kishore Devvarman, 2026 SCC OnLine

Del 4824; inPondicherry Basketball Assn.(supra), writ petitions

challenging elections and results were held maintainable.

31.12.Since MCA’s and PCA’s reliefs were not fully adjudicated, the

Appeals may be brought to a quietus by appointing an

Administrator, thereby satisfying the prayers in W.P. (C) Nos.

17077/2024 and 8665/2025. Cont. Case (C) No. 1297/2023 and

W.P. (C) No. 10610/2026 may also be disposed of given that

AICF had agreed before this Court to such appointment.

SUBMISSIONS ON BEHALF OF THE UOI

32.The following submissions were made on behalf of UOI:

32.1.One of the principal grounds raised by AICF in LPA 697/2025 is

the Ministry’s alleged failure to act on the election report dated

30.08.2023. However, pursuant to this Court’s orders dated

17.11.2025 and 30.01.2026, the Ministry issued letter dated

06.02.2026, which AICF challenged in W.P. (C) No. 3513/2026.

In compliance with the order dated 11.05.2026 passed therein, the

Ministry reconsidered the 2023-Election after considering

AICF’s objections dated 09.02.2026 and passed a detailed order

LPA 697/2025 with connected matters Page 16 of 26

dated 10.07.2026. Accordingly, the objection regarding non-

consideration of the 2023-Election is without merit and, to that

extent, LPA 697/2025 has become infructuous.

32.2.The 2023-Election is inconsistent with the Sports Code and the

extant Ministry guidelines,inter alia, on the following grounds:

a.The inclusion of two State associations from Maharashtra

in the electoral college for the 2023-Election violated

Clause 3.10 of the Sports Code.

b.Clause 3.20 of the Sports Code mandatorily requires 25%

representation of sportspersons of outstanding merit on an

NSF’s executive board. AICF’s Constitution contains no

corresponding provision.

c.The Sports Code permits an individual to hold the office of

President for a maximum of twelve years, with or without

break. Shri Rakibul Hussain, President of AICF, had

exceeded the said limit as on 17.07.2025.

32.3.AICF has already challenged the Ministry’s order dated

10.07.2026 in W.P. (C) No. 10610/2026, which remains pending

before this Court. In the absence of any interim order therein and

having regard to the material discrepancies in the 2023-Election,

the Ministry cannot presently take the said election on record or

renew AICF’s recognition.

32.4.Under Clause 8.2 and Annexure XV of the Sports Code, every

NSF must obtain annual recognition. Annexure XV provides that

a federation failing to comply with the requirements for annual

renewal ceases to be an NSF. Upon submission of election details,

LPA 697/2025 with connected matters Page 17 of 26

the Ministry is required to examine the results and thereafter

consider renewal of recognition.

32.5.InTaekwondo Federation(supra), this Court,videorder dated

06.01.2026, held that an NSF must be afforded an opportunity to

present its defence before recognition is withdrawn. In the present

case, AICF’s objections dated 09.02.2026 were duly considered

before the Ministry passed order dated 10.07.2026.

32.6.During the pendency of these proceedings, the NSG Act was

partially notified and brought into force with effect from

01.01.2026. Section 4 thereof prescribes mandatory compliance

requirements for every NSF, including constitution of an Athletes

Committee and Ethics Committee, inclusion of sportspersons on

the executive board, and compliance with age, tenure and board-

size limits.

32.7.The NSG Rules were notified on 12.01.2026. Rule 18 mandates

every NSF to amend its bye-laws in conformity with the NSG Act

within six months.

32.8.In view of the prevailing factual and legal position, even if AICF

succeeds in W.P. (C) No. 10610/2026, it would remain non-

compliant with the NSG Act. Until AICF brings itself into

conformity with the NSG Act and applies afresh for recognition,

it cannot be treated as an NSF.

32.9.Clause 3.6(2) of the Sports Code provides that an NSF failing to

comply with applicable Government guidelines shall not be

permitted to use the word ‘India’ in its name. The Ministry’s

letter dated 16.10.2018 further clarifies that only recognised

LPA 697/2025 with connected matters Page 18 of 26

NSFs may use the expressions ‘India’ or ‘Indian’; bodies whose

recognition has been suspended or withdrawn, or which fail to

complete renewal formalities within six months of expiry of

recognition, lose the right to use those expressions.

32.10.The Emblems and Names (Prevention of Improper Use) Act,

1950 also prohibits use of the word ‘India’ in the name of any

entity without prior Government approval, where such use may

suggest patronage of the Government of India.

32.11.As regards AICF’s grievance concerning participation in the 9

th

World Carrom Championship, 2026, there is no restriction on

AICF sending athletes for domestic or international tournaments.

However, since AICF is not presently recognised as an NSF by

the Ministry, the restrictions contained in the Ministry’s letter

dated 16.10.2018 regarding use of the expressions ‘India’ or

‘Indian’ apply to it.

32.12.At this stage, the Ministry is not in a position to verify thebona

fidesof ICF, which is not affiliated with any recognised

international body such as the Indian Olympic Association or the

Olympic Council of Asia. Accordingly, the Ministry cannot

provide funds to AICF or to athletes for participation, and winners

may not be eligible for employment under sports quota or other

benefits available in Ministry-recognised competitions.

32.13.Since AICF is not presently recognised, the Ministry has no

regulatory control or authority over it. It is therefore for AICF to

bring itself in conformity with the NSG Act, 2025, without any

role of the Ministry in that process.

LPA 697/2025 with connected matters Page 19 of 26

32.14.Once AICF aligns itself with the NSG Act, 2025, it may apply

afresh for recognition, and such application shall be considered

on its own merits.

32.15.Since the Ministry neither recognises nor exercises regulatory

control over AICF, it cannot bear costs associated with its

functioning or depute any officer to oversee its administration. If

this Court appoints an Administrator, the attendant costs must be

borne by AICF or other persons interested in its functioning.

ANALYSIS AND FINDINGS

33.We have heard learned counsel for AICF, the UOI, MCA and PCA, and

have perused the material on record.

34.The principal issue arising in these Appeals is whether, in absence of

any order suspending or withdrawing AICF’s recognition under the Sports

Code, and in the absence of any statutory provision empowering the Ministry

to alter the name of an existing sports federation, the UOI/Ministry could

direct AICF to remove the words ‘India’ or ‘Indian’ from its name.

35.AICF contended that the Ministry has passed no order suspending or

withdrawing its recognition as an NSF under the Sports Code. The Ministry’s

affidavit dated 30.01.2025 in W.P. (C) No. 17077/2024 also does not state

that AICF’s recognition has been suspended or withdrawn. AICF submitted

that the learned Single Judge relied on oral submissions advanced on behalf

of the Ministry, without any documentary material on record evidencing such

suspension or withdrawal. AICF further relied upon Annexure III of the

Sports Code to contend that recognition of an NSF can be suspended or

withdrawn only after following the prescribed procedure and affording the

concerned NSF an opportunity of hearing.

LPA 697/2025 with connected matters Page 20 of 26

36.The Impugned Order proceeded on the basis that AICF’s recognition

had not been renewed by the UOI and that, in the absence of such renewal,

AICF could not be regarded as an NSF and the issue of suspension or

withdrawal of AICF’s recognition in accordance with the Sports Code was

not discussed therein.

37.The Impugned Order further directed AICF, being a body earlier

recognised by the UOI/Ministry as an NSF, to submit a representation for

recognition as an NSF. It further directed that, if such representation was

made, the UOI would consider it in accordance with law and that AICF would

comply with all directions issued by the UOI regarding recognition and that,

upon being satisfied with such compliance, the UOI could grant recognition

after following due procedure.

38.The Impugned Order also directed that, until AICF was recognised by

the Ministry as an NSF, it shall not use the expressions ‘India’ or ‘Indian’ in

any manner, whether in its name, logo or competitions conducted by it, while

granting liberty to use the expression ‘Team from India’.

39.However, instead of filing a representation as observed in the

Impugned Order, AICF challenged the Impugned Order by filing LPA

697/2025. Notice was issuedvideorder dated 17.11.2025, wherein this Court

observed that AICF’s prayer for renewal of recognition, based on the 2023-

Election, remained pending consideration before the UOI, notwithstanding

that the clarification sought by the UOIvideletter dated 15.01.2024 had

already been furnished by AICF on 06.02.2024. This Court further observed

that the 2023-Election had not been set aside or declared invalid by any

authority or Court. Accordingly, as an interim measure, AICF was permitted

to send a team to the international event scheduled from 02.12.2025 to

LPA 697/2025 with connected matters Page 21 of 26

06.12.2025 and to use the expressions ‘India’ or ‘Indian’ only for that event.

It was further directed that, in the event of any future international event,

AICF shall seek leave of this Court before sending any team or initiating the

process for selection of players.

40.AICF, thereafter, filed CM APPL. 79570/2025 in LPA 697/2025

seeking leave of this Court to host the 9

th

Carrom World Championship, 2023

as allotted by ICF, and to conduct the 53

rd

Senior National Carrom

Championship for selecting the Indian Team for the said international event.

41.Videorder dated 17.12.2025, notice was issued in CM APPL.

79570/2025 in LPA 697/2025 and response thereto was directed to be filed

within two weeks. Pursuant thereto, the UOI/Ministry filed its reply dated

27.01.2026, annexing letter dated 24.01.2026 issued to AICF, stating that there

was no change in the status of AICF’s recognition as an NSF.

42.Videorder dated 30.01.2026 passed in LPA 697/2025, this Court

observed that the letter dated 24.01.2026 could not be treated as the decision

expected from the UOI on AICF’s prayer for renewal of recognition based on

the 2023-Election. Accordingly, the UOI was directed to take a decision in

terms of the order dated 17.11.2025 by the next date of listing.

43.Pursuant to the order dated 30.01.2026, the UOI/Ministry,videorder

dated 06.02.2026, held that the 2023-Election was not in accordance with the

Sports Code or the extant guidelines issued by the Ministry from time to time.

Consequently, the said election could not be taken on record, and AICF’s

request for renewal of annual recognition as an NSF based thereon could not

be considered.

44.AICF challenged the order dated 06.02.2026 by filing W.P. (C) No.

3513/2026 before the learned Single Judge of this Court. Notice was issued

LPA 697/2025 with connected matters Page 22 of 26

on 18.03.2026, and the UOI/Ministry was directed to file its counter affidavit.

In its counter affidavit, the UOI/Ministry stated that the election process

undertaken by AICF was not in conformity with the Sports Code and the

Guidelines.

45.Videorder dated 11.05.2026, the learned Single Judge observed that,

although the order dated 06.02.2026 may have been passed in compliance

with the directions issued in LPA 697/2025, it could not have been issued

without affording AICF an opportunity of hearing. Accordingly, the order

dated 06.02.2026 was directed to be treated as a show-cause notice to AICF.

The writ petition was disposed of with a direction to the UOI/Ministry to pass

a fresh order on AICF’s recognition within eight weeks from the date of the

order.

46.Pursuant to the order dated 11.05.2026 passed by the learned Single

Judge in W.P. (C) No. 3513/2026, the UOI/Ministry passed order dated

10.07.2026 holding that AICF’s elections had been conducted in

contravention of the Sports Code, the Guidelines and the extant guidelines

issued by the Ministry from time to time. Consequently, the said elections

could not be taken on record, and AICF’s request for renewal of annual

recognition as an NSF on that basis was not accepted by the Ministry.

47.AICF has challenged the order dated 10.07.2026 in W.P. (C) No.

10610/2026 before the learned Single Judge of this Court. Notice was issued

therein on 30.07.2026, and the UOI was directed to file its counter affidavit

within four weeks. The next date of hearing of the said petition is 14.09.2026.

48.In view of the subsequent developments after passing of the Impugned

Order by the learned Single Judge, we are of the considered view that AICF’s

principal grievance regarding non-renewal of its recognition as an NSF has

LPA 697/2025 with connected matters Page 23 of 26

been addressed by the UOI/Ministry in the order dated 10.07.2026, which is

presently under challenge before the learned Single Judge in W.P. (C) No.

10610/2026.

49.Learned SPC for the UOI/Ministry submitted that, in view of the

notified provisions of the NSG Act and the NSG Rules, AICF must comply

therewith before seeking recognition as an NSF. It was further submitted that,

even if AICF succeeds in W.P. (C) No. 10610/2026 and the order dated

10.07.2026 is set aside, AICF would still be required to comply with the NSG

Act and the NSG Rules.

50.In view thereof, this Court queried the authorised representative of

AICF, who appeared in person, regarding compliance with the NSG Act and

the NSG Rules. It was submitted on behalf of AICF that it is willing to comply

with the said provisions for seeking recognition as an NSF.

51.The only issue that survives for consideration is whether AICF can use

the expressions ‘India’ or ‘Indian’ in its name and send an Indian team for

national or international Carrom competitions, till such time AICF is

recognised as NSF pursuant to compliance with NSG Act and NSG Rules.

52.AICF has relied on the decision of this Bench inTaekwondo

Federation(supra), wherein it was held that withdrawal of recognition or de-

recognition of an NSF can take place only by a positive act, after affording

the concerned NSF an opportunity of hearing, and cannot occur automatically.

The said requirement was held to flow from the principles of natural justice

governing administrative action by a public authority or body.

53.A perusal of the letter dated 07.12.2020 issued by the UOI/Ministry

shows that AICF was not afforded an opportunity of hearing before renewal

of its recognition as an NSF was refused. The said letter is, therefore, contrary

LPA 697/2025 with connected matters Page 24 of 26

to the analysis of the law inTaekwondo Federation(supra), which requires

suspension or withdrawal of NSF recognition to be undertaken only in

accordance with Annexure III of the Sports Code, including the prescribed

procedure and consequences thereof.

54.Accordingly, the letter dated 07.12.2020 cannot be treated as an order

suspending or withdrawing AICF’s recognition as an NSF. The said

communication merely recorded the Ministry’s objection regarding alleged

non-compliance with Clause 3.10 of the Sports Code and did not purport to

initiate or conclude proceedings under Annexure III thereof. In the absence of

a notice, opportunity of hearing, reasoned determination and consequential

order passed in accordance with the prescribed procedure, there can be no

automatic or deemed withdrawal or de-recognition of AICF as an NSF, as

held inTaekwondo Federation(supra) on the basis of letter dated

07.12.2020.

55.Accordingly, Annexure III of the Sports Code was not complied with

by UOI at the time of issuance of letter dated 07.12.2020 and, therefore, the

same cannot be treated as an order suspending or withdrawing AICF’s

recognition as an NSF. The said communication did not record that

proceedings for suspension or withdrawal had been initiated, nor did it

disclose that AICF had been served with a notice or afforded an opportunity

to answer the allegation of non-compliance. It also did not contain any final

determination, supported by reasons, that AICF’s recognition stood

suspended or withdrawn.

56.However, the Impugned Order did not examine the legal effect of the

letter dated 07.12.2020 on AICF’s status as an NSF in the light of Annexure

III of the Sports Code. Instead, it proceeded on the premise that non-renewal

LPA 697/2025 with connected matters Page 25 of 26

of annual recognition, by itself, was sufficient to deny AICF the status of an

NSF and restrained AICF from using the expressions ‘India’ or ‘Indian’.

Once the Sports Code prescribes a specific procedure for suspension or

withdrawal of recognition, that procedure could not have been bypassed based

on a communication which neither fulfilled the requirements of notice and

hearing nor resulted in a reasoned order. Consequently, the assumption

underlying the Impugned Order, namely that AICF had ceased to be an NSF

at the time when the Impugned Order was passed, is unsustainable.

57.Accordingly, the Impugned Order is liable to be set aside for having

proceeded without considering the mandatory procedure prescribed under the

Sports Code for suspension or withdrawal of recognition of an NSF.

58.We may, however, notice that during the pendency of these Appeals,

pursuant to the order dated 11.05.2026 passed in W.P. (C) No. 3513/2026, the

UOI/Ministry has afforded AICF an opportunity of hearing and has thereafter

passed a fresh order dated 10.07.2026. Consequently, the said order is not

subject matter of this appeal and it is now under challenge in the pending W.P.

(C) No. 10610/2026 before this Court, the legality, validity and effect thereof

shall be examined by the learned Single Judge in W.P. (C) No. 10610/2026,

which is pending at present. At the same time, we clarify that the present

judgment shall not affect the adjudication of W.P. (C) No. 10610/2026, which

shall be decided independently and on its own merits.

59.As regards compliance with the NSG Act and the NSG Rules, the same

shall have to be complied with by AICF irrespective of the setting aside of the

Impugned Order for being recognised as NSF.

LPA 697/2025 with connected matters Page 26 of 26

60.In view of the foregoing analysis, LPA 697/2025 is allowed and the

Impugned Order is set aside. Consequently, LPA 739/2025 and LPA

744/2025 are dismissed.

61.It is clarified that we have not expressed any opinion on the merits of

the challenge to the order dated 10.07.2026 passed by the UOI/Ministry,

which is the subject matter of W.P. (C) No. 10610/2026. The said writ petition

shall be decided independently and uninfluenced by any observations made

herein or in the Impugned Order. The present Appeals, along with all pending

Applications, stand disposed of in the aforesaid terms. There shall be no order

as to costs.

TEJAS KARIA, J

DEVENDRA KUMAR UPADHYAYA, CJ

SEPTEMBER 2, 2026/sms