Court Rules Ministry of Youth Affairs and Sports Must Follow Due Process Under National Sports Code Before Suspending or Withdrawing Recognition of National Sports Federations
In a significant judgment dated September 2, 2026, the Division Bench of the Delhi High Court, comprising Chief Justice Devendra Kumar Upadhyaya and Justice Tejas Karia, set aside an earlier order that directed the All India Carrom Federation (AICF) to remove the word "India" from its name and prohibited its use in any competitions or logos. The court emphasized that the Ministry of Youth Affairs and Sports (the Ministry) cannot unilaterally restrict the use of such nomenclature without adhering to the procedural safeguards outlined in the National Sports Development Code of India (Sports Code), 2011, and the recently enacted National Sports Governance Act, 2025.
Background and Proceedings:
The AICF, a society registered under the Societies Registration Act, 1860, has long claimed to be the National Sports Federation (NSF) for Carrom in India and has been affiliated with the International Carrom Federation since 1988. Despite its longstanding status, questions arose regarding the legality of its elections and compliance with the Sports Code's governance provisions.
The dispute intensified following the 2023 elections of AICF, which were challenged by the Maharashtra Carrom Association (MCA), the Union Territory Pondicherry Carrom Association (PCA), and others, on grounds including violation of the "One State One Unit" principle and irregularities in the electoral college. The Ministry refused to renew AICF's recognition as NSF based on these alleged irregularities and instructed AICF to cease using "India" or "Indian" in its name and official functions.
The Single Judge of the Delhi High Court had earlier directed AICF to remove "India" from its name and barred the use of the expressions "India" or "Indian," pending fresh recognition. AICF challenged this order in the present appeals.
Key Findings of the Court:
1. Procedural Fairness and Natural Justice:
The court underscored that suspension or withdrawal of recognition of an NSF must follow the procedure set forth in Annexure III of the Sports Code, which mandates notice, an opportunity to be heard, and a reasoned order. The Ministry's letter dated December 7, 2020, which refused renewal of recognition, did not constitute a formal order of suspension or withdrawal as it lacked these procedural steps.
2. Non-Renewal Does Not Equal De-Recognition:
The court held that mere non-renewal of annual recognition does not automatically result in de-recognition or loss of status as an NSF. Therefore, the Ministry lacked the authority to direct AICF to remove "India" from its name without following due process.
3. No Statutory Authority for Name Alteration by Ministry:
AICF's name and international affiliation predated government recognition. The court ruled that the Ministry has no statutory power to compel an existing registered sports federation to change its name or remove the word "India" without formal suspension or withdrawal of recognition.
4. Compliance with National Sports Governance Act, 2025:
The court noted the recent enactment of the National Sports Governance (NSG) Act, 2025, and the NSG Rules, 2026, which prescribe mandatory governance reforms for NSFs, including athlete representation and governance standards. AICF must comply with these provisions and apply afresh for recognition.
5. Interim Relief on Use of "India" and Sending Teams:
The court permitted AICF to send teams to international events during the pendency of appeals and allowed limited use of "India" or "Indian" in this context, subject to future compliance with the Sports Code and Ministry directives.
6. Pending Challenges to Ministry's Order:
The Ministry's later order dated July 10, 2026, refusing to take the 2023 elections on record and denying recognition, was not the subject of this appeal and remains under consideration by the Single Judge. The court clarified that this judgment does not influence the decision on that order.
Implications:
This judgment affirms the importance of procedural fairness in the governance of national sports federations in India. It reinforces that the Ministry of Youth Affairs and Sports must adhere to established codes and laws before restricting or withdrawing recognition from federations. Moreover, it highlights the mandatory compliance requirements under the new NSG Act, signaling a move towards greater transparency and athlete representation in sports administration.
The ruling also provides interim relief to AICF, ensuring continuity for athletes and competitions under its banner, while mandating compliance with governance norms. The case underscores the judiciary's role in balancing administrative oversight with the autonomy of sports bodies.
Bottom Line:
The decision evaluates the legality of the Ministry of Youth Affairs and Sports' actions concerning the All India Carrom Federation (AICF), particularly regarding its recognition as a National Sports Federation (NSF), the use of "India" in its name, and compliance with procedural safeguards under the National Sports Code and the National Sports Governance Act.
Statutory provision(s):
Societies Registration Act, 1860, National Sports Development Code of India, 2011 (Sports Code), National Sports Governance Act, 2025, National Sports Governance (National Sports Bodies) Rules, 2026, Emblems and Names (Prevention of Improper Use) Act, 1950
All India Carrom Federation v. Union of India, (Delhi)(DB) : Law Finder Doc Id # 2971974
