The Tiruchirappalli District Cricket Association vs Anna Nagar Cricket Club and Anr Etc.

2026 INSC 154 REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO(S). OF 2026 ARISING OUT OF SLP (C) NO(S). 26653-26654 OF 2024

THE TIRUCHIRAPPALLI DISTRICT CRICKET ASSOCIATION ...APPELLANT(S)

VERSUS

ANNA NAGAR CRICKET CLUB & ANR. ETC. …RESPONDENT(S)

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 Signature Not Verified Digitally signed by Jayant Kumar Arora 16:24:06 IST Reason: Tamil Nadu Cricket Association (‘TNCA’), the State association. The Date: 2026.02.13

facts in both the appeals before the High Court were distinct in content

Page 1 of 19 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 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

Page 2 of 19 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

India 1 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

1 W.P. (MD) No. 3447 of 2019.

2 W.A. No. 1202 of 2022.

Page 3 of 19 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 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

Page 4 of 19 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

Page 5 of 19 the prayers of the writ petition, placing reliance 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

Page 6 of 19 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 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

Page 7 of 19 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 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.

Page 8 of 19 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)

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

3 CA No. 4235/2014.

Page 9 of 19 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

Page 10 of 19 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.

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

Page 11 of 19 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.

(…)

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

4 (2016) 8 SCC 535, Para 57.

Page 12 of 19 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 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

Page 13 of 19 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

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

5 2025 INSC 1131.

6 AIFF (supra), paras 64-71.

Page 14 of 19 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

Page 15 of 19 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 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

7 Article 38(2), Indian Constitution.

8 Article 39(b), Indian Constitution.

9 Article 38, Indian Constitution.

10 Article 15(2), Indian Constitution.

Page 16 of 19 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.

11 All India Football Federation v. Rahul Mehra, 2025 INSC 1131. Page 17 of 19

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

Page 18 of 19 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.

………………………………....J. [PAMIDIGHANTAM SRI NARASIMHA]

………………………………....J. [ALOK ARADHE]

NEW DELHI;

FEBRUARY 13, 2026

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