LexALL INDIA FOOTBALL FEDERATION versus RAHUL MEHRA & ORS.
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[2025] 9 S.C.R. 1146 : 2025 INSC 1131 All India Football Federation v. Rahul Mehra & Ors. (Civil Appeal No(s). 12591-12592 of 2025) 19 September 2025 [Pamidighantam Sri Narasimha and Joymalya Bagchi, JJ.] Issue for Consideration Should Eminent Players be in the General Body; if so, to what extent; what should be the Eligibility criteria to be designated an Eminent Player; whether ‘Office bearers’ should be limited to President, Treasurer, Secretary; whether the number of VPs should be increased to ensure regional representation; whether public servants should be included under disqualification events; whether ‘indirect interest’ should be retained in the definition of ‘conflict of interest’; should the All India Football Federation (AIFF) Constitution apply to state associations; what is the permissible extent of delegation of powers, functions, and exploitation of rights by AIFF to third parties; whether promotion and relegation should form part of the AIFF Constitution; to what extent are BCCI judgements applicable to football; should Amendments to the Constitution be approved by the Supreme Court; whether the current AIFF administration is a permanent or interim body. Headnotes† Sports – National Sports Development Code of India, 2011 – Draft Constitution of the appellant-Federation (AIFF) – Objections and suggestions from relevant stakeholders – Draft approved and finalised, with few modifications – AIFF to call for a special general body meeting and adopt the draft Constitution with the modifications, preferably within 4 weeks – National Sports Governance Act, 2025. [Paras 24-122] Sports – Should Eminent Players be in the General Body, to what extent – National Sports Development Code of India, 2011 – Clauses 3.9, 3.10 or 3.20: Held: 1.1 A harmonious and conjoint reading of clauses 3.9, 3.10 or 3.20 show that clause 3.20 is essentially a carve-out from clauses 3.9 or 3.10, and grants voting rights to the class of persons indicated [2025] 9 S.C.R. 1147 All India Football Federation v. Rahul Mehra & Ors. therein, i.e., “prominent sportspersons of outstanding merit” – The substantive composition of the organisational structure should consist of member associations, and it is contemplated to be an ideal situation to have eminent sportspersons having voting rights – The percentage indicated in clause 3.20 of the NSC 2011 is not transgressed by clause 20.2 of the draft Constitution. [Para 33] 1.2 The freedom of choice to form an association is not in any way compromised by the requirement to incorporate 15 eminent players – The democratic setup of the federation is not destabilised as the elected member associates certainly continue to hold more than 62% as the NSC 2011 u/clause 3.20 only suggests that the number of prominent sportspersons should be a minimum of 25% which means that model provision has not prohibited a number larger than 25% – The inclusion of eminent players, coaches, referees, and club representatives in the general body, will only further good governance, herald transparency and fair play – The draft provision not interfered with. [Paras 35, 36] Sports – Eligibility criteria for Eminent Players – Article 1.19 of the draft Constitution: Held: The draft Constitution prescribed a criterion – It is reasonable to reduce the eligibility criteria for an Eminent Player suggested by Justice L N Rao, to 5 matches for men and from 2 matches for women – Such modification will ensure a wider pool and participation by retired players who will prove themselves to be efficient administrators and guiding lights for Indian football – Submission of AIFF qua counting domestic experience for eminence status, not accepted – Domestic experience might not yield the result sought to be achieved with the adoption of the Constitution, which is formulated to project Indian football on the international panorama. [Para 40] Sports – Whether ‘Office bearers’ should be limited to President, Treasurer, Secretary – Definition of “Office-Bearers”: Held: Office bearers must be understood in the context of the functioning of the AIFF and the reform that needs to be brought about – This definition will have a direct bearing on the applicability of cooling-off, the term, tenure and age limit – The inclusive definition will be consistent with the reforms that have been introduced and applied as independent measures for the vibrant working of the federation. [Para 42] 1148 [2
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