All India Football Federation v. Rahul Mehra 2025 INSC 1131 - All India Football Federation (AIFF) Constitution

Case Name and Neutral Citation

• Case Name: All India Football Federation v. Rahul Mehra & Ors.
• Neutral Citation: 2025 INSC 1131

Coram (Judges)

• Justice Pamidighantam Sri Narasimha
• Justice Joymalya Bagchi

Judgment Date

• Date: September 19, 2025

Caselaws and Citations Referred

1. BCCI v. Cricket Association of Bihar
2. • (2016) 8 SCC 535
   • (2022) 19 SCC 30
   • (2018) 9 SCC 624
2. Public Interest Foundation v. Union of India
3. • (2019) 3 SCC 224
3. Indian Olympic Association v. Union of India
4. • 2014 SCC OnLine Del 2967
4. Damyanti Naranga v. Union of India
5. • (1971) 1 SCC 678
5. Rahul Mehra v. Union of India
6. • 2022 SCC OnLine Del 2438
6. N.P. Ponnuswami v. Returning Officer, Namakkal Constituency
7. • AIR 1952 SC 64
7. Jagan Nath v. Jaswant Singh
8. • AIR 1954 SC 210
8. Dr. N. B. Khare v. Election Commission of India
9. • AIR 1958 SC 139

Statutes/Laws Referred

• National Sports Development Code of India, 2011 (NSC 2011)
• National Sports Governance Act, 2025 (NSGA 2025)
• Indian Constitution
• • Article 38(2)
  • Article 39(b)
  • Article 38
  • Article 15(2)
  • Article 19(1)(c)
• Representation of the People’s Act, 1951 (RPA)
• • Section 8(3)
• Indian Penal Code, 1860
• • Section 21 (definition of public servant)
• FIFA Statutes (2022, 2024)
• FIFA Standard Statutes, 2005
• Asian Football Confederation (AFC) Statutes
• Olympic Charter
• Arbitration and Conciliation Act, 1996

Reports and Academic Works Cited

• Mihir Bose, A History of Indian Cricket (London: Andre Deutsch Ltd, 1990)
• Boria Majumdar & Kausik Bandyopadhyay, A Social History of Indian Football: Striving to Score (Routledge, 2008)
• C Boillat and R Poli, ‘Governance Models Across Football Associations and Leagues’, International Centre for Sport Studies (2007)
• Jasina, John and Rotthoff, Kurt W., A Model of Promotion and Relegation in League Sports (Journal of Economics and Finance, 2012)
• Law Commission of India, Report No. 244, Electoral Disqualifications (February, 2014)

Case Basics

• Q: What is the case and citation?
• • A: All India Football Federation v. Rahul Mehra & Ors., 2025 INSC 1131 (Supreme Court of India, 19 Sept 2025).
• Q: Who authored the judgment and when?
• • A: The bench comprised Justice Pamidighantam Sri Narasimha and Justice Joymalya Bagchi; judgment dated 19 September 2025.
• Q: What is the central subject of the appeal?
• • A: Approval and finalization of the All India Football Federation (AIFF) Constitution, with scrutiny of objections/suggestions from stakeholders and alignment with the National Sports Code 2011 and FIFA/AFC statutes.

Procedural History and Context

• Q: What triggered Supreme Court’s involvement?
• • A: Delhi High Court’s 31.10.2017 order setting aside AIFF’s 2016 election for non-compliance with the National Sports Code 2011 (NSC 2011), appointment of an Administrator/Returning Officer, and directions to amend the AIFF Constitution.
• Q: What interim steps did the Supreme Court take?
• • A: Stayed the High Court’s para 22 directions (10.11.2017); appointed a Committee of Administrators (CoA) to draft a compliant AIFF Constitution; later reconstituted CoA (18.05.2022), organized stakeholder consultation, and enabled elections (03.08.2022 and 22.08.2022) to address FIFA suspension risk.
• Q: How did FIFA’s suspension affect proceedings?
• • A: FIFA suspended AIFF on 14.08.2022, prompting expedited elections to restore compliance for hosting the U-17 Women’s World Cup 2022 and for Indian teams’ international participation.
• Q: Why did Justice L. Nageswara Rao become involved?
• • A: On 02.05.2023, the Court tasked him with finalizing the AIFF draft Constitution given overlaps with IOA/BCCI reforms and mixed questions of law and policy.

Governing Legal Instruments and References

• Q: Which legal/regulatory sources guided the Court?
• • A: NSC 2011; FIFA Statutes (2022, 2024) and FIFA Standard Statutes (2005); AFC criteria; Constitutional provisions (Arts. 15(2), 38, 38(2), 39(b), 19(1)(c)); Representation of the People Act s. 8(3); IPC s. 21; Law Commission Report No. 244; BCCI line of cases (2016, 2018, 2022); Delhi High Court rulings on NSC/IOA and on applicability to constituents.
• Q: How did the Court consider the National Sports Governance Act, 2025?
• • A: Notified status pending; treated as filling a legislative void in interregnum and noted broad consonance with Justice L. N. Rao’s amendments (e.g., EC cap at 15, eligibility baseline of 25 years, women representation).

Core Issues and Holdings (Legal Focus)

1. Eminent Players in General Body and Voting Rights

• Q: Can eminent players be part of the General Body with voting rights?
• • A: Yes. The Court harmonized NSC 2011 clauses 3.9, 3.10, and 3.20, reading 3.20 as a carve-out allowing voting rights to “prominent sportspersons of outstanding merit.” FIFA’s model/statutes and global practice support player, coach, referee, and club representation.
• Q: Is the 15-player inclusion lawful?
• • A: Yes. Member associations retain roughly 62%+ share; 25% is a suggested minimum in NSC 2011, not a ceiling.

1. Eligibility Criteria for “Eminent Players”

• Q: What is the final match threshold to qualify as an eminent player?
• • A: Reduced to 5 competitive international matches for men and 2 for women (FIFA/AFC sanctioned), post-retirement of at least 2 years. Domestic matches will not count.

1. Definition of Office-Bearers

• Q: Who are “office-bearers”?
• • A: All elected members of the Executive Committee (EC) as per Article 25, not restricted to only President/Treasurer/Secretary. This broader definition aligns with age/tenure/cooling-off reforms.

1. Number of Vice-Presidents (VPs)

• Q: How many VPs will AIFF have?
• • A: Three, including at least one woman. A five-VP zonal scheme was rejected; EC must not exceed 15 (aligned with NSGA 2025 s. 4(1)(b)).

1. Disqualification Events

• Criminal Charge/Conviction
• • Q: Does framing of charges disqualify a candidate/office-bearer?
  • • A: No. The Court aligned with BCCI (2022): disqualification attaches on conviction followed by sentence of imprisonment; framing of charges alone is insufficient.
• Public Servant/Government Office
• • Q: Are public servants disqualified?
  • • A: Disqualification narrowed to “Minister or Government Servant,” consistent with BCCI (2022). Government servants may participate if they obtain requisite approvals (noted with reference to NSGA 2025 s. 4(2)(e)).
• Office-bearer in other NSFs
• • Q: Are former office-bearers of other NSFs barred from AIFF posts?
  • • A: No. A blanket bar was rejected as overly onerous (consistent with BCCI (2022) modifications).

1. Conflict of Interest (Indirect Interest)

• Q: Is “indirect interest” retained in conflict-of-interest definition?
• • A: Yes. Article 73.1(a) (indirect conflicts via relatives/associates) and Article 73.5 (direct dual-role incompatibilities) cover distinct scenarios; both retained.

1. Applicability of AIFF Constitution to State Associations

• Q: Must State associations align their constitutions with AIFF’s?
• • A: Yes. Article 15.1 obliges State bodies to mirror AIFF’s governance standards (e.g., EC composition, age/tenure/cooling-off, election processes, judicial bodies), consistent with FIFA’s hierarchical governance and High Court precedents. This mitigates circumvention (e.g., tenure/cooling-off evasion).

1. Delegation to Third Parties and Commercial Rights

• Q: Can AIFF divest essential functions to private parties?
• • A: No. Article 1.21 (“Essential Aspects”) acts as a boundary preserving AIFF’s primacy over organization, rules, promotion, approval of stakeholder rights, promotion/relegation sanctity, and FIFA/AFC compliance. Proposals to dilute this boundary (e.g., “entirely through a third party”) were rejected. AIFF is “fully responsible and accountable” (NSC 2011, cl. 6.1(b)).
• Q: What about FSDL’s suggestions on Article 63?
• • A: Addition of “ownership” deemed superfluous; removal of AIFF’s “not bound by third-party demand” clause and “entirely through a third party” model rejected to safeguard AIFF’s control and accountability. The MRA’s extended term ends in 2025; future contracts must respect Article 1.21’s boundary.

1. Promotion and Relegation

• Q: Must the senior-most top division league implement promotion and relegation?
• • A: Yes. Article 1.54 expressly requires it, aligning with FIFA Statutes 2024 (sporting merit). CAS’s Miami FC decision is inapplicable because India already adopted promotion (and committed to relegation from 2024–25). Deletions sought by FSDL were rejected.

1. Applicability of BCCI Judgments

• Q: Are BCCI reforms relevant to AIFF despite BCCI not being an NSF?
• • A: Yes. The Court applied BCCI principles of governance, integrity, and accountability as persuasive standards; NSC 2011 is to be effectuated purposively, not literally as if a statute.

1. Constitutional Amendments Requiring Supreme Court Leave

• Q: Will AIFF need Supreme Court’s leave to amend its Constitution?
• • A: Yes. Article 23.3 is inserted: no amendment shall be given effect without the leave of the Supreme Court (presently). The Court emphasized this is a transitional safeguard; perpetual monitoring is not ideal.

1. Status of the Current AIFF Executive Committee

• Q: Is the current EC interim or permanent?
• • A: Treated as permanent for its remaining term, subject to Court’s orders. Its term ends in September 2026 (less than a year from the judgment date).

Additional Holdings and Clean-Ups

• Q: What are the refined eligibility conditions for candidates?
• • A: Must be a citizen and resident of India, at least 25 years old, and a voting member of the General Body (Articles 1.11 and 25.4 amended accordingly; aligned with NSGA 2025 s. 4(2)).
• Q: Any special eligibility for top offices?
• • A: Article 25.4(A): President/Vice-Presidents/Treasurer must be a sportsperson of outstanding merit or have served at least one full term in the AIFF EC or as an office-bearer in an affiliate unit.
• Q: Did the definition of “immediate family” change?
• • A: Yes. Siblings added to “immediate family” (Article 1.32) to tighten conflict management.
• Q: What about member associations’ obligations?
• • A: Article 15 now expressly includes “disqualification event(s)” among mandatory governance elements to align with AIFF standards.
• Q: What voting threshold is needed to impose suspension?
• • A: Mirror threshold added: if 75% is required to revoke suspension (Article 17), an equivalent supermajority is now required to impose it, ensuring parity and fairness.
• Q: Can one person hold AIFF and State office-bearer roles simultaneously?
• • A: No. The CoA’s original clauses (b) and (c) were reinstated (as new clauses (c) and (d) of Article 25): election as AIFF office-bearer vacates State office-bearer post and vice versa. However, prior clause deeming EC office vacated due to suspension/expulsion of the member association was not reinstated.
• Q: Who serves as Acting President if President and Senior VP are incapacitated?
• • A: One of the other VPs or, if none, an EC member elected by simple majority till the next AGM (Article 25.6 modified).
• Q: Any quorum/vote safeguards for large commercial decisions?
• • A: Yes. Article 41.2 to include that business on commercial arrangements exceeding four years or Rs. 5 crore must meet the enhanced approval requirements, aligning with Article 20.9(m).
• Q: Composition of Disciplinary and Appeal Committees?
• • A: Only the chairperson and deputy chairperson need legal qualifications (Articles 46 and 47 modified), increasing inclusivity while maintaining due process.
• Q: Are there fast-track timelines for athlete disputes?
• • A: Yes. Article 51 gains provisos that matters affecting a player’s participation or urgency should be prioritized with a preferably within 30 days decision at both first instance and arbitral stages (Article 51.15 similarly supplemented).
• Q: Election bye-laws: can candidates nominate polling agents?
• • A: Restored. CoA’s original Article 9.2 (Schedule III) allowing each candidate to nominate one polling agent is reinstated; names and IDs must be filed within two days of final list publication.

Implementation and Directions

• Q: What immediate steps must AIFF take?
• • A: Convene a Special General Body Meeting and adopt the Constitution as modified by the Supreme Court, preferably within 4 weeks (Article 84 mechanism invoked by the Court’s concluding directions).

Policy Rationale and Broader Observations

• Q: What constitutional and policy values did the Court emphasize?
• • A: Fraternity, inclusivity, accessibility, and equitable distribution of sporting resources; professional, efficient, transparent governance; and minimizing concentration of sports opportunities among urban elites.
• Q: Why insist on promotion & relegation and limits on delegation?
• • A: To ensure sporting merit governs competition structure; and that AIFF remains accountable for essential governance functions while welcoming private investment within principled boundaries.