District Cricket Associations Must Voluntarily Adopt Good Governance; Not Bound To Align Bye-Laws With BCCI Constitution: Supreme Court
Kiran Raj
The Supreme Court Division Bench of Justices P.S. Narasimha and Alok Aradhe on Friday (February 13) partly allowed an appeal by a district cricket association, setting aside a High Court order that had extended athletics-governance directions to its functioning. The Court asked the High Court to decide the pending writ appeals quickly so related inquiries can conclude and elections are held. It recorded that a member club may vote and that upcoming elections may be overseen, but said courts cannot require district bodies to align their bye-laws with the BCCI constitution. Still, it said it is open, and necessary, for the state association to initiate reforms, and encouraged district units to voluntarily adopt good-governance measures, including transparency in player selection, professional administration, and exclusion of conflicts of interest.
The appellant, a district cricket association registered under the Tamil Nadu Societies Registration Act, challenged a common judgment of the Madras High Court which had applied directions issued in S. Nithya to its functioning. The dispute arose from two writ appeals. In the first, a cricket club sought membership, voting rights, and permission to participate in a tournament. The association informed the court that participation had already been permitted. The High Court, however, upheld the club’s right to membership and voting.
In the second matter, an ex-office bearer sought directions for conducting free and fair elections after preparation of a fresh voters’ list and alleged non-compliance with directions issued in S. Nithya, including requirements relating to the presence of eminent sportspersons and constitutional amendments. The High Court allowed these prayers. The association contended before the Supreme Court that the directions in S. Nithya were inapplicable to cricket associations governed by the framework in BCCI v. Cricket Association of Bihar, and further argued that there was no mandate requiring district associations to adopt the BCCI Constitution.
On the applicability of S. Nithya, the Court observed that “the petition in S. Nithya (supra) was only concerned with reforms in athletics governance and championships.” It noted that when that judgment 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.” The Bench recorded that “There being no prescription or direction in the BCCI 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.”
While considering the argument that district associations must amend their constitutions in line with BCCI, the Court referred to the extract in BCCI and recorded: “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).” It further recorded: “Composition of the State Cricket Associations remain unaffected, and so does the right of those forming such associations under Article 19(1)(c).”
The Court stated that “the judgment in BCCI does not warrant District Associations to model their regulations and bye-laws on exact lines of the BCCI Constitution.” It clarified that “the argument that the appellant must be asked to restructure its functioning and laws in terms of the BCCI Constitution cannot be accepted.”
On governance standards, the Court observed: “District Associations must volunteer to adopt reformative measures such as good governance, refined management, transparency, and the exclusion of conflicts of interest.” It recorded that “sporting ‘facilities and opportunities’ are ‘material resources of the community’, and their organizers are ‘the institutions of the national life’.” The Bench added that “As ‘places of public resort’, sporting institutions and bodies must remain accessible, not just for pursuing sport, but also for its administration.”
The Court having held that “the directions in S. Nithya (supra) would not be applicable to the fact of the present case concerning sport of cricket” and that “the argument that the appellant must be asked to restructure its functioning and laws in terms of the BCCI Constitution cannot be accepted. In this view, we allow the appeal in part, set aside the judgment and order of the High Court to the extent indicated hereinabove.”
“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. The appeal(s) are disposed of accordingly. Pending applications, if any, also stand disposed of.”
Advocates Representing the Parties:
For the Petitioners: Mr. Amol Chitale, Adv. Mrs. Pragya Baghel, AOR Ms. Shweta Singh Parihar, Adv. Mr. Sarthak Sharma, Adv.
For the Respondents: Mr. Mayank Mishra, Adv. Mr. Raghav Sabharwal, AOR Mr. Kunwar Surya Pratap, Adv. Mr. Harsh Vardhan Singh, Adv. Mr. Akshaj Chaturvedi, Adv.
Amicus Curiae: Mr. V. C. Shukla, Adv.
Case Title: The Tiruchirappalli District Cricket Association v. Anna Nagar Cricket Club & Anr. Etc.
Neutral Citation: 2026 INSC 154
Case Number: Civil Appeal No(s). of 2026 (Arising out of SLP (C) No(s). 26653-26654 of 2024)
Bench: Justice P.S. Narasimha and Justice Alok Aradhe
