Sports Ministry Cannot Act As Rubber Stamp: Delhi High Court Quashes NSF Recognition Granted To Body Picked By International Taekwondo Federation
Safiya Malik
The High Court of Delhi Single Bench of Justice Sachin Datta set aside the Government’s order granting recognition to a parallel body as the National Sports Federation for Taekwondo and directed the Union Sports Ministry to reassess the matter after hearing all stakeholders. The Court noted that the Ministry cannot function as a mere rubber stamp to confer recognition on an entity effectively handpicked by an international federation, particularly when the previously recognised body had not been suspended or de-recognised in accordance with the Sports Code. The dispute centered on competing claims over governing the sport and the legality of recognition based solely on international affiliation. The Court directed that a reasoned, code-compliant decision be taken, with the existing federation continuing in the interim.
The matter arises from a challenge to a communication issued by the Union Sports Ministry granting recognition to a separate body as the National Sports Federation (NSF) for Taekwondo. The petitioner, already recognised as the NSF pursuant to elections supervised under court directions, asserted that this new recognition was granted while its own status had neither been suspended nor withdrawn. The Ministry’s earlier letter had recorded the petitioner’s elected office-bearers and directed it to obtain affiliation from the international and national Olympic bodies.
The dispute traces back to factional issues within the petitioner federation, which had led to court-mandated elections. During this period, an ad-hoc committee formed by the national Olympic authority to manage the sport allegedly facilitated the creation of another entity, which later obtained affiliation from the international and continental Taekwondo bodies. Evidence placed on record included communications from these international bodies, internal correspondence of the national Olympic authority, and findings of its Ethics Commission concerning conflict-of-interest issues within the ad-hoc committee.
The respondents contended that the petitioner had not secured international affiliation, had failed to furnish required documents for annual renewal under the Sports Code, and therefore lacked continued recognition. They relied on correspondence indicating non-submission of documents and the petitioner’s suspension by the international federation. The petitioner countered that no notice of suspension or withdrawal was issued as required under the Sports Code, which mandates procedural safeguards before altering NSF status.
The Court observed that “for an inordinately long period, the sport of Taekwondo has remained in a state of turmoil in India” and recounted the chain of events beginning with IOA’s constitution of an ad-hoc committee in 2019. It recorded that in earlier proceedings, “this Court… took note of the fact that the respondent no.3 had not been recognised as the NSF for the sport of Taekwondo” even though TFI was suspended by the world federation in 2019.
The Court noted that MYAS had taken a “conscious call” in its letter dated 17.03.2023 to approve court-supervised elections and recognise TFI as the NSF. It recorded that the respondents’ claim of non-renewal of recognition in 2024 was “neither borne out from the records… nor from the provisions/requirements of the Sports Code.” It stated that earlier orders of the Court dated 24.12.2024 and 13.01.2025 “belie the stand now sought to be taken… that the petitioner’s status as NSF was not renewed.”
The Court discussed the Sports Code provisions on recognition, noting that while Clause 8.2 provides for automatic renewal subject to submissions, paragraph 8.5 and Annexure III make clear that suspension, non-renewal, or withdrawal must follow procedural safeguards. It stated: “any suspension or ‘non-renewal’ or withdrawal of recognition… must be predicated on adherence to procedural safeguards as contemplated under Annexure III.”
The Court recorded that “neither a specific notice appears to have been given to the petitioner… nor has any order been issued… purporting to suspend/withdraw the recognition.” Instead, MYAS had directly recognised respondent no.3, which the Court found “clearly incongruous” because Clause 3.10 mandates that “there will be only one recognised federation for each discipline of sport.”
It observed that serious allegations surrounded the incorporation of respondent no.3 and that “records of the case do not reveal that the aforesaid relevant circumstances were considered” by MYAS. The Court stated that “recognition of an NSF cannot be at the dictates/whims/directives of any International Federation” and that MYAS is “not expected to act as a mere ‘rubber stamp’ and grant recognition to whichever body/entity is handpicked” by the international federation.
The Court referred to precedent holding that adherence to the Sports Code is part of the law of the land, noting that governmental action to enforce it cannot be construed as interference. It reiterated that sports governance must adhere to good governance practices, including transparency, representativeness, and compliance with the legal framework.
The Court set aside the communication dated 08.05.2025. It directed that the Union of India “reconsider the matter as regards recognition of a suitable body to act as the NSF for the sport of Taekwondo in the country, after affording an opportunity of hearing all the stakeholders including the petitioner and the respondent no.3 and thereafter take an appropriate decision by issuing a reasoned order, in consonance with the Sports Code and good governance practices.”
“Till the aforesaid exercise is completed… the petitioner shall continue to act as the NSF in respect of the sport of Taekwondo in India.” It disposed of the petition in these terms, along with all pending applications.
Advocates Representing The Parties
For the Petitioner: Mr. Rahul Mehra, Senior Advocate; Mr. Saurabh Jain, Mr. Chaitanya Gosain, Mr. Prayag Jain, Mr. Shahid Ali, Mr. Mohd. Salman, Mr. Sameer Tayyeb, Advocates.
For the Respondents: Mr. Udit Dedhiya (SPC); Mr. Apurva Sachdev, Ms. Vidhi (GP), Mr. Preyansh Gupta, Mr. Vikash Singh, Mr. Ujjwal Chaudhary, Mr. Darpan Wadhwa, Senior Advocate; Mr. Sanjeev Mahajan, Mr. Parth Goswami, Mr. R.A. Iyer, Mr. Ayush Yadav.
Case Title: Taekwondo Federation of India v. Union of India & Ors.
Neutral Citation: 2025: DHC:10148
Case Number: W.P.(C) 7029/2025
Bench: Justice Sachin Datta
