Supreme Court approves reworked AIFF Constitution with player representation, tweaks to disqualification and governance rules

A bench of Justice Pamidighantam Sri Narasimha and Justice Joymalya Bagchi heard the appeals filed by the All India Football Federation (AIFF) challenging the Delhi High Court order of October 31, 2017 that had set aside AIFF’s 2016 election results and appointed an Administrator‑cum‑Returning Officer. The appeals arose from long‑running litigation initiated by Rahul Mehra and others over governance, elections and compliance with the National Sports Development Code (NSC) and related norms.

The Court allowed in large measure the draft Constitution prepared by the Committee of Administrators and refined by Hon’ble Justice L. Nageswara Rao, subject to specific modifications announced in the judgment. It upheld inclusion of “Eminent Players”, coaches, referees and club representatives in the General Body with voting rights, and reduced the eligibility threshold for eminent players to encourage a workable pool (men: 5 international appearances; women: 2). The Court modified proposed disqualification grounds so that criminal disqualification would attach on conviction and sentence (rather than merely on framing of charges), aligned the public‑servant bar to “minister or government servant”, retained the definition of indirect conflicts of interest, and held that State associations must conform to essential provisions of the AIFF Constitution to preserve the pyramid and international recognition. The Court directed that proposed amendments to the AIFF Constitution would not be given effect without leave of the Supreme Court. The Court further clarified the AIFF’s contractual relationship with third parties must respect the Constitution’s “essential aspects” while allowing commercial partnerships within those bounds. The Court, in its reasoning, observed: Background The dispute began with a writ petition by Rahul Mehra in 2010 challenging processes in national sports federations. During pendency, the NSC 2011 was issued. In 2012 the Delhi High Court directed the Union to examine AIFF elections; the Union had cleared the 2012 polls as free and fair. In December 2016 the High Court stayed AIFF elections; it later set aside AIFF’s 2016 election results (paragraph 22), appointed Dr S.Y. Quraishi as Administrator and directed fresh elections after preparation of an Electoral College. The Supreme Court stayed that order on November 10, 2017 and appointed a two‑member Committee of Administrators (Quraishi and Bhaskar Ganguly) to draft a new Constitution in consonance with NSC and Model Guidelines. The CoA was reconstituted in 2022 to include Justice Anil R. Dave and later wound up following elections held to revive AIFF’s functioning amid FIFA suspension in August 2022. The Court then entrusted finalisation to Justice L. N. Rao, who prepared a report and amendments after extensive stakeholder consultations and inputs from amici. After hearings in 2025, the Supreme Court approved the draft with specified changes and directed AIFF to convene a Special General Body meeting and adopt the Constitution with the amendments within four weeks. The Court noted that “the Constitution, once adopted in terms of Article 84, will mark a new beginning for Indian football and take the sport to greater heights.” The Court also clarified the elected Executive Committee would continue to serve its permitted term and that amendments to the Constitution would require the Supreme Court’s leave.

Case Details: Case No.: 2025 INSC 1131 Case Title: All India Football Federation v. Rahul Mehra & Ors. Appearances: For the Petitioner(s): Mr. Ranjit Kumar, Senior Counsel (for AIFF); assisted by other counsel including Mr. K. M. Nataraj, Additional Solicitor General (appearing for Ministry submissions as appropriate) For the Respondent(s): Mr. Rahul Mehra (in person); Dr. Menaka Guruswamy, Senior Counsel (representing State associations/intervenors) Amici/Assisting: Mr. Gopal Sankaranarayanan and Mr. Samar Bansal (Amici Curiae)