MAHARASHTRA ARCHERY ASSOCIATION versus RAHUL MEHRA AND ORS.

MAHARASHTRA ARCHERY ASSOCIATION versus RAHUL MEHRA AND ORS.

The Administrator of the Archery Association of India acted beyond the authority granted by Supreme Court's order dated 4th December, 2017 by unilaterally amending the Constitution and conducting subsequent elections. Only four amendments approved by the Supreme Court were permissible. All steps taken beyond the scope of the authority are non est in law, and elections conducted on the basis of the amended Constitution are null and void. The Constitution should only be amended further by the elected body and in accordance with the law after proper stakeholder consultation.

Parties
Appellant: Maharashtra Archery Association; Respondents: Rahul Mehra and Ors.
Jurisdiction
India
Judgment Date
01 May 2019
Procedural Posture
Civil Appeal / Appeal From High Court Interim Order and Writ Petition Proceedings
Outcome
Appeals allowed; steps by Administrator declared null and void; parties relegated to pre-4 December 2017 position; fresh elections ordered
Legal Topics
Right to Association, Governance of Sports Bodies, Election and Constitution Amendment Process, National Sports Code Compliance
Sports Law Constitutional Law Right to Association Governance of Sports Bodies Election and Constitution Amendment Process National Sports Code Compliance

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Parties

Maharashtra Archery Association

Appellant

Rahul Mehra and Ors.

Respondents

Procedural Posture

Civil Appeal / Appeal From High Court Interim Order and Writ Petition Proceedings

Legal Issues

  1. 1 Whether Administrator had authority to amend Constitution of Archery Association of India beyond Supreme Court's directive
  2. 2 Validity of Administrator's unilateral amendments and elections
  3. 3 Proper procedure for constitutional amendments and conducting elections in sports federations

Ratio Decidendi

The Administrator of the Archery Association of India acted beyond the authority granted by Supreme Court's order dated 4th December, 2017 by unilaterally amending the Constitution and conducting subsequent elections. Only four amendments approved by the Supreme Court were permissible. All steps taken beyond the scope of the authority are non est in law, and elections conducted on the basis of the amended Constitution are null and void. The Constitution should only be amended further by the elected body and in accordance with the law after proper stakeholder consultation.

Court Disposition

Appeals allowed; steps by Administrator declared null and void; parties relegated to pre-4 December 2017 position; fresh elections ordered

Orders

  • The Constitution of Archery Association of India stands amended only to the extent of four amendments approved by Supreme Court's order dated 4 December 2017.
  • All steps and elections conducted based on further amendments by Administrator are null and void.