District Cricket Associations Not Required To Replicate BCCI Constitution; Judicial Review Cannot Enforce Such Reform: Supreme Court

While recognising the importance of institutional reform, the Court clarified that such improvements must arise through appropriate regulatory or administrative action rather than court-imposed structural prescriptions.

The Court was hearing civil appeals challenging directions of the Madurai Bench of the Madras High Court that required a district cricket association to align its constitutional framework with governance reforms flowing from earlier sports-related judgments.

A Bench of Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe examined the scope of prior jurisprudence governing cricket administration and observed that “…no judgment or document has been brought on record to demonstrate any understanding across the cricketing associations at the District Level to make their Constitution on exact lines as of the BCCI, nor any judgment which directs such a prescription”.

The Bench further underscored that “…though enforcement of such a reform as contemplated in the BCCI judgment cannot be done through judicial review, we must clarify that it is open, rather necessary, for the State Association to initiate reforms to ensure that District Associations operate as professional, transparent, and in the best interests of the sport”.

Background

The litigation arose from writ proceedings concerning the internal governance of a district cricket association affiliated with a state cricket body. A member club sought recognition of its voting and participation rights in the association’s affairs, alleging irregularities in membership administration and election processes.

While adjudicating these disputes, the High Court examined the structure of the association and expressed concern over the absence of codified governance safeguards. Relying primarily on the judgment in S. Nithya v. Union of India, which dealt with structural reforms in athletics federations, the High Court directed the district cricket association to remodel its constitution to reflect principles of transparency, age and tenure restrictions, and organisational uniformity.

The district association challenged this direction before the Supreme Court, arguing that cricket governance is governed by a distinct jurisprudential framework laid down in Board of Control for Cricket in India v. Cricket Association of Bihar and related decisions. It was contended that the BCCI judgments did not mandate district associations to replicate the BCCI Constitution, and that the High Court erred in importing governance prescriptions from athletics litigation into cricket administration.

Court’s Observation

The Supreme Court first examined the legal foundation of the High Court’s reliance on S. Nithya, noting that the judgment arose in the context of governance deficiencies within athletics federations and was tailored to that specific regulatory environment.

The Bench observed that the directions issued in that case were not framed as universal prescriptions applicable to all sports associations. Mechanical transplantation of those reforms into cricket administration, without examining the distinct jurisprudence governing cricket bodies, amounted to an overextension of judicial precedent.

Turning to cricket governance, the Court analysed the ratio of BCCI v. Cricket Association of Bihar and subsequent decisions that addressed institutional reform within cricket administration. The Bench clarified that the BCCI judgments were directed primarily at ensuring compliance by the national body and affiliated state associations with principles of accountability and transparency. Those rulings did not prescribe that district associations must adopt constitutional structures identical to those of the BCCI.

The Court emphasised that the appellant’s plea, that the BCCI judgment itself did not require district-level replication, was consistent with the ratio of that decision. No material was placed before the Court to demonstrate any binding directive, statutory framework, or settled practice mandating district cricket associations to structure their bye-laws on exact BCCI lines.

Addressing the scope of judicial review, the Bench reiterated that courts may intervene to correct illegality, arbitrariness, or procedural unfairness, but cannot impose structural uniformity absent statutory authority. Judicial review is not a vehicle for prescribing governance models where the legislature or regulatory framework has not mandated such conformity.

At the same time, the Court underscored that the autonomy of sports bodies is accompanied by an expectation of institutional responsibility. While courts cannot compel constitutional restructuring, state cricket associations remain free and indeed encouraged to initiate reforms.

Finally, the Bench clarified that disputes concerning membership rights and election processes, which formed the original basis of the writ petitions, remain justiciable before competent authorities. Those matters must be adjudicated independently of any assumption that district associations are bound to replicate the BCCI Constitution.

Conclusion

Holding that the High Court exceeded its jurisdiction in directing the district cricket association to remodel its constitution on BCCI lines, the Supreme Court set aside those directions.

The appeals were allowed to that extent, with pending disputes concerning internal governance left to be resolved in accordance with the law.

Cause Title: The Tiruchirappalli District Cricket Association v. Anna Nagar Cricket Club & Anr. (Neutral Citation: 2026 INSC 154)

Appearances

Appellant: Amol Chitale, Advocate; Pragya Baghel, AOR; Shweta Singh Parihar and Sarthak Sharma, Advocates.

Respondents: Mayank Mishra, Advocate; Raghav Sabharwal, AOR; Kunwar Surya Pratap, Harsh Vardhan Singh and Akshaj Chaturvedi, Advocates, With Advocate V. C. Shukla (Amicus Curiae)

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