Derecognition Cannot Be Automatic: Delhi High Court Sets Aside Order Restraining All India Carrom Federation from Using 'India' in Its Name
Intra-court appeals were filed by the All India Carrom Federation (AICF) and two State associations against a Single Judge's order which had directed AICF to delete the word "India" from its name until it secured fresh recognition.
Chief Justice Devendra Kumar Upadhyaya, Justice Tejas Karia, Delhi High Court
The Delhi High Court has held that a National Sports Federation cannot be treated as de-recognised, and consequently restrained from using the expressions "India" or "Indian" in its name, merely because its annual recognition has not been renewed by the Union Government. The Court ruled that suspension or withdrawal of recognition can occur only through a positive act taken after affording the federation an opportunity of hearing, in accordance with the procedure prescribed under the National Sports Development Code of India, 2011, and cannot be inferred automatically from non-renewal.
The judgment came in intra-court appeals filed by the All India Carrom Federation (AICF) and two State associations against a Single Judge's order which had directed AICF to delete the word "India" from its name until it secured fresh recognition, on the ground that its recognition had lapsed following disputes over its 2023 elections.
A Division Bench comprising the Chief Justice D.K. Upadhyaya and Justice Tejas Karia observed, “…in the absence of a notice, opportunity of hearing, reasoned determination and consequential order passed in accordance with the prescribed procedure, there can be no automatic or deemed withdrawal or de-recognition of AICF as an NSF, as held in Taekwondo Federation (supra) on the basis of letter dated 07.12.2020”.
Udit Dedhiya, SPC, Advocate Aseem Mehrotra appeared for the respondents.
AICF, affiliated with the International Carrom Federation since 1988, had its recognition renewals repeatedly contested by the Ministry of Youth Affairs and Sports on grounds including violation of the "One State One Unit" principle, given two competing Maharashtra units, and irregularities in its 2015, 2018 and 2023 elections. The Ministry's letter of December 07, 2020 flagged these violations without formally suspending or withdrawing recognition. The Single Judge, before whom writ petitions by Maharashtra Carrom Association, Pondicherry Carrom Association and an individual were pending, disposed of them by directing AICF to rename itself, sending national teams only as a "Team from
AICF's appeal, along with connected appeals by the State associations challenging aspects of the same order, came up before the Division Bench. During the pendency of the appeals, the Ministry, acting pursuant to the Court's interim directions, passed successive orders on February 06, 2026 and July 10, 2026 declining to accept AICF's 2023 election, the latter order being separately challenged in a pending writ petition before the Single Judge.
Relying on its own earlier decision in Union of India v. Taekwondo Federation of India & Anr. LPA 5/2026, the Bench reiterated that, “AICF has relied on the decision of this Bench in Taekwondo Federation (supra), wherein it was held that withdrawal of recognition or derecognition of an NSF can take place only by a positive act, after affording the concerned NSF an opportunity of hearing, and cannot occur automatically. The said requirement was held to flow from the principles of natural justice governing administrative action by a public authority or body”.
The Court clarified that AICF must still comply with the National Sports Governance Act, 2025 and Rules framed thereunder to seek recognition afresh, and that the legality of the Ministry's subsequent order dated July 10, 2026 would be independently examined in the pending writ petition before the Single Judge. No order as to costs was made.
Cause Title: All India Carrom Federation v. Union of India & Anr. (Neutral Citation: 2026:DHC:7411-DB)
Appearances:
Appellant: None.
Respondent: Udit Dedhiya, SPC, Rajat Mohan Dwivedi, G.P., Apurva Sachdev, Preyansh Gupta, Shivam Dubey, Yash Singh, Aseem Mehrotra, Deeksha Mehrotra, Advocates.