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Case Analysis All India Football Federation vs Churchill Brothers & Ors 2026 DHC 3647-DB

Synopsis

Churchill Brothers, a football club, raised grievances against the All India Football Federation (AIFF) regarding certain representations. The AIFF constituted an Ethics Committee under its Constitution to adjudicate the complaints. The club objected to one member, who was subsequently replaced by a retired High Court judge. Despite this, a Single Judge of the High Court, in writ proceedings, reconstituted the Ethics Committee by appointing a former judge of the Delhi High Court as Chairperson, a Senior Advocate, a retired District Judge, and directing two additional members to be added. The AIFF appealed. The Division Bench allowed the appeal, holding that a society registered under the Societies Registration Act is autonomous and its internal affairs, including composition of its judicial bodies, are governed by its own Constitution. The Court interfered only when the existing constitution of the committee already addressed the apprehension and provided appellate remedies, and the Single Judge’s interference was unwarranted.


Court: High Court of Delhi

Coram: Hon’ble the Chief Justice and Hon’ble Mr. Justice Tejas Karia (Division Bench)

Date of Judgment: 28th April 2026

Citation: 2026:DHC:3647-DB (W.P.(C) 3981/2026 & W.P.(C) 4064/2026)

Core Law: Constitutional Law – Article 19(1)(c) (right to form association); Societies Registration Act, 1860 – Autonomy of registered societies; Writ jurisdiction – Scope of interference in internal affairs of autonomous bodies.


1.  Heading of the judgment

High court of delhi

W.p.(c) 3981 of 2026 & w.p.(c) 4064 of 2026

All india football federation (appellant) vs. Churchill brothers & ors (respondents)

Coram: hon’ble the chief justice and hon’ble mr. justice tejas karia (division bench)

Date: 28th april, 2026


2. Legal framework

Major laws and provisions involved:

  • Constitution of india, 1950 – article 19(1)(c) (right to form associations)

  • Societies registration act, 1860 – sections 3, 13, 20

  • National sports development code of india, 2011 / national sports governance act, 2025 – recognition of national sports federations

  • Writ jurisdiction under article 226 – scope of interference in internal affairs of autonomous bodies

Subject matter of the judgment:

Whether a court exercising writ jurisdiction can reconstitute an internal judicial body (Ethics Committee) of a


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