Summary and Analysis of Santhosh Karunakaran vs. Ombudsman cum Ethics Officer, Kerala Cricket Association

1. Heading of the Judgment

Case Name: Santhosh Karunakaran vs. Ombudsman cum Ethics Officer, Kerala Cricket Association & Another
Court: Supreme Court of India
Judgment Date: 29th July 2025
Case No.: Civil Appeal No(s). ____ of 2025 (Arising out of SLP (Civil) No. 12903 of 2021)
Judges: Vikram Nath & Sandeep Mehta, JJ.

2. Related Laws and Sections

• Byelaws of Kerala Cricket Association (KCA): Section 15(4)(s) (pertaining to disciplinary action against members).

• Jurisdiction of Ombudsman-cum-Ethics Officer: Functioning as a persona designata (a designated authority, not a court of record).

• Principles of Natural Justice: Right to fair hearing, transparency in proceedings, and access to case records.

3. Basic Judgment Details

• Appellant: Santhosh Karunakaran (former Ranji Trophy player and member of Thiruvananthapuram District Cricket Association).

• Respondents:
  Ombudsman-cum-Ethics Officer, Kerala Cricket Association (KCA).
  Kerala Cricket Association (KCA).

• Key Issue: Whether the proceedings before the Ombudsman were transparent and whether the appellant was denied a fair opportunity to present his case.

• Outcome: Supreme Court set aside the orders of the Ombudsman and High Court, quashed the blacklisting of the appellant, and directed fresh proceedings.

4. Explanation of the Judgment

Background of the Case

• The appellant, Santhosh Karunakaran, filed an application before the Ombudsman of KCA seeking:
  Framing of uniform bylaws for district cricket associations as per Lodha Committee recommendations.
  Implementation of these bylaws across all districts under KCA.
  Conducting fair elections in KCA with proper district representation.

• The Ombudsman rejected his application, stating that the appellant failed to implead District Cricket Associations (DCAs) despite prior directions.

• The High Court upheld this rejection, leading the KCA to blacklist the appellant and impose a life ban on him.

Appellant’s Grievances

1. Lack of Transparency:
   The appellant claimed he was unaware of the Ombudsman’s orders directing him to implead DCAs.
   His requests for case records were denied on the grounds that the Ombudsman is not a court of record.

2. Procedural Unfairness:
   Virtual hearings were frequently disrupted, preventing proper representation.
   The Ombudsman’s earlier order (2nd August 2019) suggested that impleading DCAs was unnecessary, creating confusion.

Supreme Court’s Observations

• The High Court took an excessively harsh view by dismissing the appellant’s petition on grounds of "unclean hands" without considering procedural lapses.

• The appellant’s application was not adversarial in nature (i.e., not a dispute against any party) but rather a request for systemic reforms.

• Denial of records and lack of fair hearing violated principles of natural justice.

Final Decision

1. Quashing of Orders:
   The Supreme Court set aside:
   Ombudsman’s order (3rd October 2020).
   High Court’s judgments (27th January 2021 & 21st June 2021).
   KCA’s blacklisting order (22nd August 2021).

2. Revival of Proceedings:
   Original Application No. 10 of 2019 was restored.
   The Ombudsman must rehear the case, provide all parties a fair opportunity, and pass a reasoned order within three months.

Significance of the Judgment

• Emphasizes the importance of transparency and fair procedure in quasi-judicial proceedings.

• Reinforces that disciplinary actions (like blacklisting) must follow due process.

• Ensures that even non-adversarial applications (like policy reforms) must be heard fairly.

Conclusion

The Supreme Court ruled in favor of the appellant, holding that the proceedings before the Ombudsman and the subsequent disciplinary action by KCA were unjust. The case will now be reconsidered afresh, ensuring fairness and adherence to legal principles.