Supreme Court defers decision on Hyderabad Cricket Association Constitution: Hyderabad Cricket Association vs. Charminar Cricket Club (2025) INSC 23

Introduction

Date of the Judgment: January 03, 2025
Citation: 2025 INSC 23
Judges: Justice Vikram Nath and Justice Satish Chandra Sharma

Can the internal rules of a cricket association conflict with the broader guidelines set by the Board of Control for Cricket in India (BCCI)? The Supreme Court of India recently grappled with this question in a case involving the Hyderabad Cricket Association. The core issue revolves around whether the recommendations made by a committee regarding the Hyderabad Cricket Association’s constitution should be implemented, especially when concerns arise about potential conflicts with BCCI regulations. The bench comprised of Justice Vikram Nath and Justice Satish Chandra Sharma.

Case Background

The case began with a suit filed by M/s Budding Star Cricket Club (Respondent No. 2) in the Civil Court, registered as PSROP No. 17 of 2020. The club sought a declaration that the appointment of the Ombudsman and Ethics Officer by the Apex Council of the Hyderabad Cricket Association was not in line with the association’s constitution. In this suit, an application (I.A. No. 674 of 2020) was filed, and the Civil Court suspended the Apex Council’s decision regarding the Ombudsman and Ethics Officer until the suit’s resolution. This order was challenged in the High Court.

The High Court for the State of Telangana at Hyderabad overturned the Civil Court’s decision in Civil Revision Petition No. 117 of 2021, dismissing the suit and the application with costs of Rs. 25,000. This led to the filing of the present Special Leave Petitions before the Supreme Court. Over time, the scope of these petitions expanded significantly. The Supreme Court appointed a Supervisory Committee, which was later replaced by a Single Member Committee to conduct elections for the Hyderabad Cricket Association. The Single Member Committee also made recommendations for changes to the association’s constitution. These recommendations faced objections, leading to the present proceedings.

Timeline:

Course of Proceedings

The High Court for the State of Telangana at Hyderabad, in Civil Revision Petition No. 117 of 2021, overturned the Civil Court’s order that had suspended the appointment of the Ombudsman and Ethics Officer. The High Court also dismissed the original suit filed by M/s Budding Star Cricket Club. Subsequently, the matter reached the Supreme Court through Special Leave Petitions. Initially, the Supreme Court appointed a Supervisory Committee, but later, a Single Member Committee was tasked with conducting elections and recommending changes to the Hyderabad Cricket Association’s constitution. The Single Member Committee’s report and recommendations were then challenged with objections from various parties. During the proceedings, it was brought to the Court’s attention that Civil Appeal No. 4235 of 2014, pending before another bench, involves similar issues related to the BCCI’s constitution and its impact on state cricket associations. This led to the Supreme Court’s decision to tag the present matter with the pending Civil Appeal.

Legal Framework

The core legal issue revolves around the constitution of the Hyderabad Cricket Association and whether it should align with the constitution and guidelines of the Board of Control for Cricket in India (BCCI). The judgment refers to the directions passed in Civil Appeal No. 4235 of 2014, which mandates that all State Cricket Associations should have their constitutions in line with the BCCI’s constitution. The case also touches upon the powers of the court to oversee and direct the functioning of sports associations to ensure fair and transparent governance.

Arguments

Mr. Avishkar Singhvi, representing the elected office bearers of the Hyderabad Cricket Association, argued that the recommendations made by the Single Member Committee might conflict with the constitution of the BCCI. He pointed out that Civil Appeal No. 4235 of 2014, which is pending before another bench of the Supreme Court, deals with the broader issue of the BCCI’s constitution and its applicability to state cricket associations. He submitted that if the Hyderabad Cricket Association adopts the recommendations, it could lead to a direct conflict with the directions issued in the said appeal. Therefore, he requested that the present matter be heard along with Civil Appeal No. 4235 of 2014 to avoid conflicting views and orders.

Some counsels for the intervenors supported Mr. Singhvi’s submissions, while others opposed, arguing that the present matter could proceed independently without any conflict with the judgment and directions in Civil Appeal No. 4235 of 2014.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues in this order. However, the primary concern that emerged was whether the recommendations made by the Single Member Committee for the Hyderabad Cricket Association’s constitution were in conflict with the constitution, regulations, and guidelines of the BCCI, especially considering the directions passed in Civil Appeal No. 4235 of 2014.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following:

• Civil Appeal No. 4235 of 2014 – This case deals with the broader issue of the constitution of the Board of Control for Cricket in India (BCCI) and its impact on state cricket associations. The Supreme Court noted that there are directions in this appeal that all State Cricket Associations would have their constitution in line with the constitution of the BCCI.

Judgment

The court did not make a final judgment on the merits of the case. Instead, it focused on the procedural aspect of ensuring that the matter is heard by the same bench that is dealing with the related Civil Appeal No. 4235 of 2014. The court noted the potential conflict between the recommendations of the Single Member Committee and the directions in the pending Civil Appeal. Therefore, the court directed that the matter be tagged with Civil Appeal No. 4235 of 2014.

What weighed in the mind of the Court?

The primary concern that weighed in the mind of the Court was the potential for conflicting orders and the need to maintain uniformity in the constitutions of cricket associations, particularly with respect to the BCCI’s guidelines. The Court was also concerned about the directions passed in Civil Appeal No. 4235 of 2014, which mandates that all State Cricket Associations should align their constitutions with that of the BCCI. The Court’s decision to tag the matter with Civil Appeal No. 4235 of 2014 reflects its emphasis on judicial efficiency and the need to avoid contradictory rulings.

The court’s reasoning was primarily driven by the procedural aspect of ensuring that the matter is heard by the same bench that is dealing with the related Civil Appeal No. 4235 of 2014. This was to prevent any conflicting views and orders. The court also considered the need for uniformity in the regulations, constitutions, and guidelines of the BCCI and the State Cricket Associations, as per the judgment and directions passed in Civil Appeal No. 4235 of 2014.

The court did not delve into the merits of the recommendations made by the Single Member Committee. Instead, it focused on the procedural aspect of ensuring that the matter is heard by the same bench that is dealing with the related Civil Appeal No. 4235 of 2014. This approach was taken to prevent any conflicting views and orders and to ensure uniformity in the regulations, constitutions, and guidelines of the BCCI and the State Cricket Associations.

The court considered the arguments of the parties and the potential implications of the recommendations made by the Single Member Committee. However, the court did not express any opinion on the merits of those recommendations. The court’s decision was based on the need to maintain judicial consistency and to ensure that all State Cricket Associations adhere to the directions passed in Civil Appeal No. 4235 of 2014.

“Having given our anxious consideration and without going into the merits of the matter s, once the issue is raised that the recommendations made by the Single Member Committee which are to be approved/ disapproved in the present case, may be in conflict or not in consonance with the Constitution, Regulations and Guidelines of the BCCI , it would only be appropriate that these matters may be tagged with Civil Appeal No.4235 of 2014 and heard by the same bench.”

Key Takeaways

• The Supreme Court has prioritized the need for uniformity in the constitutions of State Cricket Associations with the BCCI’s constitution.
• The court has deferred the decision on the recommendations of the Single Member Committee for the Hyderabad Cricket Association, pending a hearing with a related civil appeal.
• This decision highlights the importance of avoiding conflicting orders and ensuring consistency in the application of legal principles.
• The case underscores the Supreme Court’s role in overseeing the governance of sports associations to ensure transparency and fairness.

Directions

The Supreme Court directed the Registry to place the papers before the Hon’ble Chief Justice of India for passing appropriate orders to tag the matter with Civil Appeal No. 4235 of 2014.

Specific Amendments Analysis

There is no specific amendment analysis in this judgment.

Development of Law

The ratio decidendi of this case is that matters concerning the constitution of state cricket associations, particularly when they involve potential conflicts with the BCCI’s constitution and guidelines, should be heard together with cases that directly address the BCCI’s constitution. This is to ensure uniformity and avoid conflicting orders, especially when there are existing directions from the Supreme Court on the matter. This case does not change any previous positions of law, but rather reinforces the need for consistency in the application of existing legal principles.

Conclusion

In conclusion, the Supreme Court did not make a final decision on the merits of the case regarding the Hyderabad Cricket Association’s constitution. Instead, it deferred the matter to be heard along with Civil Appeal No. 4235 of 2014, which deals with the broader issue of the BCCI’s constitution. The Court’s decision was driven by the need to avoid conflicting orders and ensure that all State Cricket Associations adhere to the directions passed in the related civil appeal. This highlights the Court’s emphasis on maintaining uniformity and consistency in the governance of cricket associations in India.