The Delhi High Court has restored All India Carrom Federation’s (AICF) right to use ‘India’ in its nomenclature, while reminding the National Sporting Federation (NSF) that compliance with the National Sports Governance Act, 2025 (NSG Act) and NSG Rules, 2026 remains mandatory for fresh recognition. The principal issue before the Court was whether, in the absence of any order suspending or withdrawing AICF’s recognition under the Sports Code, and in the absence of any statutory provision empowering the Ministry to alter the name of an existing sports federation, the Union of India could direct AICF to remove the words ‘India’ or ‘Indian’ from its name.
The Court held that withdrawal of recognition or de-recognition of an NSF can take place only by a positive act, after affording the concerned NSF an opportunity of hearing, and cannot occur automatically, as the requirement flows from the principles of natural justice governing administrative action. The Court reaffirmed the principle laid down in Union of India v. Taekwondo Federation of India [LPA5/2026] that de-recognition of a National Sports Federation cannot occur automatically upon non-renewal of annual recognition and must follow the prescribed procedure with notice and an opportunity of hearing.
The Ministry’s letter dated Dec 07, 2020, which flagged violation of the One State One Unit principle, was held to be merely an objection and not a valid order of suspension or withdrawal, since it lacked notice, hearing, and a reasoned determination. At the same time, the Court also made clear that AICF’s legal victory on the name issue does not translate into recognition as an NSF, and the federation must independently comply with the NSG Act, 2025 and the NSG Rules, 2026 before seeking fresh recognition.
The Division Bench comprising the Chief Justice Devendra Kumar Upadhyaya and Justice Tejas Karia observed that AICF had been granted annual recognition from 2010 to 2015, after which recognition was not granted in 2016, and only provisional recognition was granted in 2019 and 2020 subject to pending litigation. The Ministry, by letter dated Dec 07, 2020, raised violation of Clause 3.10 of the Sports Code regarding the One State One Unit principle, noting that AICF had two units in Maharashtra. Page 6 Pursuant to the Division Bench’s directions, the Ministry passed order dated 06.02.2026 holding that the 2023-Election was not in accordance with the Sports Code, and thereafter passed a detailed order dated 10.07.2026 after affording AICF an opportunity of hearing. Page 8 The Court noted that the National Sports Governance Act, 2025 (“NSG Act”) was partially notified with effect from 01.01.2026, and the NSG Rules were notified on 12.01.2026, both prescribing mandatory compliance requirements for every NSF. Page 17 The Court placed reliance on its earlier decision in Union of India v. Taekwondo Federation of India, LPA 5/2026, which held that non-renewal of annual recognition does not result in automatic withdrawal or de-recognition, and that suspension or withdrawal can occur only in accordance with Annexure III of the Sports Code after due process.
Briefly, All India Carrom Federation (AICF), a society registered under the Societies Registration Act, 1860, claims to be the National Sporting Federation (NSF) for the sport of Carrom and has been a member of the International Carrom Federation since 1988. AICF held elections on Aug 27, 2023, under the supervision of a former Allahabad High Court Judge as Returning Officer, and the results were declared unanimous.
Multiple petitions were filed before the Delhi High Court by Maharashtra Carrom Association, Union Territory Pondicherry Carrom Association, and one Ravi Kumar, challenging the 2023-Election and seeking directions that AICF be restrained from using the words ‘India’ or ‘Indian’ in its name, logo, or competitions.
The Single Judge, by a common order dated Oct 29, 2025, directed AICF to delete the word ‘India’ from its nomenclature and not use the expressions ‘India’ or ‘Indian’ in any manner, while granting liberty to use ‘Team from India’. AICF, Maharashtra Carrom Association, and Pondicherry Carrom Association filed intra-court appeals against the said Impugned Order.
