In a writ petition filed before the Delhi High Court by Kamlesh Mehta, an illustrious veteran of Indian table tennis, to assail an order dated 28-01-2026 of the executive committee of the Table Tennis Federation of India (TTFI), whereby he was declared a persona non grata and was suspended from the post of Secretary General, TTFI, till the outcome of the inquiry was pending, a Single Judge Bench of Justice Purushaindra Kumar Kaurav set aside the impugned order and appointed an Enquiry Authority.
After directions were issued in Manika Batra v. TTFI & Ors. (W.P.(C) No. 10590/2021), fresh elections to the executive committee were held on 05-12-2022, and Kamlesh Mehta was elected as the Secretary General of TTFI. On 06-01-2026, the President issued an Executive Committee Meeting (ECM)/Annual General Meeting (AGM) notice and scheduled it for 28-01-2026. The notice stated that it was issued due to the petitioner’s non-cooperation. Thereafter, 17 State member associations of TTFI requested the petitioner to requisition a Special General Meeting (SGM), citing issues with the agenda items circulated in the said notice, and the SGM was scheduled for 17-01-2026.
It was unanimously resolved at the SGM that the said notice was invalid and that certain agenda items contained therein were discriminatory against the North Eastern States. The minutes of the meeting were circulated on 28-01-2026. On 28-01-2026, the impugned order was passed, and Kamlesh Mehta was suspended from his post, pending the outcome of the inquiry to be conducted by the enquiry committee. Hence, the present petition was filed.
The Court referred to Rahul Mehra v. Union of India, 2022 SCC OnLine Del 2438, and deemed it appropriate to delve into the present dispute while exercising writ jurisdiction. It was stated that the sunrays that purify the functioning of National Sports Federations are those of a Constitutional Court rather than those of a private adjudicatory mechanism such as arbitration.
The Court noted that the question was not whether the impugned order was passed after affording adequate hearing to the petitioner, but rather concerned the complete absence of the principles of natural justice and the complete lack of an opportunity of hearing. It was stated that an opportunity to be heard cannot be denied on mere grounds that the impugned order ‘merely’ directs the suspension of the petitioner. The Court said that while determining whether principles of natural justice are to be adhered to while passing an order declaring a person as persona non grata under Clause 11(d) of the MoA, it must be considered that the petitioner was an office bearer elected to the Executive Committee for 4 years.
The Court noted that the suspension, effected through the impugned order, caused deprivation, not merely to the duly elected Secretary General but also to the constituents whom he represented in the TTFI. It was said that upon the suspension of a democratically elected individual, a shadow is cast on the constituents’ right to be represented and stated that it could not be held that the principles of natural justice can be given a go by and that a person can be, unilaterally, put under suspension.
The Court perused Clause 11 of the MoA and found it to be guilty for not having a rational nexus between the differential treatment of individuals and the object sought to be achieved by the Clause. It was held that this provision would, ex facie, fall ill of Article 14 of the Constitution. Further, the Court said that owing to the petitioner’s suspension affecting his right to elected office, due to lack of express words excluding application of principles of natural justice, and because the non-application of the principles would result in differential treatment, the principles of natural hearing was to be read into Clause 11(d) of the MoA.
Referring to Mohinder Singh Gill v. Chief Election Commissioner 1978 AIR 851, the Court said that TTFI could not supplement and add to the reasons as to why a hearing was not granted to the petitioner before the passing of the impugned order. Hence, since the impugned order did not adhere to even the most basic, rudimentary, and elemental principles of natural justice, the Court held that the same deserved to be set aside.
The Court said that the relatively ‘emergent’ events concerned the SGM dated 17-01-2026 and the petitioner’s involvement in the deliberations on certain agenda items, which were ridden with a purported conflict of interest. However, it was stated that it would be unfair and impermissible to hang the SGM’s outcome on the petitioner’s neck and claim that all that happened was because of the petitioner’s acts. It was noted that the condition that 1/3rd of the associations in membership with the Federation ought to request the SGM was complied with.
Thus, the Court held that granting notice to the petitioner and a consequent hearing would not frustrate or defeat the purpose of the action contemplated against the petitioner, and that no irreversible consequences would have fallen upon TTFI had the petitioner been granted an opportunity of hearing.
Further, the Court held that two high-ranking officials – the President and the Secretary General of TTFI were facing serious allegations which would raise questions as to whether they could act in the best interest of the development, promotion, and management of Table Tennis. The Court said that it could not shut its eyes to allegations made by two of the highest officers of a National Sports Federation against each other, and that even though the impugned order was set aside, the seriousness of the allegations could not be ignored. Hence, the Court appointed Justice (Retd.) Krishna Murari, Former Judge, Supreme Court of India, as the enquiry authority to inquire into the conduct and functioning of TTFI.
The Court held that any further action against the office bearers, including the petitioner, would be taken by and subject to the action and inquiry by the Enquiry Authority, which would be entitled to decide its remuneration to be borne by TTFI. Thus, the petition was disposed of.
Appearances:
For Petitioner – Mr. Abhishek Malhotra (Sr. Adv), Mr. Abhishek Bharti, Ms. Aahna Mehrotra, Mr. Kartikay Dutta, Mr. Shivansh Soni, Ms. Anukriti
For Respondents – Mr. Rahul Mehra (Sr. Adv), Mr. Avi Singh (Sr. Adv), Mr. Udit Dedhiya (SPC), Mr. Akshit Mohan (GP), Mr. Parth Goswami, Mr. Chaitnya Gossain, Mr. Ranjeet Pawar, Mr. Hanif Chimthanawala, Mr. Ayush Yadav, Ms. Apurva Sachdev, Mr. Preyansh Gupta, Ms. Aashita Khanna, Ms. Aanya Agarwal
