The sporting ecosystem in India has undergone a remarkable transformation over the past two decades. What was once largely confined to cricket has now evolved into a rapidly expanding commercial sports industry driven by franchise-based leagues, private investments, media rights, sponsorships, and athlete branding. The success of the Indian Premier League altered the economic landscape of Indian sports, demonstrating the immense commercial potential of professionally managed sporting competitions. This model was subsequently replicated across disciplines through leagues such as the Indian Super League, Pro Kabaddi League, Premier Badminton League, Ultimate Table Tennis, and several emerging franchise-based tournaments across various sports.
This commercialisation has generated complex legal and regulatory relationships involving athletes, franchises, governing federations, sponsors, broadcasters, and agents. As a result, the need for time-sensitive dispute resolution mechanisms has significantly become more pronounced.
However, despite this India continues to lack a dedicated and institutionalised sports dispute resolution framework. Sports related disputes in India are often resolved through internal federation mechanisms, ad hoc committees, civil courts, or writ proceedings before High Court and the Supreme Court, which are frequently criticised for delays, lack of procedural uniformity, limited sporting expertise, and concerns relating to institutional independence.
Sports Arbitration and the Global CAS Model
Sports arbitration refers to a specialised form of dispute resolution designed exclusively for conflicts arising within the sporting ecosystem. It is structured to address disputes that require urgent adjudication, technical sporting expertise, procedural flexibility, and institutional neutrality.
At the international level, the most prominent institution governing sporting disputes is the Court of Arbitration for Sport (“CAS”), headquartered in Lausanne, Switzerland. Established in 1984 under the aegis of the International Olympic Committee, CAS has evolved into the apex dispute resolution body for international sports governance.[1] It functions as an independent arbitral institution responsible for adjudicating disputes involving athletes, sporting federations, anti-doping authorities, clubs and event organisers. Over the years, CAS has developed a substantial body of jurisprudence commonly referred to as lex sportiva, a transnational framework of principles, precedents, and sporting norms that increasingly govern international sports law.
The role of CAS becomes particularly significant during international sporting events such as the Olympic Games, where disputes often require immediate determination. The CAS Ad Hoc Division, constituted specifically for the Olympics, delivers binding decisions within extremely short timelines, sometimes within twenty-four hours.[2] Such mechanisms are essential in preserving fairness, competitive integrity, and athlete rights during major sporting events.[3]
A recent illustration of the importance of specialised sports arbitration emerged in the case involving Indian wrestler Vinesh Phogat during the Paris Olympics. Following her disqualification from the women’s wrestling final on account of an alleged weight violation, Vinesh Phogat challenged the decision before CAS seeking appropriate relief.[4] Regardless of the outcome, the case demonstrated the availability of an independent and specialised international forum capable of urgently adjudicating athlete grievances during a live sporting event.
The situation, however, raises an important institutional question for India. If a similar dispute were to arise exclusively within the domestic sporting framework, India presently lacks a dedicated sports dispute resolution mechanism capable of providing specialised and time-sensitive relief. An athlete in such circumstances would largely be compelled to approach constitutional courts through writ proceedings under Article 226 or institute civil litigation before ordinary courts. While Indian courts undoubtedly possess constitutional authority to review arbitrary or unfair sporting decisions, ordinary judicial processes are often ill-suited for the urgency, technicality, and specialised requirements of sports disputes.
India’s Fragmented Sports Dispute Resolution Framework
The present framework in India remains fragmented, inconsistent, and largely dependent on federation-level internal mechanisms. Most disputes are initially addressed by national sports federations, selection committees, disciplinary bodies, ad hoc panels, or administrative committees created for specific controversies. While such mechanisms may be convenient from an administrative standpoint, they often lack independence, transparency, procedural uniformity, and specialised legal expertise.
The dispute involving P.U. Chitra is perhaps one of the clearest examples of this problem. In 2017, Chitra, a middle-distance runner, approached the Kerala High Court after being excluded from India’s squad for the World Athletics Championships.[5] Reports in 2025 stated that her 2017 case was still pending, even though her last recorded competition was in 2023.[6] This demonstrates why sports disputes cannot be treated as ordinary civil disputes. A long-distance runner’s career is inherently short-lived and performance-dependent. Selection to an international event is not merely a contractual or administrative issue; it may represent the peak competitive opportunity of an athlete’s career. If such a dispute remains pending years after the event has concluded, the legal remedy becomes practically meaningless.
This delay problem lies at the heart of the sports dispute-resolution deficit. In ordinary litigation, a delay of months or years may be unfortunate but procedurally common. In sport, however, delay can destroy careers. A missed championship, an unresolved eligibility dispute, or a delayed selection challenge cannot always be compensated later. Sporting opportunities are immediate, seasonal, and often non-repeatable. This is precisely why sports disputes require specialised, time-bound adjudication rather than being absorbed into the ordinary docket of civil and constitutional courts.
The Manika Batra[7] case further illustrates the inadequacy of federation-led mechanisms. Batra approached the court in 2021 after issues arose concerning selection rules and alleged unfair treatment by the federation. Her case involved allegations of conflict of interest and pressure by the national coach, raising serious questions about athlete selection, federation neutrality, and procedural fairness. The matter showed how a athlete challenging selection decisions may have little effective recourse other than approaching the High Court, even though such disputes require urgent sporting and technical assessment.
The recent governance crisis involving the All India Football Federation (“AIFF”) also exposes the tension between domestic judicial intervention and international sporting autonomy. In 2022, FIFA suspended the AIFF due to ‘undue third-party influence’ after the Supreme Court appointed Committee of Administrators became involved in the federation’s affairs.[8] The suspension had serious consequences for Indian football and India’s hosting rights of the FIFA U-17 Women’s World Cup were threatened until the AIFF issue was resolved.[9]
These examples reveal a deeper institutional problem. There is no unified statutory forum with jurisdiction over sports-related disputes. Further, the lack of sports law specialists further compounds the problem. Sports disputes often require familiarity with federation regulations, international sporting codes, Olympic principles, anti-doping standards, eligibility norms, tournament timelines, and principles of natural justice. Ordinary courts can examine legality, arbitrariness, and procedural fairness, but they are not institutionally designed to act as first-instance sports adjudicators.[10]
Moreover, concerns regarding political interference and lack of neutrality cannot be ruled out. For athletes, who often lack bargaining power against federations, the absence of an independent adjudicatory forum undermines confidence in the fairness of the system.
While the CAS is the leading global forum for international sports disputes, it is expensive, procedurally complex, and available only where the applicable rules permit access. For domestic Indian athletes, especially those outside elite international competitions, CAS remains distant and largely inaccessible.
The present state of sports dispute resolution therefore, reflects a mismatch between the commercial growth of Indian sport and the institutional mechanisms available to regulate it and for a country seeking to become a serious global sporting power, this institutional vacuum is no longer sustainable.
National Sports Governance Act, 2025: A Necessary but Incomplete Reform
The National Sports Governance Act, 2025[11] (“Act”) is an important legislative development in Indian sports law. It reflects a growing recognition that sports governance can no longer be left entirely to federation constitutions, executive guidelines, ad-hoc committees, and court-driven intervention. By introducing a statutory framework, the Act marks a necessary shift towards institutional regulation.
The creation of the National Sports Tribunal is the most significant feature of the Act.[12] Conceptually, the Tribunal is intended to provide a specialised domestic forum for sports disputes, reducing dependence on ordinary courts and creating a more coherent adjudicatory mechanism. This is a welcome reform. A dedicated forum can bring consistency, expertise, and speed to disputes.[13]
Yet the existence of a tribunal alone does not guarantee justice. The real test will lie in its independence, accessibility, procedure, and speed. The tribunal must be capable of granting urgent interim relief, deciding matters within strict timelines, and understanding the technical rules of sporting federations.
The Act also operates within a complex legal environment. Some disputes may still begin before internal federation mechanisms. This means that the Tribunal cannot be treated as a universal remedy for every sports dispute.[14] Its success will depend on clear jurisdictional boundaries and coordination with federation rules and CAS obligations.
The Act is a positive and necessary reform, but it does not by itself resolve India’s sports dispute resolution crisis. India does not merely need a tribunal in name; it needs a specialised framework that is fast, independent, affordable, and athlete-centred. The Tribunal must not become another layer of litigation. It must become a practical substitute for the delays and inconsistencies that have historically weakened sports justice in India.[15] If implemented effectively, the National Sports Tribunal could become a landmark development. If implemented poorly, it may simply replicate the same delays and institutional weaknesses that the Act was meant to cure.
Designing an Effective National Sports Tribunal
The purpose of a National Sports Tribunal should be to provide what ordinary courts and federation committees have failed to consistently deliver: speed, expertise, neutrality, accessibility, and enforceability.
The first requirement is independence. A sports tribunal must be structurally separate from national sports federations, government influence and commercial stakeholders. Athletes must be able to approach the forum without fear that their future selection, funding, or participation will be affected.
The second requirement is specialised adjudication. The tribunal should include experienced arbitrators, sports law practitioners, former athletes and technical experts.
The third requirement is speed. A tribunal that takes months or years to decide a selection dispute will defeat its own purpose. The tribunal must not become the sports-law equivalent of slow-moving tribunals such as the Central Administrative Tribunal or Debt Recovery Tribunal, which have often been criticised for delays, backlog, and procedural complexity. In sports, justice delayed is not merely justice denied; it is often opportunity destroyed.
Selection disputes, eligibility challenges, disciplinary suspensions, and tournament-related grievances should be capable of being decided within strict timelines and emergency benches should be available during major national and international events. Further, many Indian athletes lack the resources to pursue prolonged litigation or arbitration. Legal costs, travel, language barriers, federation pressure, and fear of retaliation often prevent athletes from asserting their rights. The tribunal must therefore be affordable, procedurally simple, and athlete-friendly.
The need for such a tribunal is therefore, both legal and practical. A strong tribunal would protect athletes, strengthen accountability, reassure investors, reduce unnecessary court intervention, and develop a coherent Indian sports jurisprudence.
Conclusion
India’s emergence as a global sporting nation requires more than professional leagues, international events, and commercial success. It requires institutions capable of delivering timely, expert, and independent justice to athletes, federations, clubs, and other sporting stakeholders. A modern sports economy cannot function effectively if its disputes are resolved through delayed litigation, opaque federation processes, or ad hoc mechanisms.
The National Sports Governance Act, 2025 offers India a historic opportunity to correct this institutional gap.[16] However, the success of this Act will depend on implementation. Without a genuinely functional framework, governance reform will remain incomplete. India does not need a tribunal that exists only on paper or replicates the delays of existing adjudicatory bodies. It needs a forum that understands the realities of sport: urgency, expertise, neutrality, and finality. If implemented effectively, the National Sports Tribunal can become a cornerstone of Indian sports law and a decisive step towards protecting athletes while strengthening the integrity of the Indian sports ecosystem.
*Prateek Dhankhar, Counsel | Dispute Resolution (Litigation & International Arbitration)
[1]Court of Arbitration for Sport, History.
[2]Olympic Charter, Article 61.
[3]Court of Arbitration for Sport, Arbitration Rules for the Olympic Games.
[4] CAS dismisses Indian wrestler Phogat’s appeal against disqualification, Reuters, 15 August 2024.
[5]Denied berth in India’s World Championships squad, P.U. Chitra runs to court, Indian Express, 26 July 2017.
[6] Factional fights, aggrieved athletes: In 10 years, about 770 sports cases in court, Indian Express, 17 March 2025.
[7] Ms Manika Batra v Table Tennis Federation of India, W.P.(C) 10590/2021, Delhi High Court.
[8]FIFA, FIFA suspends All India Football Federation, 15 August 2022.
[9]ESPN, FIFA lifts suspension of All India Football Federation, U-17 Women’s World Cup to go ahead, 26 August 2022.
[10] PRS Legislative Research, Issues for Consideration: The National Sports Governance Bill, 2025.
[11]National Sports Governance Act, 2025, Act No. 25 of 2025, Government of India.
[12] National Sports Governance Act 2025, ss 17(2)–17(6).
[13] PRS Legislative Research, The National Sports Governance Bill, 2025.
[14] National Sports Governance Act 2025, s 20.
[15] National Sports Governance Act 2025, ss 22–23.
[16] Statement of Objects and Reasons, National Sports Governance Act 2025.