Delhi HC Quashes Recognition Of Yogasana Bharat, Directs Fresh Recognition Exercise

The Hon’ble Delhi High Court, in Yoga Federation of India v. Union of India & Ors., W.P.(C) 20/2021, judgment delivered on July 9, 2026, quashed the recognition granted to the National Yogasana Sports Federation (Yogasana Bharat) as the National Sports Federation for Yogasana, holding that the federation did not satisfy the mandatory eligibility requirements under the National Sports Development Code of India, 2011 (Sports Code).

The Court further held that the Ministry of Youth Affairs and Sports had failed to independently examine Yogasana Bharat’s eligibility against the mandatory criteria and had effectively acted upon the recommendation of the Ministry of AYUSH without undertaking the independent application of mind required of the authority vested with the power of recognition.

The dispute concerned the Sports Ministry’s decision dated November 27, 2020, granting Yogasana Bharat recognition as the National Sports Federation for Yogasana. The petitioner, Yoga Federation of India, had applied for recognition in December 2019 and its application was still under consideration shortly before Yogasana Bharat was recognised. Yogasana Bharat was registered on August 21, 2020, and the Ministry of AYUSH recommended it for recognition on October 29, 2020. The petitioner’s pending application was neither considered nor referred to in the recognition letter.

The Court found that Yogasana Bharat did not meet the mandatory conditions under the Sports Code on the date of recognition. It had existed for only approximately three months (falling short of the three-year requirement under Clause 3.3 by thirty-three months), had no State or Union Territory affiliations as required under Clause 3.4, and had not conducted the required National Championships at Senior, Junior and Sub-Junior levels for both men and women as mandated by Clause 3.8. The Court held that these were substantive conditions precedent to recognition and not procedural requirements that could be cured subsequently.

The Court also examined the role played by the Ministry of AYUSH. Referring to Rule 4 of the Government of India (Allocation of Business) Rules, 1961, it held that inter-ministerial consultation was permissible since Yogasana concerned both the AYUSH and Sports Ministries. However, the AYUSH recommendation could be considered only as input. The Sports Ministry was required to independently examine the eligibility of Yogasana Bharat and the competing application. Relying on A.K. Kraipak v. Union of India, the Court also considered the conflict arising from AYUSH’s involvement in promoting the establishment of the Yogasana body which it subsequently recommended for recognition.

The Court rejected the contention that the later relaxation clause introduced into the Sports Code on February 1, 2021 could validate the recognition granted in November 2020. Relying on Commissioner of Income Tax v. Vatika Township Pvt. Ltd., the Court held that the relaxation provision could not operate retrospectively. It further distinguished All India Pickleball Association v. Union of India & Anr., noting that the relaxation in that case had been formally exercised, with reasons recorded and specific requirements identified for relaxation. No such exercise had taken place in the present case.

The Court further set aside the speaking order dated October 19, 2021. The Sports Ministry relied on an RTI response received after the hearing, which Yogasana Bharat had submitted through the Ministry of AYUSH but which was never disclosed to the petitioner. Relying on Mohinder Singh Gill v. Chief Election Commissioner and Deepak Ananda Patil v. State of Maharashtra, the Court held that the petitioner was entitled to an opportunity to respond to material relied upon against it. The Court also found that the speaking order considered the petitioner’s eligibility but failed to address whether Yogasana Bharat itself satisfied the mandatory Sports Code criteria, despite an earlier direction of the Court to consider whether its recognition should continue.

The Court accordingly quashed the recognition dated November 27, 2020, the speaking order dated October 19, 2021 and the annual renewal letters for 2022 to 2025. However, it protected certificates, titles, medals, rankings and selections conferred upon athletes and other participants while the recognition remained operative. The Sports Ministry was directed to issue a public notice within 60 days inviting applications from all eligible bodies seeking recognition as the National Sports Federation for Yoga/Yogasana and to complete the recognition exercise in accordance with the Sports Code. The Court clarified that it was not declaring the Yoga Federation of India as the National Sports Federation.