Match Fixing: BCCI Allowed to Intervene in KPL Case, Bats for Criminalisation

Having recently been permitted by the Supreme Court to intervene in the Karnataka Premier League (KPL) case, the Board of Control for Cricket in India (BCCI) has batted for the criminalisation of match fixing.[1]

The KPL fixing scandal concerns alleged match fixing in several KPL matches during 2018 and 2019. Ultimately, 16 individuals were named as accused, with FIRs filed across three police stations. Four of the six accused named in one of the FIRs later approached the Karnataka High Court, which quashed the criminal proceedings by an order dated 10 January 2022. The Court ruled that match fixing did not constitute an offence under criminal law. Subsequently, some of the other accused, relying on this order, also obtained court relief.

The Karnataka state government then preferred the present petitions challenging the High Court’s January 2022 order.

Decision of Karnataka HC

The Karnataka High Court ruled that match fixing does not constitute an offence punishable under Section 420 of the Indian Penal Code, 1860 (replaced last year by the Bharatiya Nyaya Sanhita, 2023). The essential ingredients for invoking this offence are deception and the dishonest inducement of a person to deliver any property or to alter or destroy the whole or any part of a valuable security. The Court rejected the argument that spectators are induced to buy tickets for the fair play assured and that the element of deception therefore exists in match fixing. It was observed that while spectators may expect a fair game, tickets are purchased voluntarily, and consequently, the question of inducement does not arise.

The Court added that match fixing may indicate dishonesty, indiscipline, and mental corruption in a player, for which the BCCI may take disciplinary action. However, the registration of an FIR on the ground that an offence punishable under Section 420 IPC has been committed is not permitted.

Additional observations made by the Court concerned the use of a co-accused’s confessional statement recorded during interrogation in another case for FIR registration, the lack of necessity to produce this statement, and the inapplicability of the offence of conspiracy punishable under Section 120B IPC.

Matter Before the Supreme Court

Considering the broader perspective of the matter before it, the Supreme Court directed the Union of India, through the Ministry of Law and Justice, to be impleaded as one of the respondents in 2022, and also appointed an amicus curiae in April this year.

The matter remains pending and will be heard next on November 27, 2025.

BCCI’s Stand on Match Fixing

The BCCI has maintained that match fixing satisfies the ingredients of the offence of cheating. Having adopted its Anti-Corruption Code in March 2019, the Board emphasised the adverse impact of corrupt practices in cricket matches on the game and the integrity of the sport. It also referred to the 276^th report of the Law Commission of India, titled ‘Legal Framework: Gambling and Sports Betting including in Cricket in India’, which recommended that match fixing and sports fraud be specifically made criminal offences with severe punishments.

Final Thoughts

The case raises an important question of law that the Supreme Court will decide in the coming months. Its ruling could not only determine whether match fixing attracts criminal liability under existing law but also shape the future legal framework for addressing corruption in sports in India.

References:

[1] State of Karnataka & Anr. v. Abrar Kazi & Ors. [SLP(Crl) Nos. 9408-9411/2022].