On October 12, 2025, the All India Football Federation (AIFF) adopted the Supreme Court-approved Constitution at its Special General Body Meeting, excluding two contentious clauses pending directions from the Court.[1]
In this update, we unpack the case and explore key provisions of the new AIFF Constitution.
Case Background
The instant case relates to a broader matter that raised questions about the working of various sports federations in the country and their election process, during the pendency of which the National Sports Development Code of India, 2011, was issued. While setting aside the results of the 2016 elections and paving the way for fresh elections, the Delhi High Court, vide decision dated October 31, 2017, had also ordered that the elected body had to carry out the requisite amendments to the AIFF Constitution to bring it into conformity with the Sports Code.
On appeal, later that year, the Supreme Court stayed the operation of the High Court’s decision and made appointments to the Committee of Administrators, which was entrusted with formulating the draft AIFF Constitution. Subsequently, the Committee’s mandate terminated and elections were held, with the newly elected Executive Committee taking charge on September 2, 2022. In 2023, the Court entrusted the task of finalising the AIFF Constitution to former Judge of the Supreme Court Justice L Nageswara Rao, noting that many of the stakeholders’ objections to the draft did not strictly implicate the issues of law, but also trenched into issues of policy. Subsequently, Retd. Justice L N Rao prepared a report and suggested amendments, and then objections were sought from stakeholders and AIFF to the new draft.
Supreme Court Approves AIFF Constitution
The Supreme Court, vide its September 19 judgment, addressed the objections to the draft Constitution and made necessary modifications. It finally approved the draft Constitution and directed the Federation to adopt it at the earliest, preferably within four weeks.
Key features of the approved AIFF Constitution include:
- Amendments to AIFF Constitution Require SC Nod: Amendments to the Constitution cannot be given effect to without the leave of the Supreme Court.
- Applicability to State Associations: AIFF has to ensure that the statutes, regulations, directives and decisions of FIFA and AFC, as well as the provisions of the Sports Code, are implemented and respected by its Members. Member Associations are also obligated to conform to AIFF’s Constitution.
- Concurrent Membership: If a person is elected as an office bearer on the AIFF Executive Committee and holds a position as an office bearer in a Member Association, they will automatically be deemed to have vacated their position in the Member Association.
- No Disqualification at the Stage of Charging: Disqualification from contesting and holding a position in the AIFF will not be at the stage of charging, but upon conviction followed by a sentence of imprisonment.
- No Transitory Provision: Current AIFF Executive Committee to be treated as a permanent body and not just an interim body, especially considering that its functioning would be subject to court orders and its term is set to expire in less than a year.
Further Clarity Sought
Concerns regarding clauses about the Supreme Court nod for the Constitution amendment, and concurrent membership have been raised before the Court. It is yet to be decided. The next hearing has been scheduled today (i.e. October 15, 2025), and it remains to be seen how these issues will be resolved.
[1] All India Football Federation v. Rahul Mehra & Ors. (Civil Appeal Nos. 12591-12592/2025)