The National Sports Governance Act, 2025 faces its first real test in the All-India Tennis Association reform process. After years of factionalism and disputed elections, the Delhi High Court on 27 April 2026 appointed Justice Gita Mittal (Retd) as Administrator to oversee the Association’s constitutional reform. On 18 June, a division bench recorded a consent roadmap with a fixed timetable for amending the byelaws and holding fresh elections.
In AIFF v. Rahul Mehra (2025), the Supreme Court described sporting facilities and opportunities as “material resources of the community” under Article 39(b), and their organisers as institutions of national life. The restructuring of the All-India Tennis Association (AITA) is the first test of whether the new regime can live up to that description, and of how statutory mandates fare against entrenched administrative resistance, judicial intervention, and concerns about international autonomy.
The National Sports Development Code of India, 2011 now stands superseded by the National Sports Governance Act, 2025 and the National Sports Governance (National Sports Bodies) Rules, 2026. Rule 18 of the 2026 regulations requires federations to amend their byelaws within six months of notification—12 January 2026—of certain provisions of the Act, and a Sports Ministry directive of 22 December 2025 has allowed elections to be deferred only until 31 December 2026. In compliance with the same, AITA’s constitution stood amended on 26 July 2026, and AITA is required to conform on the following five fronts:
- An Executive Committee capped at 15 (AITA had 25)
- An age limit of 70
- Three-term limits followed by cooling-off for office-bearers
- Inclusion of Sportspersons of Outstanding Merit
- Statutory Athletes, Ethics, and Dispute Resolution Committees
How has the restructuring unfolded?
The restructuring was initiated in 2024, when former players Somdev Devvarman and Purav Raja challenged the federation’s elections in the Delhi High Court over non-compliance with the 2011 Sports Code. On 24 September 2024, four days prior to the scheduled voting, the court directed that election results be placed in a sealed cover, leaving the outgoing Executive Committee in charge. On 27 April 2026, following the notification of the National Sports Governance Act, 2025, the single judge opened the sealed cover, permitting the declared candidates to function strictly as an interim Executive Committee for day-to-day operations while appointing Justice Mittal (Retd) as Administrator to align AITA’s constitution with the new Act.
In response to the single judge’s decision, cross-appeals came to be filed by AITA against the Administrator’s appointment and by the petitioners challenging interim recognition of the 2024 body. The division bench of the Delhi High Court recorded a court-facilitated consent schedule on 18 June 2026 without adjudicating the merits. This consent roadmap required the interim Executive Committee to submit its suggestions for reforms and compliance with the Act by 25 June 2026, mandated finalised draft amendments by 15 July 2026, scheduled an Extraordinary General Meeting (EGM) by 31 July 2026, and set fresh elections for 30 September 2026, while permitting state associations to vote irrespective of immediate compliance, provided they align with the Act by 31 December 2026.
On 26 July 2026, the General Body convened to vote clause by clause on the Administrator’s draft amendments alongside the Executive Committee’s proposed modifications. AITA reported that the Executive Committee’s modified version was approved by a large majority, with the General Body preferring a 70-year age cap over 75 years by a 25-to-22 margin. Friction deepened on 14 September 2026, when the Administrator submitted Report V before the High Court, recording that the interim Executive Committee had failed to produce minute books, selection policies, a validly constituted selection committee, or payment records. Report V also placed on record material concerning the AITA Trust, the Delhi Lawn Tennis Association (DLTA), and the R.K. Khanna Tennis Stadium, seeking their formal impleadment, a forensic audit, and official reports from both the Ministry of Youth Affairs and Sports and the Land & Development Office.
To accommodate statutory timelines, the division bench issued an order on 25 September 2026, extending the election schedule and shifting the polling date from 30 September to 27 November. At its Annual General Meeting (AGM) on 30 September, AITA formally appointed Rajeev Sharma, former Haryana State Election Commissioner and member of the National Sports Election Panel, as electoral officer. The AGM further constituted a Dispute Resolution Committee, granted voting rights to two para-athletes in the General Body, and established a task force to bring the AITA Trust directly under AITA. The electoral calendar, spanning from the publication of the final electoral college on 7 November to polling on 27 November, follows the 21-day model calendar under Schedule II of the Rules. Amid these developments, both cross-appeals remain part-heard before the division bench, leaving all resolutions and General Body decisions explicitly subject to the final judicial outcome.
AITA’s legal position is centred on defending its institutional autonomy as a registered society under Article 19(1)(c) of the Constitution. Challenging the single judge’s directions in appeal, AITA contended that appointing an Administrator to redraft byelaws, oversee bank accounts, and conduct elections was ultra vires the National Sports Governance Act, 2025, which contemplates only executive and regulatory oversight by the Central government. AITA argued that in the absence of any finding of gross mismanagement or structural breakdown, replacing the Executive Committee’s statutory powers was premature, especially given the statutory transition period allowing federations until December 2026 to align their byelaws. AITA also cautioned that open-ended judicial administration constituted impermissible “third-party interference” under International Tennis Federation (ITF) charters, jeopardising the federation’s international standing and risking player suspension ahead of major events such as the 2026 Asian Games.
Why the court, not the board
AITA and general opponents of judicial intervention in the non-judicial arena of sport have raised questions as to why the Delhi High Court has even interfered. The simple answer is that while the Act does provide a remedy for such a situation in Sections 9, 10, and 11(2) to 11(5), the same are not yet in force. The unnotified provisions include Section 6 (the Board’s powers), Section 9 (Board inquiries into athlete welfare, the development of sport, and misuse of public funds), Section 10 (suspension or cancellation of recognition for, among other things, failure to hold elections, gross irregularities in them, failure to publish audited accounts, or misuse of public funds) and Sections 11(2) to 11(5) (a Board-appointed ad hoc administrative body of up to five members).
Therefore, in the absence of the actualisation of the legislative machinery to meet the present contingency, the court, through the appointment of Justice Mittal (Retd), is filling in a legislative vacuum. Section 11(1), the only part of Section 11 in force, only applies where a federation loses international recognition.
While the election schedule addresses immediate ITF concerns, does the process materially address the governance lapses?
Pursuant to a recent letter from ITF to AITA, dated 8 May 2026, it was stated that the Administrator’s continuance beyond court-mandated timelines may be construed as third-party interference and thereby invite ITF to review AITA’s membership as well as disallow participation of Indian players in ITF competitions. It is possible that, in view of this directive, the Administrator has filed an application for discharge from her duties, with the next returnable date being 6 November 2026. However well-intentioned, such pressure from the ITF may derail any real reform process of addressing serious governance and financial issues that have been unearthed in reports submitted to the Delhi High Court by the Administrator.
One of these reports raises several questions regarding alleged financial mismanagement which the aforementioned process does not reach. This pertains to the activities of the AITA Trust. The Administrator’s Report records that in 2000, AITA irrevocably transferred its rights in the R.K. Khanna Stadium, and its income, to the AITA Trust, run by office-bearers overlapping with AITA’s. DLTA alleges it paid the Trust Rs 39.09 crore in rentals between 2006 and 2023. None of this is adjudicated. But electing a new committee neither traces that money nor fixes responsibility; without a forensic audit, it simply brushes past lapses under the carpet.
In short, although the election will produce a committee that is compliant on paper, it will not address the real governance concerns. The court will be left to deal with whether to further inquire into the alleged irregularities and consider the prayers of the Administrator in its report, which has sought a forensic audit among other pertinent prayers.
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The real outstanding questions for Indian tennis
From the players’ perspective, the most important questions will remain open after 27 November 2026:
- Who controls the DLTA stadium and its income? Until the AITA Trust and DLTA arrangement is unwound or regularised, the elected federation will lack control of its principal asset and its revenue.
- Will there be an audit with consequences? The forensic audit sought is the only mechanism now available to trace public grants and stadium revenue. The election should not close that account.
- Will athletes have real power? Sportspersons of outstanding merit and Athletes’ Committee representatives hold four of 15 seats, and the byelaws decide whether the latter may vote (second proviso to Section 4(1)(b)). The Report found no written policy or properly constituted committee for the decisions players feel most: selection, captaincy, and pay for support staff.
- Will the decline be arrested? Citing the Administrator’s sports expert, the Report notes that India has one man in the ATP top 300 and no woman in the WTA top 300, and that it had no singles player in the qualifying or main draw at Wimbledon 2026. Reform will be judged by coaching, junior pathways, and a functioning centre of excellence, not by a compliant constitution.
- Will the State associations follow? National compliance means little if the affiliates that form the electorate remain unreformed after 31 December 2026.
- When will remaining provisions of the Act be notified? Notifying Sections 6, 9, 10, 11(2) to 11(5), 12, and 13, and the Tribunal provisions in Sections 20 and 22 to 26, would let the regulator and the specialist tribunal, rather than writ courts, handle the next AITA.
Yash Johri leads Johri & Co. Akashdeep SR is a law student at NALSAR, Hyderabad. Akshat Rathore is a Delhi-based lawyer working at Johri & Co. Views are personal.
(Edited by Prasanna Bachchhav)