Hyderabad Cricket Association: A Constitutional Conundrum

Court: Supreme Court of India.

Case Name: M/S the Hyderabad Cricket Association vs. M/S Charminar Cricket Club.

Citation: 2025 INSC 23. [PDF]

Introduction

The case before the Supreme Court involves a dispute regarding the governance and constitution of the Hyderabad Cricket Association (HCA). The legal battle began with a challenge to the appointment of the Ombudsman and Ethics Officer by the HCA's Apex Council. This challenge was initiated by M/s Budding Star Cricket Club, which contested the appointments as not being in line with the Association's constitution.

The matter has seen several twists and turns, with the case evolving significantly over time. The Supreme Court has become actively involved, appointing committees to oversee the HCA's affairs and recommend changes to its constitution. The court has also been tasked with resolving the objections to these changes.

A crucial issue arose concerning the alignment of HCA's constitution with that of the Board of Control for Cricket in India (BCCI). The Supreme Court has noted that there is a direction that all State Cricket Associations should have their constitutions in line with the BCCI constitution. This directive raised concerns that recommendations made by a Single Member Committee may conflict with the BCCI constitution.

Case Summary

  1. The case originated from a suit filed by M/s Budding Star Cricket Club, which contested the appointment of the Ombudsman and Ethics Officer by the Apex Council of the Hyderabad Cricket Association. The club argued that the appointments did not comply with the Association’s constitution.
  2. The Civil Court initially suspended the appointments, but the High Court reversed this decision. The High Court dismissed the suspension order and the suit itself, and imposed a cost of ₹25,000.
  3. The Hyderabad Cricket Association (HCA) filed Special Leave Petitions (SLPs) in the Supreme Court, challenging the High Court's order.
  4. The Supreme Court appointed a Supervisory Committee to oversee the affairs of the HCA. The committee included a retired Chief Justice, an IPS officer, and an ex-Indian cricketer.
  5. The Supervisory Committee was later dissolved, and a retired Supreme Court Judge was appointed as a Single Member Committee to conduct elections for the HCA’s executive body. The Single Member Committee also made recommendations for changes to HCA’s constitution.
  6. Objections were raised to the recommendations by various parties, some supporting and others opposing them.
  7. The Supreme Court found the Single Member Committee's recommendations to be prima facie "salutary" and ordered their implementation on an interim basis.
  8. A key issue arose regarding potential conflicts between the Single Member Committee's recommendations and the constitution of the Board of Control for Cricket in India (BCCI).
  9. The Supreme Court noted that there is a direction that all State Cricket Associations must align their constitutions with the BCCI constitution.
  10. The Supreme Court decided to tag the case with Civil Appeal No. 4235 of 2014, which deals with the BCCI constitution, to ensure a consistent approach.
  11. The matter has been referred to the Chief Justice of India to assign it to the appropriate bench.

Study guide

  1. Initial Dispute: The case began with M/s Budding Star Cricket Club challenging the appointment of the Ombudsman and Ethics Officer by the Hyderabad Cricket Association’s Apex Council. The club contended that these appointments did not follow the association’s constitution.
  2. Civil Court's Ruling: The Civil Court initially suspended the appointments of the Ombudsman and Ethics Officer. This decision was a temporary measure pending the resolution of the suit.
  3. High Court's Intervention: The High Court overturned the Civil Court’s decision. It set aside the suspension order, dismissed the suit, and imposed a cost of ₹25,000.
  4. Supreme Court's Involvement: The Hyderabad Cricket Association filed Special Leave Petitions in the Supreme Court, challenging the High Court’s judgment. The Supreme Court then broadened the scope of the case and began overseeing the matter.
  5. Supervisory Committee: The Supreme Court appointed a Supervisory Committee to oversee the operations of the HCA. This committee was composed of a retired Chief Justice, an IPS officer, and an ex-Indian cricketer.
  6. Dissolution of the Supervisory Committee: The Supervisory Committee was dissolved to pave the way for fair and proper elections for the HCA's executive body.
  7. Single Member Committee: The Supreme Court appointed a retired Supreme Court judge as a Single Member Committee to conduct elections and propose constitutional reforms for the HCA.
  8. Single Member Committee Recommendations: The Single Member Committee submitted a report with recommendations for constitutional changes. These recommendations were met with objections from various parties.
  9. Initial Court Reaction to Recommendations: Initially, the Supreme Court considered the recommendations to be beneficial and ordered their implementation on an interim basis while still allowing parties to voice their objections.
  10. Conflict with BCCI Constitution: A significant concern arose that the recommendations of the Single Member Committee might conflict with the constitution of the Board of Control for Cricket in India (BCCI).
  11. Civil Appeal No. 4235 of 2014: This case deals with the constitution of the BCCI and has a directive that all State Cricket Associations must align their constitutions with the BCCI constitution.
  12. Mr. Avishkar Singhvi's Argument: Mr. Avishkar Singhvi argued that the Single Member Committee’s recommendations could conflict with the BCCI constitution. He proposed that the present case be heard together with Civil Appeal No. 4235 of 2014 to avoid conflicting orders.
  13. Supreme Court's Final Order: The Supreme Court decided to tag the case with Civil Appeal No. 4235 of 2014 and referred the matter to the Chief Justice of India for assignment to an appropriate bench.

Rationale

  1. The Supreme Court acknowledged that the initial dispute centered on whether the appointment of the Ombudsman and Ethics Officer by the Hyderabad Cricket Association (HCA) was in line with its constitution.
  2. The Court noted the procedural evolution of the case, including the Civil Court's initial suspension order and the High Court’s reversal. The Supreme Court's intervention broadened the case's scope over time.
  3. The appointment of the Supervisory Committee was a measure to oversee the HCA’s affairs. The subsequent appointment of the Single Member Committee indicated the court's focus on ensuring fair elections and constitutional reforms.
  4. The Court considered the objections raised by various parties concerning the Single Member Committee’s recommendations. The Court initially found the recommendations to be prima facie salutary, but did not want to shut out parties from making submissions.
  5. The Court’s decision to tag the case with Civil Appeal No. 4235 of 2014 was based on the concern that the HCA's constitution must align with the BCCI’s constitution. The court wanted to avoid any potential conflicts with the directives issued in the BCCI case.
  6. Mr. Singhvi's submission highlighted the necessity of having consistent rules for all state cricket associations. The Court agreed that any conflicting views and orders would not serve the best interests of the cricket associations and the game.
  7. The Supreme Court did not delve into the merits of the recommendations of the Single Member Committee at this stage. It determined that the issue of potential conflict with BCCI guidelines needed to be addressed first.
  8. The Court recognized that the matter should be heard by the same bench handling Civil Appeal No. 4235 of 2014. This is to ensure consistency in application of the law and to avoid conflicting rulings.

FAQ

Q.1. What was the primary reason for the initial legal challenge?

Answer: The primary reason was a suit filed by M/s Budding Star Cricket Club challenging the appointment of the Ombudsman and Ethics Officer by the Hyderabad Cricket Association's Apex Council, arguing that the appointments were not in accordance with the association’s constitution.

Q.2. How did the High Court respond to the Civil Court's initial ruling?

Answer: The High Court overturned the Civil Court’s decision, dismissing the suspension order and the original suit. Additionally, the High Court imposed a cost of ₹25,000 on the losing party.

Q.3. What was the purpose of the Supervisory Committee appointed by the Supreme Court?

Answer: The Supervisory Committee was appointed to oversee the affairs of the Hyderabad Cricket Association. It was composed of a retired Chief Justice, an IPS officer, and an ex-Indian cricketer.

Q.4. Why was the Supervisory Committee dissolved?

Answer: The Supervisory Committee was dissolved to allow for fair and proper elections for the Hyderabad Cricket Association’s executive body.

Q.5. What were the key responsibilities of the Single Member Committee?

Answer: The Single Member Committee's main tasks were to conduct elections for the Hyderabad Cricket Association and to propose changes to its constitution.

Q.6. What led the Supreme Court to tag this case with Civil Appeal No. 4235 of 2014?

Answer: The primary concern was that the Single Member Committee’s recommendations might conflict with the constitution of the Board of Control for Cricket in India (BCCI). The Court wanted to ensure alignment with the BCCI constitution as per the direction in Civil Appeal No. 4235 of 2014.

Q.7. What is the significance of Civil Appeal No. 4235 of 2014?

Answer: Civil Appeal No. 4235 of 2014 is a case dealing with the constitution of the BCCI, and it includes a direction that all State Cricket Associations align their constitutions with the BCCI constitution. This case is significant because the Hyderabad Cricket Association’s constitution is expected to conform to BCCI guidelines.

Q.8. What is the next step for this case?

Answer: The Supreme Court has directed the Registry to place the papers of the case before the Chief Justice of India so that it can be tagged with Civil Appeal No. 4235 of 2014 and heard by the same bench. This is to ensure a consistent approach and to avoid any potential conflicting orders.

Conclusion

The Supreme Court's order of January 3, 2025, concerning the Hyderabad Cricket Association, underscores the complexities of governance and internal disputes within cricket associations. The decision to tag the case with Civil Appeal No. 4235 of 2014 highlights the judiciary's emphasis on ensuring consistency between the constitutions of state cricket associations and the BCCI. The case is not yet resolved and remains subject to further judicial consideration. The next phase will depend on the Chief Justice of India assigning the matter to an appropriate bench that can address both cases concurrently. The outcome of this process will have important implications for the Hyderabad Cricket Association and potentially for other state cricket associations in terms of aligning their constitutions with the BCCI, and what this might mean for the governance of cricket in India.

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