AIFF Returns to Supreme Court Over Constitutional Crisis as FIFA Ban Deadline Looms

The All India Football Federation finds itself in constitutional turmoil once again, returning to the Supreme Court just weeks after the apex court approved its draft constitution on September 19, 2025. The AIFF has approached the Supreme Court seeking urgent clarification and potential modification of two contentious clauses—Articles 23.3 and 25—that federation officials believe could violate FIFA statutes and trigger administrative chaos within Indian football’s governance structure.

Timeline of Constitutional Crisis

The development came after an urgent meeting of the AIFF Executive Committee in New Delhi on Tuesday, October 8, where members unanimously decided to file a review petition concerning the problematic constitutional provisions. Senior Advocate Siddharth Luthra mentioned the matter before the Supreme Court on Thursday, with the bench agreeing to hear the case on Friday at 10:30 AM.

The Contentious Articles Explained

Article 23.3: The Third-Party Interference Dilemma

Article 23.3 of the draft constitution states unequivocally: “Any such amendment shall not be given effect to without the leave of the Hon’ble Supreme Court.”

This provision mandates that the AIFF must seek Supreme Court permission before implementing any amendments to its constitution. While seemingly designed to maintain judicial oversight and prevent arbitrary changes, this clause has raised serious concerns about “third-party interference”—a red line for FIFA that has historically resulted in sanctions against member associations.

The FIFA Perspective: Article 19 of FIFA Statutes explicitly mandates that member associations must operate independently without external interference in their internal affairs. Any government or judicial intervention in football administration can be construed as third-party interference, potentially triggering suspension from international competitions.

Historical Precedent: India experienced this firsthand in 2022 when FIFA imposed a ban on the AIFF for precisely such interference. The ban was lifted only after assurances were given that the federation would operate autonomously. The specter of another ban now looms large with Article 23.3 potentially creating a permanent mechanism for court involvement in AIFF’s constitutional amendments.

AIFF’s Argument: The federation’s submission to the Supreme Court emphasized that this clause was not part of Justice L. Nageswara Rao’s original draft recommendations. Justice Rao, the former Supreme Court judge appointed to formulate the constitution after consulting stakeholders including FIFA, reportedly did not include such a restrictive provision. The AIFF contends that introducing this requirement contradicts the spirit of FIFA’s autonomy principles and could leave Indian football perpetually vulnerable to sanctions.

Article 25: The Dual Office-Bearer Prohibition

Article 25 of the draft constitution addresses concurrent memberships and states: “In the event a person is elected as an Office-Bearer in the Executive Committee of the AIFF and holds a position of an Office-Bearer in a Member Association, he/she shall automatically be deemed to have vacated his/her position in the Member Association.”

The Practical Impact: This provision effectively prohibits individuals from simultaneously holding office-bearer positions in both the AIFF and state football associations. The ramifications are potentially devastating for the current administrative structure:

State Association Resistance: State football association officials have vehemently opposed Article 25, arguing that FIFA statutes contain no such restriction on concurrent memberships. They point out that simultaneous involvement at national and state levels actually enhances coordination, ensures consistent policy implementation, and leverages experienced administrators’ expertise across governance tiers.

Several state association representatives have expressed willingness to resign en masse if the constitution with this provision is adopted—a move that could create unprecedented administrative vacuum and potentially cripple grassroots football development.

The Supreme Court’s Rationale: When approving the draft constitution on September 19, the Supreme Court had reinstated clauses (b) and (c) of Article 25 specifically to “ensure that an official at the national federation is not overworked with responsibilities at a member association.” The Court’s intention appeared focused on preventing conflicts of interest and ensuring dedicated attention to national federation duties.

However, critics argue this well-intentioned provision ignores ground realities of Indian football administration, where many competent administrators serve both levels precisely because of limited qualified personnel willing to take on these demanding volunteer roles.

FIFA’s October 30 Deadline

Adding urgency to the constitutional crisis is FIFA’s unambiguous deadline of October 30, 2025, for the AIFF to finalize and adopt its new constitution. This timeline was communicated to the federation last month with clear implications: failure to comply could result in another suspension from international football.

Consequences of Missing the Deadline:

• Immediate suspension from all FIFA competitions and tournaments
• Indian clubs barred from AFC competitions including Asian Champions League
• Indian national teams (men’s, women’s, youth) prohibited from international matches
• Potential disruption to the upcoming Indian Super League season scheduled for December
• Loss of FIFA development funding and technical assistance
• Damage to India’s international football reputation

The 2022 ban, though brief, demonstrated FIFA’s willingness to enforce its statutes strictly. That suspension lasted only days but created panic within Indian football circles, with the Under-17 Women’s World Cup hosting rights potentially at risk before the ban was lifted.

The Special General Meeting Conundrum

The AIFF has scheduled a Special General Meeting (SGM) for October 12, 2025—Saturday—where the draft constitution is expected to be formally adopted by member associations. This meeting occurs just two days after the Supreme Court hearing, creating a compressed timeline fraught with uncertainty.

Possible Scenarios:

1. Supreme Court Grants Relief: If the Court modifies or clarifies Articles 23.3 and 25, the SGM can proceed with adopting an amended constitution that satisfies both judicial requirements and FIFA statutes.
2. Court Maintains Original Position: The AIFF may face pressure to adopt the constitution as approved despite internal reservations, risking either FIFA sanctions or mass resignations from the Executive Committee.
3. Further Delays: Additional hearings or deliberations could push adoption beyond the October 12 SGM date, requiring another meeting closer to the FIFA deadline.

Executive Committee’s Predicament

The current AIFF Executive Committee, led by President Kalyan Chaubey, faces an unprecedented dilemma. The September 19 Supreme Court judgment recognized their tenure as legitimate and allowed them to serve out their remaining term (approximately one year) without fresh elections.

However, if Article 25 comes into force without modification, a significant portion of the Executive Committee members who simultaneously hold state association positions would automatically be disqualified. This includes:

Affected Categories:

• Vice Presidents with state association roles
• Treasurer with state federation connections
• Executive Committee members serving as state association presidents or secretaries
• Co-opted members holding dual positions

President Kalyan Chaubey remains unaffected as he holds no state association office, but governing a federation whose Executive Committee has been decimated by automatic disqualifications presents enormous challenges.

Several members have privately indicated they would choose to retain state positions rather than national roles, given the grassroots importance of state association work and the closer connection to local football ecosystems.

The National Sports Governance Act Factor

Complicating matters further is the National Sports Governance Act (NSGA) 2025, enacted while the constitutional process was ongoing. The Act creates new requirements and standards for national sports federations operating in India.

Some legal experts suggest that when the NSGA 2025 comes into full effect, certain contentious constitutional provisions may become redundant or require realignment with the new legislation. Article 25’s restrictions, for instance, might need reinterpretation in light of the Act’s governance framework.

The Supreme Court, in its September 19 judgment, acknowledged the NSGA 2025 and modified certain disqualification criteria accordingly. For instance, the Court amended provisions related to government servants holding AIFF positions, recognizing that if proper permissions are obtained under Section 4(2)(e) of the NSGA 2025, such individuals should not face blanket disqualification.

Stakeholder Positions

AIFF’s Request: The federation seeks “minor tweaks” to the two contentious clauses rather than wholesale rejection of the court-approved constitution. This moderate approach aims to balance judicial mandates, FIFA requirements, and administrative practicality.

Amicus Curiae Position: Gopal Sankaranarayanan, serving as amicus curiae, and advocate Samar Bansal have been directed to receive copies of the AIFF’s submissions and will likely provide independent analysis of whether modifications compromise the constitutional framework’s integrity.

FIFA-AFC Stance: While not directly party to the Supreme Court proceedings, FIFA and the Asian Football Confederation have made their position clear through the October 30 deadline. Any constitution that enables third-party interference or fails to ensure federation autonomy will be unacceptable.

State Associations: Most state federations oppose Article 25 and have lobbied intensively for its removal or modification. Their collective voice carries weight given that they form the AIFF’s membership base and will vote on constitutional adoption at the SGM.

Indian Super League Implications

The constitutional uncertainty has cascading effects on Indian football’s commercial landscape, particularly the Indian Super League (ISL). The league’s commercial partner, Football Sports Development Limited (FSDL), has been operating under an extended Master Rights Agreement (MRA) that expires in December 2025.

Negotiations for a new MRA have been hampered by the constitutional ambiguity, with FSDL seeking clarity on AIFF’s governance structure and decision-making authority before committing to a renewed agreement. The Supreme Court, recognizing this commercial imperative, had lifted its embargo on AIFF entering contracts once the constitution was finalized.

However, the renewed uncertainty could delay MRA negotiations further, potentially impacting:

• ISL season start date (currently planned for December)
• Franchise agreements and player contracts
• Broadcasting rights negotiations
• Sponsorship commitments
• Prize money distribution

Historical Context: The 2017 Origins

This constitutional saga traces back to 2017 when the Delhi High Court quashed the election of AIFF office-bearers, including then-President Praful Patel, following a petition by sports activist and lawyer Rahul Mehra. The High Court found governance irregularities and violations of the National Sports Code.

The matter reached the Supreme Court, which has since maintained oversight of AIFF’s constitutional reforms. The appointment of Justice L. Nageswara Rao in May 2023 to draft a comprehensive constitution after stakeholder consultations represented a major step toward resolution.

Justice Rao’s draft incorporated inputs from FIFA, the Indian Olympic Association, the Ministry of Youth Affairs and Sports, state associations, and other stakeholders. The final constitution approved by the Supreme Court on September 19 substantially followed Justice Rao’s recommendations with certain judicial modifications—including the now-contentious Articles 23.3 and 25.

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