CONSTITUTION OF INDIA — Article 226 — Writ of Mandamus — Sports bodies — Recognition of State Sports Association — Natural justice — Compliance with earlier writ directions. Where derecognition of a State Football Association had earlier been set aside in W.P. No.30093 of 2025 with liberty to the State Sports Authority to pass fresh orders after affording opportunity, and thereafter the Authority issued a circular seeking documents, but proceeded to issue a “final notice” without effectively considering the association’s representation and request for rescheduling of hearing (sent by courier and e-mail), on respondents stating their willingness to consider the representation afresh on receipt of one more set of documents, the High Court disposed of the writ at admission stage permitting the association to submit one more complete set of documents and directing the authority to pass orders after granting a personal hearing within the framework of earlier directions. No costs. (A.P. Football Association v. State of A.P. & Ors., W.P. No.34023 of 2025, order dated 08-12-2025, per Harinath N., J.)

CONSTITUTION OF INDIA — Article 226 — Writ of Mandamus — Sports bodies — Recognition of State Sports Association — Natural justice — Compliance with earlier writ directions.
Where derecognition of a State Football Association had earlier been set aside in W.P. No.30093 of 2025 with liberty to the State Sports Authority to pass fresh orders after affording opportunity, and thereafter the Authority issued a circular seeking documents, but proceeded to issue a “final notice” without effectively considering the association’s representation and request for rescheduling of hearing (sent by courier and e-mail), on respondents stating their willingness to consider the representation afresh on receipt of one more set of documents, the High Court disposed of the writ at admission stage permitting the association to submit one more complete set of documents and directing the authority to pass orders after granting a personal hearing within the framework of earlier directions. No costs.
(A.P. Football Association v. State of A.P. & Ors., W.P. No.34023 of 2025, order dated 08-12-2025, per Harinath N., J.)

II. ANALYSIS OF FACTS AND LAW

1. Parties and relief sought

• Petitioner: Andhra Pradesh Football Association (APFA), represented by its General Secretary M. Daniel Pradeep.

• Respondents:

  1. State of A.P. (Principal Secretary, Sports Department),

  2. Sports Authority of Andhra Pradesh (SAAP) – Vice Chairman & Managing Director,

  3. SAAP – Chairman,

  4. All India Football Federation (AIFF).

Substantive relief (as per writ prayer):
Mandamus to declare as arbitrary and illegal the action of Respondent No.2 (SAAP) in issuing a list dated 12-11-2025 showing APFA’s recognition as “not renewed” for 2025 and circulating the same along with circular No. SAAP/coaches/1931970/2025, as being contrary to the National Sports Development Code, violative of natural justice and the earlier order in W.P. No.30093/2025, and to direct SAAP to reflect APFA’s recognition as renewed for 2025 and permit it to continue to function as the recognized State Football Association.

Two interlocutory applications sought:

• IA 1: Direction to formally recognise that APFA’s recognition stands renewed for 2025 as per proceedings dated 29-10-2025, and to allow it to conduct all activities and receive grants;

• IA 2: Suspension of notice dated 04-12-2025 and a direction to consider APFA’s explanation dated 22-11-2025 with opportunity of personal hearing as per the Sports Code.

2. Background: Earlier writ W.P. No.30093 of 2025

• The Court notes that APFA previously challenged derecognition/related proceedings in W.P. No.30093 of 2025.

• By order in that writ:

  • The impugned proceedings dated 29-10-2025 were set aside;

  • The matter was remitted, leaving it open to 2nd respondent (SAAP) to pass appropriate orders in accordance with law after affording an opportunity to APFA.

Thus, there is already a binding direction that any decision on recognition must conform to fair procedure and hearing.

3. Subsequent conduct and grievance in present writ

According to the petitioner:

• Post-remand action:

  • SAAP (R2) issued a circular calling for several documents for renewal; APFA claims to have submitted them “promptly”.

• Final notice without true hearing:

  • SAAP thereafter issued a final notice dated 04-12-2025, stating that no further opportunity would be given and that the authority would proceed based on documents on record.

• Petitioner’s efforts to respond:

  • APFA submitted an application dated 22-11-2025 by DTDC courier; tracking shows delivery to R2.

  • APFA also sent an e-mail on 04-12-2025:

    • Clarifying that a complete set of required documents had already been submitted with the renewal application,

    • Stating that another set of documents had been dispatched by courier,

    • Explaining they were engaged with the Junior Girls National Championship, Anantapur, and

    • Requesting rescheduling of the proposed hearing.

The complaint in essence: despite these steps, the authority was proceeding as if there was no meaningful representation and was shutting the door on further opportunity, allegedly in breach of the earlier High Court order and natural justice.

4. Stand of the respondents

• Learned Standing Counsel for respondents 2 and 3, on oral instructions, stated before the Court that the respondents are willing to consider the petitioner’s representation, subject to APFA submitting one more set of documents in the prescribed form.

This is effectively a concession to re-open consideration, mooting the need for a substantive adjudication at this stage.

5. Court’s approach and legal reasoning

The Court adopts a minimalist, pragmatic approach at the admission stage:

• It records:

  • Petitioner’s grievance about non-consideration of its representation and final notice;

  • Respondents’ willingness to reconsider upon receipt of fresh documents.

Rather than pronouncing on:

• Validity of the list dated 12-11-2025,

• Effect of the “final notice” dated 04-12-2025,

• Alleged violation of the National Sports Development Code or lis pendens,

the Court chooses to restore procedural fairness and enforce its earlier remit order in W.P. No.30093/2025 by:

• Permitting APFA to submit one more complete set of documents required for reconsideration;

• Directing respondents 2 and 3 to pass necessary orders after granting an opportunity of hearing to the petitioner.

In doing so, the Court:

• Reaffirms that recognition / renewal decisions are to be taken only after affording an opportunity and considering the association’s material;

• Uses its writ jurisdiction to regulate process, not to decide the merits of recognition itself.

The order is expressly a disposal at admission stage, indicating that the Court finds the procedural direction sufficient to protect the petitioner’s rights at this juncture.

III. CONCLUSION / OPERATIVE DIRECTIONS

The operative part of the order is:

1. Writ petition disposed at admission stage on consent/procedural basis.

2. Liberty to the petitioner (APFA):

   • To submit one more set of documents in the prescribed form required for re-consideration of recognition renewal.

   • Time granted: two (02) weeks from the date of the order (08-12-2025).

3. Direction to respondents 2 and 3 (SAAP authorities):

   • To pass necessary orders on recognition / renewal,

   • After granting an opportunity of hearing to the petitioner.

4. Costs: No order as to costs.

5. Pending miscellaneous petitions (including the IAs) stand closed in consequence.

So, effectively:

• The earlier derecognition/remand is still subject to reconsideration;

• APFA has been given a clear procedural window of two weeks with a right to personal hearing;

• SAAP is bound to take a fresh, reasoned decision after considering the freshly submitted documents.