Supreme Court clarifies contention over Article 23.3, Article 25 of AIFF constitution

AIFF adopted its new constitution on October 12, 2025.

The Supreme Court has issued a significant clarification on the long-debated AIFF Constitution, settling confusion over article 23.3 and articles 25.3(c) & 25.3(d).

According to the latest order, Article 23.3 need not be adopted, while Articles 25.3(c) and 25.3(d) will be formally adopted but will only take effect after the elections next year, once the current executive committee’s term ends in 2026.

This clarification comes shortly after the All India Football Federation (AIFF) formally adopted its new constitution on October 12, during a special general body meeting held in New Delhi. The adoption marked the end of a long and complicated legal journey that had delayed structural reforms in Indian football for years.

However, even after the constitution’s adoption, disputes over Articles 23 and 25 brought the federation back to the Supreme Court, prompting this latest judgment that now brings finality and stability to the governance framework.

Article 23.3 need not be adopted

Article 23.3 had sparked major concerns within the federation and from FIFA, as it required AIFF to seek the Supreme Court’s approval for any constitutional amendments. This was viewed as a potential case of “third-party interference,” which could once again attract FIFA sanctions, an issue that had already led to India’s suspension in 2022.

The Supreme Court acknowledged this concern and made it clear that continuous judicial supervision of a sports body is not appropriate. The bench, led by Justices P.S. Narasimha and Joymalya Bagchi, noted that the AIFF will instead be governed by the National Sports Governance Act, 2025 and any subordinate regulations formed under it.

“In reiteration of our opinion in para 941 of our judgment, we direct that upon AIFF adopting the draft Constitution as finalised by us, it (AIFF) will be governed by laws that are applicable to such bodies and this will include the National Sports Governance Act, 2025 and the subordinate legislation may be made thereunder, as and when they come into force. Thus, Article 23.3 need not be adopted,” the order stated.

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Articles 25.3(c) and 25.3(d) to come in after the elections next year

The court also addressed the debate around Articles 25.3(c) and 25.3(d), which bar AIFF officials from holding simultaneous positions in state associations. While the provisions were found to be consistent with both Indian law and FIFA regulations, enforcing them immediately would have forced several current office bearers to resign.

Senior Advocate Siddharth Luthra, representing AIFF, requested that the rules be deferred until the executive committee’s current term expires in September 2026. The Supreme Court accepted this proposal on recommendation from Justice Nageswara Rao, allowing AIFF to adopt the clauses now but apply them only after the next elections.

“In our judgment, we permitted the present executive to continue till the end of its term in order to ensure that there is minimal disruption to the already delay sporting events. In the same line, and to subserve the same purpose, we direct AIFF to adopt Articles 25.3(c) and (d) within three weeks from today as undertaken by Mr. Siddharth Luthra, Senior Counsel on behalf of AIFF. Articles 25.3(c) and 25.3(d) will however come into effect after the present executive demits office,” the order concluded.

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