SPORTS LAW IN INDIA
WHAT WILL WE LEARN? Sports law is that field of law which deals
1. INTRODUCTION TO SPORTS LAW IN with issues that arise during the preparation
INDIA. for or execution of sports events. Sports law
also deals with the issues connected to
2. NATIONAL SPORTS POLICY relationship between, and activities of,
3. SPORTS GOVERNING BODIES IN INDIA individuals and institutions in the sporting
4. COMMITTEE RECOMMENDATIONS world. It transgresses into the already
established body of labor law, contract laws,
ON THE NATIONAL SPORTS POLICY competition laws and the law of torts.
5. NEED FOR UNIFORM SPORTS CODE
6. LEGAL ISSUES RELATING TO INDIAN
Previously, the term sports law was considered to be a misnomer. It was believed that there was
no such thing as sports law but the amalgamation of sorts and Law. Law relating to sports is now
established to be and is considered a separate and important entity that coincides with the growing
realization of public of the importance of sports. 1
Ever since ancient times, sports have held an important pedestal in the Indian society. Sports not
just dealt with the physique of the individual but also mastering the art of offence and defense.2
Even today, various sports are being played in the country and several stakeholders invest huge
amounts of private money in them. Presently these sports are being governed by a combination of
rules that govern the particular sport as well as various other fields of law. Thus, it is of utmost
importance to have a more centralized enactment on the same.
1 Mukul Mudgal and Vidushpat Singhania, “Law and Sports in India” (2016), p.15
2 L.C. Gupta, Manual Of First Aid, Management of general injuries and sports injuries and Common Management,
Edition 2005, Jaypee Brothers New Delhi.
The following sections of the paper are divided into five main parts. The first part shall deal with
National Sports Policy. The National Sports Policy, 1984 which was further reviewed and
reformulated in the year 2001, followed by National Sports Policy 2007, their Objectives and the
deficiencies that these policies sought to remove shall be discussed in the said section.
The next section shall deal with sports governing bodies wherein the structural hierarchy of Sports
worldwide and the relation amongst national governments, and various international and national
sports bodies will be discussed, focusing primarily on the institutions that govern sports in the
The next few sections shall deal with committee recommendations and legislations regarding
Sports based legislations and the need for a Uniform Code on the same. The final section will talk
about the various Indian sporting leagues and some Issues associated with them.
2. NATIONAL SPORTS POLICY
NATIONAL SPORTS POLICY 1984/2001
In the year 1984 a resolution was laid out in both the houses of Parliament on the National Sports
Policy. The primary objective behind formulating the National Sports Policy, 1984 was to raise
the standards o sports in India. The Policy provided for a progress review every 5 years, to
determine the course of action for future. Eventually, it was realized the provisions laid down
within the National Sports Policy, 1984 regarding its implementation were incomplete and the
National Sports Policy, 2001 was the drafted to deal with these incongruities.
The National Sports Policy requires the central government, the state government, the IOA and
the National Federations to coordinate their working to strive towards broad basing of sports by
promoting rural and tribal talent. The union government and the sports authority of India (SAI)
along with IOA and National Sports Federations are to concentrate on achieving excellence both
at domestic as well as international levels.
The primary objective of the National Sports Policy, 2001 is mass participation. The relevant
portions of the said policy read as under:3
• Considering the key role of sports in national life and for inculcating national pride in the
younger generation, the objective of broad basing, that is, universalisation or
massparticipation in Sports assumes special significance. It is imperative to ensure that
the educational institutions, schools, and colleges in both rural and urban areas; the
Panchayati Raj Institutions, Local Bodies, the government machinery, the Sports
Associations and Industrial Undertakings, as also the various Youth and Sports Clubs,
including those of the Nehru Yuva Kendra Sangathan (NYKS) throughout the country are,
and remain, fully associated with this Programme. Efforts will be made to promote and
encourage women’s participation in sports. The Union and State Governments, as well as
the Sports Federations/Associations will endeavor to promote a "club culture" for the
speedier development of Sports in the country.
• In the National Sports Policy, 2001, high priority will be accorded to the development of
Sports in the rural areas to harness the available talent and potential. In this context, the
Village Panchayats/Gaon Sabhas as well as rural Youth and Sports clubs will be mobilized
to facilitate development of the requisite infrastructure and for the identification of talent
through an appropriate competition structure in the rural areas as also in the disadvantaged
and remote parts of the country which appear to merit special consideration under various
schemes including for the North East. Efforts will also be made for tapping such potential
as swimming in coastal areas and Archery in tribal areas. The available talent will be
nourished and actively supported. Geographically disadvantaged Regions will be
extended additional support for the promotion of Sports. There has been a strong tradition
of Indigenous and traditional games in practically all parts of the country through ages.
Indigenous games will be promoted through schemes related to rural sports.
3 “Comprehensive National Sports Development Policy, 2001” Available at: http://www.napess.org/sportsPolicy-
2001.php accessed on 17th November 2016
Emphasis has also been laid down on the need for integration of sports with education as well as
the development of infrastructural facilities, in the following terms:4
• The integration of Sports and Physical Education with the Educational Curriculum, making
it a compulsory subject of learning up to the Secondary School level and incorporating the
same in the evaluation system of the student, will be actively pursued. A National Fitness
Programme would be introduced in all Schools in the country, steps initiated to augment
the availability of infrastructure, including play fields/ sports equipment and action taken
to provide Physical Education Teachers in educational institutions through, inter-alia, the
training of selected teachers in these disciplines. Specialized Sports Schools may also be
set up. An appropriate Inter-school and Inter- College/University competition structure
would be introduced at the National, State and District levels.
• The availability of adequate sports facilities throughout the country is basic to the
development and broad-basing of Sports. In addition to the Union and State Governments,
the sustained involvement of other agencies, including the Panchayati Raj Institutions,
Local Bodies, Educational Institutions, Sports Federations/Associations. Clubs and
Industrial Undertakings will be enlisted in the creation, utilization and proper maintenance
of the Sports infrastructure. While existing play fields and stadia, both in rural and urban
areas, will be maintained for sports purposes, the introduction of suitable legislation may
be considered for providing open areas to promote sports activities. Steps would be taken
to evolve low cost functional and environment-friendly designs in this regard, so that
maximum benefits could be derived through relatively low levels of investment. Efforts
will also be made to optimally utilize the available infrastructure and manpower and
Special Coaching Cams organised, during the vacations, to provide intensive training to
talented sports persons, even as they pursue their academic work.
The policy also stresses at achieving excellence in sports at the domestic and international levels,
and puts forth the same as under:5
4 “Comprehensive National Sports Development Policy, 2001” Available at: http://www.napess.org/sportsPolicy-
2001.php accessed on 17th November 2016
5 “Comprehensive National Sports Development Policy, 2001”Available at: http://www.napess.org/sportsPolicy-
2001.php accessed on 17th November 2016
• The Union Government would focus attention on achieving Excellence in Sports at the
National and International levels. Various sports disciplines will be prioritized on the basis
of proven potential, popularity and international performance. Particular emphasis will be
placed on the development of such priority disciplines and the prioritization reviewed, from
time to time. The IOA and the State Governments would also accord higher priority to such
disciplines. In planning the development of various disciplines, the genetic and
geographical variations within the country would be taken into account so that in areas of
potential, in particular disciplines, timely steps may be taken to harness the existing and
emerging talent. Centers of excellence will be set up to identify and train outstanding
sportspersons including sports academies where young and talented sports persons will be
groomed to achieve higher levels of performance in the international sports arena.
The policy acknowledges the importance of National Championships in harnessing competitive
spirit by emphasizing the role of National Sports Federations in ensuring effective participation in
international events, especially Olympics, Asian Games and Commonwealth game and promoting
the development of sports among juniors and sub-juniors and identifying those to be put for Special
support and training from amongst them. Resource mobilization, sports and tourism, providing
incentives to sports persons and training and development of coaches, sports scientist’s judges,
referees and umpires along with initiating suitable measure to ensure access to sports equipments
of high quality were other important themes of focus taken into consideration in the National
Sports Policy, 2001.
NATIONAL SPORTS POLICY 2007
The Comprehensive National Sports Policy 2007 aims at building on previous sports policies with
a view to accomplishing the unfinished agenda and addressing the emerging challenges of India
in the 21st century, most particularly the national goal of emerging as a global, yet inclusive,
economic power in the near future.6
Focus of the National Sports Policy, 2007 is the overall wellbeing of an individual, youth
development, community development, peace, and brotherhood. A multi-faceted approach
6 “National Sports Development Policy 2007” Available at: http://yas.nic.in/sites/default/files/File371.pdf accessed
on 18th November, 2016.
towards development is sought to be adopted including improvement in infrastructural facilities,
media coverage, and growth of sports as a business and the use of scientific technology. The role
of mega sporting events has also been recognized while considering the tradeoff between economic
benefits arising out of these events and the opportunity costs associated with them. Issues
pertaining to integrity in sports, like doping and corruption in sports, are sought to be brought in
focus and the modes to combat these menaces are sought to be strengthened. 7
The National Sports Policy, 2007 aims at involving all the stakeholders in the process of improving
the condition of sports, in India. The National Sports Policy tackles the following deficiencies that
need to be tackled:
• access to sport and physical education opportunities still remains highly inadequate,
especially in rural areas and the poorer parts of urban areas, in consequence, the levels of
participation in sport and physical education at home, school, college, the community level
and the workplace are abysmally low;
• the participation of girls and women in physical education and sports is far below that of
boys and men;
• persons with disability have hardly any access to sporting facilities and most of the sports
infrastructure is not disabled friendly;
• indigenous sports and games need to be brought centre-stage in the promotion of a national
• education remains highly academic-centric with a definite trend towards reducing school
sports and extra-curricular sports;
• India’s performance in international sport needs to be significantly enhanced through a
holistic and sportsperson-centered cradle-to-grave sports policy;
• to this end, and within the framework of the Olympic Charter, the Sports Authority of India,
the Indian Olympics Association and the National Sports Federations need to be revamped,
rejuvenated and reoriented to function in an open, democratic, equitable, transparent and
• as there is too much concentration of resources and pubic support on too few team sports
like cricket, there is need to popularize other sports, especially medal-intensive individual
sports disciplines such as athletics, gymnastics, and swimming;
• sports medicine and sports science need particular attention;
• the scientific and technical support systems for high performing athletes are insufficient;
• the disgrace of sportspersons and athletes resorting to drug abuse needs to be ended as a
matter of priority with strict adherence to the Copenhagen Declaration adopted by the
World Anti-Doping Authority (WADA) and the UNESCO Convention against Doping in
• Public as well as private and voluntary support for participative/ recreational and
competitive sport has been highly inadequate.
All this calls for a fresh look at the Constitutional provisions for sports; the legislative framework
for the regulation of sports and games at the national and, possibly, the state level (including 23
the conditions and enforcement of those conditions agreed through Long Term Development Plans
negotiated between Government and the NSFs); and the need for a Sports Regulatory Authority.8
8 “National Sports Development Plocy 2007”Available at: http://yas.nic.in/sites/default/files/File371.pdf accessed on
18th November, 2016.
POINTS TO REMEMBER
National Sports Policy laid out in the year 1984 with the intention to raise the standards of
sports in India with policy for progress review every 5 years, to determine the course of
action for future. National Sports Policy, 2001 was then drafted to deal with the setbacks of
Primary aims of the policy were broad basing of sports, integrating sports in the educational
curriculum and proper resource mobilization.
❖ It also aimed at prioritizing various disciplines on the basis of proven potential and
setting up centers of excellence to identify and train outstanding athletes.
❖ The National sports Policy of 2007 was brought in to fulfill the object of fulfilling
unfinished agendas of the previous policy and rejuvenating the Sports Authority of
India, Indian Olympics Association and National Sports federation.
❖ Providing appropriate technical and scientific support to the athletes and increasing
public as well as private and voluntary support for participative/ recreational and
3. SPORTS GOVERNING BODIES IN INDIA
A general system of hierarchy of sports governing bodies is a three tier pyramid like structure with
International Federations acquiring the top most position, followed by National federations in the
middle and State federations at the very bottom of this hierarchy. The International Federation of
the particular sport governs the sport across the world and each of the national federations is bound
by the rules formulated by the international federation. Only one national federation for that sport
is recognized by the international federation in each country and similarly only one state federation
is recognized by the national federation in each state for that sport. State federations have the duty
to control and govern the sport in that particular state. Below these state federations are the district
federations and clubs. The National Sports Development code of India 2011 also seeks to maintain
the sanctity of this structure.
However, contrary to how simple the structure appears to be, it is in fact a rather complex
relationship. The following figure gives a depiction of this structure:9
United Nations (UN) Organization stands at the top of this hierarchical structure. The right of
access to sports has been recognized by the UN through various conventions. India is one of the
9 Mukul Mudgal and Vidushpat Singhania, “Law and Sports in India” (2016), p.26
47 members of the Group of Friends of Sport for development and peace under UN that meets
every two months, with the aim of member states to integrate sports within their policy structure.
The main aim of the United Nations Office on sport for development and Peace (UNOSDP) is to
bring the world of sports and development closer.10
Various international non- governmental organizations, such as International Olympic Committee
(IOC), World Anti-doping Agency (WADA), the Court of Arbitration for Sports (CAS) and
International sports federations (IF’s) together govern the whole International sporting system.
International Olympics Organization has the supreme Jurisdiction over the Olympic Games as per
the Olympics charter. IOC is a Swiss non-profit organization with its headquarters in Lausanne. It
was created on 23rd June 1894 to act as a catalyst for collaboration between all the member
countries to promote the values that have been listed within the Olympics charter. It is responsible
for the organization of Olympic Games; one of the greatest sporting events in the world.11
The World Anti-Doping Agency (WADA) was established in the year 1999 as an international
independent agency composed and funded equally by the sport movement and governments of the
world. It is primarily involved in scientific research, education, development of anti-doping
capacities, and monitoring of the World Anti Doping Code. The WADA code is a document that
seeks to harmonize anti-doping policies in all sports and all countries.12
The beginning of 1980s saw the regular increase in the number of international sports-related
disputes and the absence of any independent authority that could successfully resolve and give a
binding decision upon them. These twin issues eventually resulted in the creation of a specialized
authority capable of settling international disputes and offering a flexible, quick and inexpensive
procedure i.e. Court Of Arbitration for Sports (CAS).13 Initially CAS was set up such that its
jurisdiction would not be imposed on either the athletes or the federations but this changed in the
10 Mukul Mudgal and Vidushpat Singhania, “Law and Sports in India” (2016), p.27
11 Available at: https://www.olympic.org/the-ioc/what-we-do Accessed on 15 November 2016.
12 “Who we are” Available at: https://www.wada-ama.org/en/who-we-are Accessed on 15 November 2016.
13 “ History of CAS”Available at: http://www.tas-cas.org/en/general-information/history-of-the-cas.html Accessed
on 15 November 2016.
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Gundel judgment wherein it was held by the Swiss Court that, CAS indeed was the true arbitration
Court for sports.14
At National level, even though it is generally preferred that sports remain out of the control of
state, state intervention in a country such as ours is essential as most sports, barring a few
exceptions like cricket, are not lucrative enough and require infrastructural support from the state.15
The State as a sovereign entity plays a decisive role in the organization and promotion of physical
activities and sports, as it oversees the approved sporting federations. It promotes the growth of
sports federations along with along with their devolved organs such as leagues and committees by
providing them with financial assistance and human resource and infrastructure in order to support
MINISTRY OF YOUTH AFFAIRS AND SPORTS
The Ministry of Youth Affairs & Sports was initially set up as the Department of Sports in 1982
at the time of organization of the IX Asian Games in New Delhi and eventually, became an
independent ministry on 27th May, 2000. The ministry is further divided into Department of Youth
Affairs and another one of Sports.17 The primary objectives of Ministry of youth affairs and sports
• Maintaining and improving India’s world rankings throughout various sporting events
across the world.
• Supporting Federation policies to increase participation in competitive sports.
• Creating the infrastructure, requisite for capacity building and achieving excellence in
world- class sporting events as well as the ones that take place at National level.18
15 A Nelson, ‘When, Where and Why does the State Intervene in Sports: A Contemporary Perspective’.Available at
http://epublications.bond.edu.au/slej/1/ accessed on 15th November.
16 Mukul Mudgal and Vidushpat Singhania, “Law and Sports in India” (2016), p.42
17 Available at: http://yas.nic.in/sports/introduction Accessed on 16th November 2016/
18 Supra note 8
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Several important awards signifying excellence in the field of sports such as the Arjuna Award,
Rajiv Gandhi Khel Ratna Award, Rashtriya Khel Protsahan puruskar and Dronacharya Award are
also given by the sports department of Ministry of Youth Affairs and Sports.19
SPORTS AUTHORITY OF INDIA
The Sports Authority of India (SAI), came into existence post the IX Asian Games held in New
Delhi in 1982. It was established in 1984 as a society under the Societies Registration Act 1860 in
pursuance of the Resolution No. 1-1/83/SAI dated 25th January 1984 of the Department of Sports
under the government of India, with the objective of promotion of Sports. SAI maintains and
utilizes stadia on behalf of the government which became venue for the Asian Games 1982 and
Commonwealth Games 2010.20
The primary aims and objectives of SAI include:
• Ensuring the promotion of sports in the country.
• Implementing schemes aimed at achieving excellence in sports, in India.
• To maintain and utilize stadia which were constructed/renovated for the IX Asian Games
held in 1982 on behalf of the government.
• SAI acts as an interface between the Ministry of Youth Affairs & Sports and other agencies
concerned, i.e., U.T. Administration, IOA, State Govt., Sports Control Boards, National
Sports Federations, Industrial Houses, etc.
• To establish, run, manage and administer the institutions to produce high caliber coaches,
sports scientists and physical education teachers.
• To plan, construct, acquire, develop, take over, mange, maintain and utilize sports
infrastructure and facilities in the country.
• To initiate, undertake, sponsor, stimulate and encourage research projects related to various
sports sciences for up gradation of sports, sportspersons and coaches.
• Other incidental issues concerning promotion, development and excellence in sports.21
19 “Awards and Awardees” Available at: http://yas.nic.in/sports/awards-awardees Accessed on 16th November
20 Available at: https: http://www.sportsauthorityofindia.nic.in/index1.asp?ls_id=56 Accessed on 15 November 2016
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SAI is completely dedicated to ensuring sporting brilliance in the nation by getting into a
partnership with various agencies. As of late, SAI went into a MOU with Glenmark Aquatic
Foundation for Swimming, Mary Kom Boxing Academy for Boxing and Gopichand Badminton
Academy for Badminton. It is also looking for creating collaborations with International Sport
Bodies. SAI has held hands with International Center for Coaching Excellence (ICCE) for building
up a national coaching system.
INDIAN OLYMPIC ASSOCIATION
Much before India gained its independence, it participated in the Olympics and it proved to be
monumental in fostering the image of India as an independent existence.22
A National Olympic Committee (NOC) is a national constituent of the worldwide Olympic
movement. The NOCs promote the rudimentary principles of Olympism at a national level. They
are committed to ensuring the positive growth of athletes. Only an NOC can pick and send teams
and competitors for participating in the Olympic Games. They also train sports administrators by
organising educational programmes. Before a candidate city can compete against those in other
countries, it first must win the selection process by the NOC in its own country. Only then can the
NOC that city to the IOC as a candidate for hosting the Olympic Games.23
In India, the responsibility for preparing the athletes and their participation in Olympics as well as
many such other events such as the Commonwealth Games lies with the Indian Olympic
Association. At the national level, each sports federation has Even the Olympic associations at the
state level strive to achieve these objectives.
The role of National Olympics committee has been prescribed as:
• To promote the values and fundamental principles of Olympics in the country, particularly
in the field of sports and education;
• to ensure the observance of the Olympic Charter in their countries;
• to encourage the development of high performance sport as well as sport for all;
22 B. Majumdar and N. Mehta, India and the Olympics
23 “Governance of National Olympic Committee” Available at: https://www.olympic.org/ioc-governance-national-
olympic-committees Accessed on 17th November 2016.
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• to help in the training of sports administrators by organising courses and ensuring that such
courses contribute to the propagation of the Fundamental Principles of Olympism;
• to take action against any form of discrimination and violence in sport;
• to adopt and implement the World Anti-Doping Code;
• To encourage and support measures relating to the medical care and health of athletes.24
The IOA has a differential voting rights system amongst its members. National sports federations
whose sports forms a part of the Olympics/ Asian/ Commonwealth program have three votes;
while State Olympic associations have two voting rights. The service Control Board as well, has
two voting rights whereas the members of IOC have one voting right. Athletes representing
Athletes Commission also have one vote.25
NATIONAL ANTI- DOPING AGENCY
Prior to the setting up of the World Anti-Doping Agency in 1999, IOC was responsible for
promotion of Anti-Doping in sports. Eventually, it was the Conference on doping in Lausanne,
Switzerland that led to the creation of world anti-doping agency in the year 1999.
In 2004 India signed the Copenhagen declaration on doping and set up National Anti-Doping
Agency (NADA) in accordance with the terms of the Code. NADA accepted the World Anti-
Doping Code and framed the anti-doping rules of NADA in conformity with the WADA’S code.26
National Anti-Doping Agency aims to achieve dope free sports in the country. The main
underlying objective of NADA is to effectively implement the Anti- Doping rules in India in
complete conformity with the WADA code to ensure the proper regulation of dope control
program, to promote education and research and creating awareness about the ill-effects of doping.
The Primary functions of NADA include:
• Implementation of the anti-doping code to ensure that all the sports organizations in the
country comply with them.
24 Article 27, International Olympic committee Charter.
25 Mukul Mudgal and Vidushpat Singhania, “Law and Sport in India” (2016) pg 45
26 “About Nada” Available at: http://nada.nic.in/View/Homepage.aspx Accessed on 17th November, 2016
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• Conducting dope testing program and coordinating it through all the participating
• Promotion of anti-doping research and education to a value system that seeks to establish
dope free sports.
• Adopting the best practice standards and extremely efficient and high quality systems to
enable the effective implementation and continual improvement of the program.27
The objective behind establishing Nada was that it acts as an independent anti-doping organization
for India having a vision of dope free sports. The NADA has the Necessary authority and
responsibility for planning, implementing, coordinating and monitoring improvements in dope
control. NADA must ensure proper control and coordination with other relevant National
Organizations and agencies and encourage reciprocal testing between National Anti-Doping
Organisation. Nada must vigorously pursue all potential anti-doping rule violations within its
jurisdiction including investigation into whether an athlete support personnel may have been
involved in a case of doping.28
NATIONAL SPORTS FEDERATIONS
National sports federation controls and ensures the efficient governance of a particular sport in the
country and recognizes only one state federation per state. Athletic Federation of India, Badminton
Federation of India, Cycling Federation of India, All India Football Federation and Fencing
Association of India are few such examples of National sporting federations.
National federations shoulder upon themselves, the responsibility to identify the sportsmen who
will represent India and the coaches who will supervise them. They are responsible to ensure
efficient utilization of the funds allocated for various sports by providing with preparatory training
and guidance to players and teams. They are also tasked with taking up initiatives to help promote
sporting activities and emphasizing on the social and educational role of sports.
However, although these federations are required to play an important role in the quantitative and
qualitative improvement of sports activities, particularly for people with disabilities, school
27 “Primary Functions” Available at: http://nada.nic.in/View/PRIMARYFUNCTION.aspx accessed on 17th
28 “Vision of NADA ” Available at: http://nada.nic.in/View/VISION.aspx Accessed on 17th November 2016.
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children, women and the elderly etc, as well as in the development and fitness of every individual,
they usually don’t.
POINTS TO REMEMBER
❖ Three tier, pyramid like hierarchical structure wherein the International Federations
acquire the top most position, followed by National federations in the middle and
State federations at the very bottom.
❖ United Nations (UN) Organization stands at the top of this hierarchical structure.
❖ International Olympic Committee (IOC), World Anti-doping Agency (WADA),
the Court of Arbitration for Sports (CAS) and International sports federations (IF’s)
together govern the whole International sporting system
❖ Ministry Of Youth Affairs and Sports was initially set up as department of sports
❖ Sports Authority of India It was established in 1984 as a society under the Societies
Registration Act 1860 with the objective of achieving excellence in sports and
ensuring the promotion of sports in the country.
❖ Indian Olympic Association has the responsibility for preparing the athletes for
participation in Olympics and other such International sporting events.
❖ National Anti-Doping Agency was set up as a result of the Copenhagen Declaration
to achieve dope free sports in the country.
❖ National Sports Federations controls and ensures the efficient governance of a
particular sport in the country and recognizes only one state federation per state.
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4. COMMITTEE RECCOMENDATIONS ON THE NATIONAL
In India, the integration of physical education and sports with formal education was emphasized
in the First Five Year Plan itself. The Lakshmibai National Institute of Physical Education (LNIPE)
at Gwalior and the National Institute of Sports (NIS) at Patiala were established in the Second Five
Year Plan. The National Coaching Scheme and the Rural Sports Programme were started in the
Third Five Year Plan and expanded during the Fourth and Fifth Five Year Plans. Talent spotting
and nurturing was emphasized in the Sixth Five Year Plan. The Seventh Five Year Plan focused
on the creation of sports infrastructure. The development of Rural Sports through a Special Area
Games Approach was the thrust of the Eighth Five Year Plan. The Ninth Five Year Plan
emphasized the need for modern sports infrastructure. The Tenth Plan sought to promote both the
broad -basing of sports and the promotion of excellence in sports.29
However, these high and ambitious objectives could not be realized in significant measure both
because of policy lacunae and because of the inadequacy of budgetary support to sports from the
Union Government and State Governments. Serious concern at this state of affairs has been
expressed in various Parliamentary Committee Reports.
The Standing Committee on Human Resource Development in its Thirty Fourth Report
(1995) on India’s performance in International Sports made wide -ranging observations and
recommendations, including the following:30
• The Government should plan the development of sports in a phased manner so that
necessary infrastructure is built up over a period of time.
• In view of the decentralization of resources to Panchayats, Government should ensure that
there is a sports complex in each Panchayat which should also hold sports competitions
and championships periodically.
29 “Comprehensive Sports Policy 2007” Pg 6, Available at: http://yas.nic.in/sites/default/files/File371.pdf accessed
on 5 November 2016
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• Panchayat bodies must also take up the responsibility of scouting talent at an early age and
select them on scientific basis.
Despite these recommendations, there has been little progress made in taking organized sports and
games to children in rural India or in involving Panchayats in the promotion of such sports and
The Parliament Standing Committee on Human Resource Development (1998) studied a wide
range of issues concerning Sports and emphasized the need for bringing about reforms in sports
management and governance in order to make it more dynamic, responsive, responsible and result
-oriented. Some of the major problems identified by the Committee include:31
• the lack of sports culture in the country;
• the non -integration of sports with the formal education system;
• the lack of coordination between all stakeholders;
• the inadequacy of sports infrastructure;
• the inadequate participation of women in sports; and
• The lack of effective sports systems for talent identification and training and fair selection
Notwithstanding some progress in filling these lacunae, the validity of these observations remains
and much more needs to be done towards fulfilling these objectives.
Against the background of Government’s decision with effect from fiscal year 2005-06 to shift
the responsibility for financing rural sports infrastructure entirely to State Governments, the
Department Related Parliamentary Standing Committee on Demands for Grants (2006-’07)
of the Ministry of Youth Affairs and Sports, in its 176th Report laid in Parliament, pointedly
recommended that the Ministry should provide “funding for rural sports infrastructure
development to patronize the rural sports under its direct supervision ”. This recommendation was
similar to the recommendation of the Working Group on Youth Affairs and Sports for the
31 “Comprehensive Sports Policy 2007” Pg 9, Available at: http://yas.nic.in/sites/default/files/File371.pdf accessed
on 5 November 2016
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Formulation of the Xth Five Year Plan which, while referring to thrust areas for the Plan,
observed that “There is an immediate need to create a network of basic sports infrastructure
throughout the country” and ensure proper access to it “to enable more people to participate in
sports thereby broadening our base for scouting of talent.” The same point was elaborated upon
by the Working Group on Youth Affairs and Sports for the Formulation of the XIth Five
Year Plan which emphasized the need to strengthen the institutional framework for the
development of sports in the country. It states that, “In order to develop a comprehensive
framework for the development of sports in a holistic manner, it would need to be seen in a
threefold perspective–the development of sports and physical education as an essential ingredient
of youth development and the promotion of a sports culture in the country; broad-basing of sports
in the context of the new dimensions that sports as an activity, per se, has acquired and the
opportunities that it would provide for our youth; and promotion of excellence, particularly with
reference to competitive sports at the international level.”32
As outlined in the section above, the role of sports in national development requires to be redefined
to accord to sports that critical role in youth development which is the prerequisite of accelerated
and inclusive national development. Earlier attempts, have not adequately addressed the issue.
Hence the imperative need of a new Comprehensive Sports Policy.
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POINTS TO REMEMBER
❖ 34th Report of the Standing Committee On Human Resource Development
recommended that, Government should plan the development of sports in a phased
manner and ensure decentralization of resources to panchayats.
❖ The lack of sports culture in the country and the non -integration of sports with the
formal education system were some of the primary issues identified by the Parliament
Standing Committee on Human Resource Development (1998).
• Department Related Parliamentary Standing Committee on Demands for Grants
(2006-’07), recommended that the Ministry should provide funding for rural sports
infrastructure development to patronize the rural sports under its direct supervision the
same being elaborated by the Working Group on Youth Affairs and Sports for the
Formulation of the XIth Five Year Plan.
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5. NEED FOR A UNIFORM SPORTS CODE IN INDIA
In India sports are a part of the State list of the Seventh Schedule under entry 33 of the Constitution.
There are no central or state legislations that regulate sports in the country. The Sports Law in
India is governed and regulated by National Sports Policy, Sports Law and Welfare Association
of India, Sports Authority of India and The Sports Broadcasting Law in India.33 The law relating
sports is mostly scattered across various legislations. There is a need for a more comprehensive
uniform code in India which successfully combines all the rules, schemes, notification and
provisions scattered across various legislations.
Commonwealth Games and IPL and the various controversies that we associate them with,
highlighted their lack of integrity towards the sport and a lack of proper investigation, procedures
for handling complainants, lack of proper investigation procedure, and division of responsibilities
amongst others. This also shows the imperative need for revamping the current legal structure
surrounding sports in India. Sports should be free of corruption and transparent and authorities
should be made accountable to the public to ensure their credibility.34
During the Commonwealth Games, the fact that there were no existing suitable legislations for the
organisation of a mega sporting event deeply affected India’s objectives and attracted a lot of
controversy to the event in contrast to other international models, such as the Sydney Olympics
2000, London Olympics 2014 and Glasgow Commonwealth Games 2014. These models enshrine
legislations for the regulation and the smooth functioning of organizing committees (OC) and
judicious dealing with key issues such as transport, ticketing, and intellectual property, land
acquisition, broadcasting and licensing rights.35
NATIONAL SPORTS DEVELOPMENT CODE OF INDIA
A step forward in the direction of having uniform sports based legislations is the National Sports
Development Code 2011 (sports Code) which was issued by the Ministry Of Youth Affairs and
33 Emergence of sports law in India by Gaurang Kanth., Indian Law Journal
34 Corruption in sports in India by Ashutosh Misra and Abhishek Vikram
35 The Prevention Of Sports Fraud Bill, 2013: A Messiah To Indian Sports? By Ashuti Panjwani And Devika A.
Kumar, International Journal For Legal Developments And Allied Issues Volume 1 Issue 3 [Issn – 2454-1273]
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Sports in January 2011. The Sports Code was an amalgamation of the various orders and circulars
issued by the government from time to time. The purpose of issuing the code was that that sports
development was a national priority, as it had a health and public welfare nature. Besides this, at
the national level, sports teams as well as individuals internationally involved national pride and
National relations of the country.36
The intention behind the sports code was to put all government related policies pertaining to sports
in one places well as to regulate sports in national interest, especially when it involves prevention
of racism, eradication of doping in sports, prevention of age fraud, child abuse, sexual harassment,
protecting gender equality in sports, banning dangerous sports, promoting professional
management, financial accountability in sports, good governance, addressing anti-trust and
completion policy issues, regulating sports broadcasting rights, regulating the price and entry to
sporting events, etc.
The provision in the sports code that became a bone of contention between the government of
India, Indian Olympic association and the National Sports Federation was the age and tenure norms
which were to be imposed on the office bearers of these organizations. Due to strong opposition
from IOA and NSF’S the instruction was overlooked for some time.
The Delhi High Court in Narendra Batra v Union of India (civil W.P. No. 7868 of 2005)37 in the
matter f Indian Hockey Federation, while disposing off the writ petition, vide order dated
02.03.2010, observed categorically that the governments guidelines governing the NSF were valid,
binding and enforceable; and the tenure clause is not in violation of the IOC’s charter.
Also, the Supreme Court in the case of Board of Control for Cricket in India v Cricket Association
of Bihar, though not directly dealing with the sport code, has recognized the role of government
in formulating legislation or guidelines pertaining to sport especially when it involves the
performance of Public functions.
36 Mukul Mudgal and Vidushpat Singhania, “Sports and Law in India” (2016) pg. 81
37 Narendra Batra v Union of India (2009) ILR 4 Del 280
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The decisions by The Supreme Court and Delhi High Court have further strengthened the poition
of Indian Government and the government has undertaken the process of drafting the National
Sports Development Code of 2015.
NATIONAL SPORTS FRAUD BILL
The spot fixing and match fixing scandals in cricket brought forth the brought forth the inadequacy
in Indian Criminal law in dealing with the problem of match fixing and spot fixing in sports. There
is not a complete absence of provisions to address these problems. The international cricket council
has an anti-corruption code for participants and BCCI’s anti-corruption code has similar provisions
to address the problem of corruption by fixing and contriving the influence of the result. However
the power to take an action under these codes in limited to the participant and cannot include the
bookies who are the main culprits as they induce such acts. Also the code is imposed by the
governing body of the sport, the penal provisions are disciplinary in nature and the sanctions range
from bans to fines.
Dishonesty in sporting event Bill which was drafted in early 2000 had limited application to the
modern commercial game. After the IPL 2013, the government of India was of the opinion that
there was a need to relook the merits of the draft and based changes based on the outlook of the
modern game. A committee headed by Justice Mukul Mudgal was constituted to provide
suggestions and it was upon their recommendations that the Prevention of Sporting Fraud Bill
was drafted. This bill seeks to punish various kinds of practices that threaten the integrity of
The Prevention of Sports Fraud Bill, 2013 is landmark legislation in the arena of sports in India
that aims to weed out corruption. Even though this is a step forward in the right direction there is
a very long distance to go in order to become a successful anti fixing legislation.39
38 Mukul Mudgal and Vidushpat Singhania, “Sports and Law in India” (2016) pg. 79
39 Corruption in sports in India by Ashutosh Misra and Abhishek Vikram
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POINTS TO REMEMBER
❖ Sports are a part of the State list of the Seventh Schedule under entry 33 of the
❖ There are no central or state legislations that regulate sports in the country.
❖ National Sports Development Code 2011 (sports Code) was issued by the Ministry Of
Youth Affairs and Sports in January 2011.
❖ Dishonesty in sporting event Bill which was drafted in early 2000 with the intention to
deal with inadequacy in Indian Criminal law in dealing with the problem of match
fixing and spot fixing in sports.
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6. INDIAN SPORTS LEAGUES: LAW AND ISSUES
Professional sports leagues are unique business structures in a free market economy. They
amalgamate within them elements of competition with cooperation and allow the owners of these
terms to gain monetary benefits based on a profit maximizing40 structures which shall be further
elaborated upon discussing each of these Indian Sporting leagues as discussed below.
THE INDIAN PREMIER LEAGUE
The first of its kind, the Indian Premier League has made the ever-increasing commercialization
of sports a step further in the area of corporate finance. Commercialization has gone to the extent
of not just the team kits being sponsored but separate sponsors have come in for sponsoring the
The revenue model of IPL depends on
centralized and decentralized systems. The
centralized revenue streams include various DID YOU KNOW?
sponsorship and broadcasting deals of IPL. The ninth edition of the Indian Premier
DLF, the property developer of India, paid League ended on a high note with 121 million
more than Rs. 200 crore to win the exclusive viewers tuning in for the finale between Royal
title sponsorship rights of IPL for a period of Challenger Bangalore and Sunrisers
five years. The other sponsors are Hero, Hyderabad on May 29.
Vodafone, Citi Bank, Karbonn Mobile,
Volkswagen and Royal Challenge. Kingfisher Airlines became the official umpire partner of IPL
at a price of Rs. 106 crore. The broadcasting right to show IPL matches in India was sold to Multi
Screen Media at an exorbitant amount of Rs. 8,700 crore for a period of ten years. A part of this
centralized revenue is distributed to the franchises. It was decided that, till 2017, 40% of this
revenue would be retained by IPL while 54% would be distributed among the franchises and 6%
would be spent as prize money. After 2017, 50% of this revenue will be retained by IPL, 45% will
40 Scott Rosner and Kenneth L. Shropshire, “The Business Of Sports”(2011) Jones and Barlett Publishers
41 Mukul Mudgal and Vindushpat Singhania, “Law and Sports in India” (2016) pg 214
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be given to the franchises and 5% will be spent as prize money. Therefore, it is evident that IPL,
like any other major leagues, provides financial support to its franchises for their survival.42
The decentralized revenue stream allows the franchise owners to sell the commercial rights of the
individual franchise. Aircel, the telecom service provider of India, has paid Rs. 85 crore to renew
its deals with Chennai Super Kings for a period of three years. Deccan Charges has added two
more sponsors, Jaypee Cements as principal sponsor and TVS as co-sponsor. Mumbai Indians
signed a deal with Hero Honda for three years for approximately Rs. 18-20 crore each year. Delhi
Daredevils signed Muthoot Group as the main sponsor of their team. So, through decentralized
revenue pool, sufficient opportunity is given to the franchises to generate fund.43 The revenue
generated by these franchisees comes through team sponsorships, gate receipts in matches, sale of
broadcast rights and gate receipts of matches held on their home ground. All of this revenue except
from the one with team sponsorships must be shared with IPL for the next 10 years.44
The cricketers are remunerated handsomely by the IPL thus setting an example for the world on
how to market a product for a huge premium. While the IPL has seen a fare share of controversies,
such as match fixing, spot fixing and other major charges of corruption, it is a novel concept which
paved the way for several other Indian sporting leagues and helped in popularizing those sports in
THE HOCKEY INDIA LEAGUE DID YOU KNOW?
The league organized by Hockey India was
initiated in the year 2013 and is played between Indian Hockey Federation was formed on
five franchises. Originally planned as six November 7, 1925, in Gwalior. IHF became
franchises, the Bangalore Franchise eventually member of International Hockey Federation
went unsold. In 2014 the HIL was joined by a in 1928, as the first non-European country
sixth franchise Kalinga Lancersand the
42 “The revenue generation and distribution model of IPL” Dated 9 April 2012, Available at
http://www.sportskeeda.com/cricket/the-revenue-generation-and-distribution-model-of-ipl Accessed on 10
44 Supra note 41
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intention is to increase the franchises to 10 by the end of 2018.45
It is a sanctioned tournament by the International Hockey Federation, wherein it provides a 30 day
window in its calendar so that all international players are able to participate in HIL.46
Hero MotoCorp, signed a multiyear deal with hockey India as the title sponsors of the HIL. The
franchises spent close to USD 1.37 million to buy 49 players from Australia, New Zealand, Spain,
Argentina, Ireland, England, South Africa and India. Other sponsors of the league include Bharti
Airtel and Yes Bank. The broadcasting rights of the League were bagged by ESPN star sports for
a period of for a time period of 5 years. The broadcast rights of Hockey India League and all other
international hockey matches hosted by Hockey India in the country will be with Star Sports from
2016 to 2018 inclusive.47
THE PRO KABBADI LEAGUE
Pro Kabbadi a first significant step of Mashal
Sports takes the sort of kabbadi to new DID YOU KNOW?
professionalism, which benefits all the
stakeholders involved, especially the players. Kabaddi first received international
The bold step has helped in the sports being exposure when India demonstrated the
known worldwide. Pro kabbadi is an eight-city sport during the Berlin Olympics in 1936.
league with games to be played on a caravan
format, with each team playing each other twice in the field which is held between the months of
July and August. The first season of the league took place in 2014. The effort has been backed by
international kabbadi federation (IKF), the Asian Kabbadi Federation and the armature Kabbadi
Federation of India (AKFI), who are also closely associated with organisation and delivery of the
45 “Hockey India League to have 8 tteams by 2016”, The Hindu Dated 27 February 2014 Available at:
Accessed on 10 November 2016
46 Supra note 41
47 “Star Sports extends broadcasting rights of Indian Hockey for three years” The Times of India Dated 20th June
2015 Available at: http://www.indiantelevision.com/television/tv-channels/sports/star-sports-extends-broadcasting-
rights-of-indian-hockey-for-three-years-150620 accessed on 10 November 2016.
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event. The games are aired live by star sports who own both TV and online rights, helps the spread
of the game to million viewers across India and the world.48
The revenue share of organizers, Marshal Sports is 80%, which is a fairly high number. The
marketing partner, World Sports Group gets 10% and the remaining 105 is put across for the
league. Each team owner some of whom have spent between 1 crore to 1.15 crore for the team
rights for 10 years. Their revenue comes from team sponsorship, ticket sales and prize money. 49
The cumulative reach of pro kabbadi league in its first year was 435 million, compared to 560
million for IPL in 2014, which made it the second most watched league in the country. The Indian
super league which also had its first season was closer with 410 million cumulative reach. The
new domestic sports leagues, however, require significant management of efforts over a period of
time to get established and become successful.50
THE INDIAN SUPER LEAGUE
Looking at the success of various other leagues in India and learning from the failures of
Badminton League, Football Sports Development, a company owned by IMG-Reliance, along
with Star India, set up the Indian Super League for football in the year 2014. The aim of the league
was to foster local talent and to feature international stars in hope to aid India in qualifying for the
2026 football world cup.
The inaugural edition of the IHL featured eight city specific franchise teams who paid an annual
franchise fee of Rs, 15 crores. The title sponsorship was bagged by hero motocorp for a term of
three years; a sum of Rs. 100 crore was generated in the centralized sponsorship pool of which 80
crores was distributed equally among the franchises. The franchises are said to have spent a sum
of Rs. 30- 40 crore in the first year. While the franchises expected the revenue levels to be at the
same point as IPL they were left highly disappointed.
48 Available at: http://www.prokabaddi.com/about-prokabaddi accessed on 10 November 2016.
49 Can star do IPL with Pro Kabbadi league” dated 18 july 2014 Available at
League.html accessed on 10th November.
50 Mukul Mudgal and Vindushpat Singhania, “Law and Sports in India” (2016) pg 217
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THE INTERNATIONAL PREMIER TENNIS LEAGUE (IPTL)
While based on the franchise system, the IPTL is played in a never seen before format. It is played
not just in India but in the UAE, Singapore and Philippines. A new franchise and venue for the
second season has been added in the form of Japan Warriors.
The matches are played between current DID YOU KNOW?
champions, tennis legends and upcoming talents
and involve some of the biggest names in the The Medieval form of tennis is termed as
world like Roger Feder, Maria Sharapova, real tennis, a game that evolved over three
Rafael Nadal, Novak Djokovik, Serena Williams centuries, from an earlier ball
etc. game played around the 12th century in
France which involved hitting a ball with
a bare hand and later with a glove
Coca cola entered into a deal with IPTL not just
as the title sponsor but also picked up, 10% equity stake. The part equity part sponsorship deal was
estimated at around 18 crore and structured in a way that coca cola’s sponsorship money would
add up to 10% equity over a certain period of time. The IPTL was broadcasted in almost 125
countries and reaches over 300 million households.
THE INDIAN BADMINTON LEAGUE (IBL)
The IBL was a one of a kind initiative of the badminton Association of India. Originally proposed
by the Maharashtra Badminton Association, the league was commercially managed by the sports
management company Sporty Solutions Private Limited.
The Idea was to make Poona a household phenomenon through a format, which was exiting and
had the ability to keep the viewers on the edge of their seats, whether in the stadia or at home. The
Format of the league was, based on Sundirman Cup format with the only difference of men’s
singles match instead of women’s double match
The success of Saina Nehwal, Jwala Gutta, Ashwani Ponnappa and Parupalli Kashyap, Coupled
with the guidanceof Pullela Gopichand, finally culminated into the Indian Badminton League
2013, the brand value of which was valued at USD 1million, the richest Badminton League in the
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IBL was heavily dependent upon advertising and
ticket sales etc for the central pool. Similarly the
individual franchisees also had the right to recover DID YOU KNOW?
the costs and make profits. Broadly the revenues
came for the franchisees fees, TV rights sale, on the concept of contemporary
ground advertising and ticket sales etc. for the badminton was developed by the British
central pool. Similarly, the individual franchisees in the 1800's from a game called “poon”
played in India
also had the right to monetize various advertising
avenues in their respective home venues as well as
through apparel partnership, on ground advertising etc.
While, the IBL was a runaway success in its first Year, ramping up impressive numbers on
television and the viewers appreciating the format to a great extent, it was not without issues from
an operational standpoint. Some of the major issues surrounding IBL were:51
• Huge sums were spent on the venues at the last minute since no physical inspection of the
venues had been done and the agreements weren’t even in place prior to assigning the
• Local associations at the venue failed to lend any form of support which worsened the
situation with the lack of staff.
• Adfactors, the appointed media agency was not proactive and lacked the skill to be able to
handle the media in the right manner.
• A couple. This was made evident in Delhi, where the requested for 100 accreditations to
• The majority of the state associations were allegedly of little to no help during the event.
Instead of providing assistance, they made matters extremely difficult for the venue
• There were complaints received about the distance of hotels from the venues, which in
particular led to further exhaustion of the players.
51 Mukul Mudgal and Vindushpat Singhania, “Law and Sports in India” (2016) pg 220
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• Signage installations were often delayed
• No itemized budget was put in place before the start of the league neither was any planning
or research done on the kind of expenses involved in the organisation of a league.
In spite of these major troubles, that faced the event, the league instilled hope for more such leagues
in the future. With the emergence of more and more such leagues in the last three years, several
sports are now emerging into the limelight. Several experimentations are being done to the formats
and the games are being modified in ways to attract more and more players/viewers. These leagues
are helping in attracting the masses towards sports by making it a viable and lucrative career option
for many Indians today.
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POINTS TO REMEMBER
❖ IPL was introduced by the BCCI in the Year 2008.
❖ The revenue for IPL is generated in a centralized and decentralized manner.
❖ The hockey India league was initiated in the year 2013 and is played between five
❖ Hero MotoCorp is the title sponsor with Bharti Airtel and Yes Bank being the other
prominent sponsors while the broadcasting rights were bagged by ESPN.
❖ Pro kabbadi is an eight-city league with games to be played on a caravan format, the
first season of which took place in the year 2014.
❖ The Indian Super League was set up in the year 2014 with the aim to foster local
talent in hopes of making India qualify the 2026 world-cup.
❖ IPTL was founded in the year 2013 and is played not just in India but UAE,
Singapore, and Philippines.
❖ Coca cola is the title sponsor and owns 10% equity stake.
❖ The Indian Badminton League was founded in the year 2013.
❖ The Format of the league was, based on Sundirman Cup format.
❖ It is the richest Badminton League in the world.
❖ Some of the major issues facing the league were, the inadequacy of venues,
inexperienced media partners and the distance between hotels and venues.
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• Mukul Mudgal and Vidushpat Singhania, “Law and Sports in India” (2016)
• “Awards and Awardees” Available at: http://yas.nic.in/sports/awards-awardees Accessed
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Common Management, Edition 2005, Jaypee Brothers New Delhi.
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of-the-cas.html Accessed on 15 November 2016
• A Nelson, ‘When, Where and Why does the State Intervene in Sports: A Contemporary
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Accessed on 15 November 2016
• B. Majumdar and N. Mehta, India and the Olympics
• “National Olympic Committees” Available at: https://www.olympic.org/ioc-governance-
national-olympic-committees Accessed on 17th November 2016
• Article 27, International Olympic committee Charter
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• “Homepage” Available at: http://nada.nic.in/View/Homepage.aspx Accessed on 17th
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http://yas.nic.in/sites/default/files/File371.pdf accessed on 5 November 2016
• Emergence of sports law in India by Gaurang Kanth., Indian Law Journal
• Corruption in sports in India by Ashutosh Misra and Abhishek Vikram
• The Prevention Of Sports Fraud Bill, 2013: A Messiah To Indian Sports? By Ashuti
Panjwani And Devika A. Kumar, International Journal For Legal Developments And
Allied Issues Volume 1 Issue 3 [Issn – 2454-1273]
• Narendra Batra v Union of India (2009) ILR 4 Del 280
• Corruption in sports in India by Ashutosh Misra and Abhishek Vikram
• Scott Rosner and Kenneth L. Shropshire, “The Business Of Sports”(2011) Jones and
• “The revenue generation and distribution model of IPL” Dated 9 April 2012, Available at
ipl Accessed on 10 November 2016
• “Hockey India League to have 8 tteams by 2016”, The Hindu Dated 27 February 2014
Available at: http://www.thehindu.com/sport/hockey/hockey-india-league-to-have-eight-
teams-by-2016/article5732742.ece Accessed on 10 November 2016
• “Star Sports extends broadcasting rights of Indian Hockey for three years” The Times of
India Dated 20th June 2015 Available at: http://www.indiantelevision.com/television/tv-
150620 accessed on 10 November 2016.
• “About Pro Kabbadi League” Available at: http://www.prokabaddi.com/about-prokabaddi
accessed on 10 November 2016.
34 | P a g e
• Can star do IPL with Pro Kabbadi league” dated 18 july 2014 Available at
with-Pro-Kabaddi-League.html accessed on 10th November.
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