[Cites 7, Cited by 0]
Delhi High Court
Rajasthan Table Tennis Association vs Table Tennis Federation Of India And Ors on 12 March, 2026
$~85
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ W.P.(C) 2185/2026 and CM APPL. 10581-10582/2026
Date of decision: 12.03.2026
IN THE MATTER OF:
RAJASTHAN TABLE TENNIS ASSOCIATION
.....PETITIONER
(Through: Mr. Deepak Biswas, Mr. Siddharth Swain, Mr. Mayank
Rai, Advocates.)
versus
TABLE TENNIS FEDERATION OF INDIA AND ORS
.....RESPONDENTS
(Through: Mr Sunil Dalal Sr Advocate Along with Mr.Dhruv
Sheoran, Mr.Rajiv Singh , Mr.Ankit Rana , Ms.Shipra Bali,
Mr.Sarthak Malhotra adn Mr. Anirudh Singh., Advocates for R-1.
Mr. Aman maheshwari, Mr. Yash Chaturvedi, Mr. Saurabh Oberoi,
Advocates for R-2 and 3.
Mr. Chetan Sharma, ASG, with Mr. Udit Dedhiya SPC,
Harshvardhan Jha GP Ms Apurva Sachdev Adv Mr Preyansh Gupta
adv Mr. Amit Gupta, Mr. R. V. Prabhat Shubham Sharma and Mr.
Yash Wardhan Sharma, Mr. Naman, Advocates for R-4.
Mr. Harshvardhan Jha G.P., Advocate for Respondent No.4.)
CORAM:
HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV
JUDGEMENT
PURUSHAINDRA KUMAR KAURAV, J. (ORAL)
1. The instant petition is for the following reliefs:-
"A. Issue a writ of certiorari or any- other appropriate writ, order or
direction in the nature thereof setting aside and quashing the Impugned
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
Ord.ers dated'-28.01.2026 passed by the EC of Respondent No;- 1 and
ratified in the AGM of the same date;
B. Issue a writ of mandamus and/or any other appropriate writ, order or
direction in the nature thereof directing Respondent No. 1 to restore
status quo ante as it existed prior to the passing of the Impugned Orders
and to withdraw and retract the recognition and affiliation granted to
RSTTA and RTTA-1 i.e., the faction led by Respondent Nos. 2 & 3;
C. Issue a writ of certiorari and/or mandamus or -any other appropriate
writ, order or direction in the nature thereof directing Respondent No. 1
to maintain neutrality and to refrain from taking any coercive,
administrative or consequential action in relation to the inter se disputes
between the rival factions of RSTTA, including matters of recognition,
affiliation and representation, during the pendency of proceedings before
the Hon'ble High Court of Rajasthan and until final adjudication thereof
by the competent judicial forum."
2. The facts of the case would indicate that on 11.02.2023, the elections
of Rajasthan State Table Tennis Association ("RSTTA") were conducted at
Jodhpur, pursuant to which respondent nos. 2 and 3 were allegedly elected
as Secretary General and President respectively. On 17.02.2023, the District
Sports Officer, Jodhpur issued certificate recognizing respondent nos. 2 and
3 as office-bearers and on 20.03.2023, Rajasthan Olympic Association
issued a certificate recognizing respondent nos.2 and 3 as office bearers.
3. Thereafter, the stakeholders, including, district associations, players
and officials, challenged the validity and legality of the elections and
submitted representation to State authorities. The said challenge led to the
formation of two factions within the RSTTA i.e.--first faction being led by
respondent nos. 2 and 3 (referred to as "RTTA-1") and the second faction
led by Mr.Ranjit Malick and Mr. Mahendra Singh Umat (referred to as
"RTTA-2").
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
4. Respondent no.1 allowed the players from both factions to participate
in the national championship without granting exclusive recognition.
5. The Registrar, Co-operative Society has rejected the complaint filed
by Mr. Ranjit Malick on 23.02.2024. Thereafter, on 31.05.2024, respondent
no.1 appointed an Enquiry Committee to investigate the disputes between
rival factions and the said Committee has submitted its report
recommending recognition of RTTA-1 faction led by respondent nos. 2 an 3
on 05.07.2024. The facts would further indicate that the Department of
Sports and Youth Affairs rejected the appeal filed by Mr. Malick impugning
the order dated 23.02.2024 passed by the Registrar, Co-operative Society.
6. Thereafter, the order dated 28.10.2024 was assailed before the High
Court of Rajasthan in S.B. Civil Revision Petition No. 368 of 2024, pursuant
to which the Court remanded the issue concerning the validity of the
RSTTA elections to the Department of Sports and Youth Affairs for fresh
consideration. On 02.06.2025, Rajasthan State Sports Council convened a
meeting of rival factions, stakeholders and parents and the said Council has
issued a communication dated 16.06.2025 seeking initiation of dissolution
and constitution of ad-hoc committee to oversee affairs of RSTTA.
Respondent no.2 on behalf of RTTA-1 faction, had challenged the said
communication dated 16.06.2025 before the High Court of Rajasthan at
Jaipur (S.B. Civil W.P. No.9899/2025), whereby, the directions dated
16.06.2025 were stayed.
7. On 28.01.2026, the Executive Committee of respondent no.1 passed
the impugned order vide which the respondent no.1 has proceeded to accord
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
recognition to the RTTA-1. According to the petitioner, it first became
aware of the impugned recognition order on 05.02.2026. The minutes of
AGM meeting dated 28.01.2026 were circulated, confirming post facto
approval of the impugned decision on 09.02.2026. Hence, the petitioner has
filed the instant writ petition.
8. Mr. Deepak Biswas, learned counsel for the petitioner while making
submissions to invoke the jurisdiction of this Court, points out that the effect
of the impugned decision is all over the country and the decision itself has
been taken in Delhi, therefore, the petitioner has a right to approach this
Court. He also submits that the dispute which is pending before the High
Court of Judicature for Rajasthan relates to the factions of the respondent
no.1. However, in the instant case, the petitioner's entitlement has been
wrongly denied by respondent no.1.
9. Mr. Sunil Dalal, learned senior counsel for respondent no.1 points out
from Annexure P-11 that a writ petition between two fractions of Rajasthan
Table Tennis Association is pending for consideration before the High Court
of Judicature for Rajasthan, Bench at Jaipur. He submits that the petitioner
belongs to the State of Rajasthan and is seeking directions to represent the
said State in all State and National Sports events. According to him, the
entire effect of the decision has been predominantly felt at the State of
Rajasthan.
10. It appears that the sole reason to invoke the jurisdiction of this Court
seems to be that respondent no. 1 is situated within the jurisdiction of this
Court, and naturally, therefore, the impugned order also has been passed in
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
Delhi.
11. This Court in The Indure Pvt. Ltd. v. Government of NCT of Delhi,1
took note of the decisions in Shristi Udaipur Hotels v. Housing and Urban
Development Corp.,2 Riddhima Singh v. Central Board of Secondary
Education,3 Smt. Manjira Devi Ayurveda Medical College and Hospital v.
Uttarakhand University of Ayurveda and Ors.,4 Michael Builders and
Developers Pvt. Ltd. v. National Medical Commission and Ors.,5 which
declare that the situs of the head office/registered office of the respondent,
does not determine whether the Court has the requisite territorial jurisdiction
to entertain a writ petition.
12. The Court in The Indure Pvt. Ltd. importantly noted, at para. 36:
"36. A petitioner who approaches this Court to assail a decision of an
authority situated in Delhi, when the underlying cause for the said decision
lies elsewhere, effectively attempts to make this High Court a mini-pan-
India Superior Court exercising jurisdiction over all events which take
place throughout this Country. There is no gainsaying with the proposition
that every High Court is competent to adjudicate upon a lis which arises
from events or actions taking place within its territory. Merely because the
ultimate order, which is based on events taking place outside Delhi and
takes cognizance of actions outside of Delhi, is passed within the
jurisdiction of this Court, a writ petition ought not be entertained by this
Court."
13. On the issue of a claimant approaching this Court on the sole-ground
of the respondent-authority, an arm of the union government, being situated
within the jurisdiction of this Court, it was observed at para. 37-38:
2026:DHC:1605.
2014 SCC OnLine Del 2892.
2023 SCC OnLine Del 7168.
2024:DHC:6903-DB
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
"37. Naturally, being the capital of the Country, various authorities and
bodies having pan-India jurisdiction would be located within the
jurisdiction of this Court. Merely because the decision making authority
happens to be in Delhi, ought not to be the sole reason to entertain a lis in
this Court. The decision, no doubt, may be passed in the national capital,
but it is usually against persons situated outside Delhi; and even more
importantly, for actions which took place beyond the borders of this Court.
The act of giving a hearing in Delhi, or the passing of an order in Delhi, is
merely a result of a body/authority being situated in the national capital, it
has nothing to do with the lis, the offending action, the legal injury or the
foundational facts on the basis of which action is being taken.
38. The case-law cited above, makes repeated reference to "dominant
facts", and facts which are "material, essential and integral" to the lis in
question. In most cases, the fact that the order is passed, or the head office
is located, or that opportunity of hearing was afforded, within the
jurisdiction of this Court is completely immaterial, non-essential, and non-
integral to the dispute in question. Any of the aforenoted three aspects could
very well have taken place in another part of the Country, it is for the sole
reason that Delhi is the national capital, that, in most cases these factors get
connected to the jurisdiction of this Court. From another lens, it may be
seen that regardless of what the underlying facts or legal
injury/infringement may be, the order impugned would, in an overwhelming
number of cases be passed from Delhi. If this be the case, can this constant
factum, which shall remain present in each case, be considered a "dominant
fact" or a "material, essential and integral" fact? The answer must be in
the negative."
14. Ultimately, the Court concluded that the substance of a matter must be
adjudged, and not the unchanging constant which is present in every petition
against a State-authority, to arrive at a conclusion on whether to entertain a
petition in the context of territorial jurisdiction and forum non conveniens.
At para. 42 this Court observed:
"42. It is the substance of the matter which the Court must consider in
determining the connection with Delhi. An order being passed by an
authority in Delhi is an unchanging constant. This static/uniform facet,
which is unmoved by the nature of the lis, ought not to determine where
territorial jurisdiction would lie."
2024:DHC:7146.
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
15. It be, thus, noted that the petitioner admittedly, belongs to the State of
Rajasthan and seeks to represent the said State in all State and National
Sports events. A perusal of the factual narration contained in para 2-7 of this
Order would reveal that the material, essential and integral cause of action
has arisen within the State of Rajasthan. In the facts of the instant case, there
may, arguably, be a part of cause of action which has arisen in Delhi,
however, the same should not be the sole reason to entertain the instant
petition.
16. The Supreme Court in the case of Kusum Ingots & Alloys Ltd. v.
Union of India and Anr.,6 has held that even if a small part of cause of
action arises within the territorial jurisdiction of the High Court, the same by
itself may not be considered to be a determinative factor compelling the
High Court to decide the matter on merit. In appropriate cases, the Court
may refuse to exercise its discretionary jurisdiction by invoking the doctrine
of forum conveniens. The material portion of the aforenoted decision reads
as under:
"Forum conveniens
30. We must, however, remind ourselves that even if a small part of
cause of action arises within the territorial jurisdiction of the High
Court, the same by itself may not be considered to be a determinative
factor compelling the High Court to decide the matter on merit. In
appropriate cases, the Court may refuse to exercise its discretionary
jurisdiction by invoking the doctrine of forum conveniens. [See Bhagat
Singh Bugga v. Dewan Jagbir Sawhney [AIR 1941 Cal 670 : ILR
(1941) 1 Cal 490] , Madanlal Jalan v. Madanlal [(1945) 49 CWN 357 :
AIR 1949 Cal 495] , Bharat Coking Coal Ltd. v. Jharia Talkies & Cold
Storage (P) Ltd. [1997 CWN 122] , S.S. Jain & Co. v. Union of
India [(1994) 1 CHN 445] and New Horizons Ltd. v. Union of
(2004) 6 SCC 254.
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
India [AIR 1994 Del 126] .]"
17. In view of the aforesaid, the Court declines to entertain the instant
writ petition. The same is accordingly dismissed.
18. Liberty is, however, granted to the petitioner to approach the Court of
competent jurisdiction, if so advised.
19. All rights and contentions of the parties are left open.
(PURUSHAINDRA KUMAR KAURAV)
JUDGE
MARCH 12, 2026
Nc
Signed By:NEHA CHOPRA Signed
Signing Date:17.03.2026 By:PURUSHAINDRA
11:33:36
KUMAR KAURAV
