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Issues: (i) whether the Board was amenable to writ jurisdiction under Article 226 though not "State" under Article 12; (ii) whether Gurunath Meiyappan and Raj Kundra were team officials and whether betting was proved against them; (iii) whether the misconduct justified sanctions against the concerned persons and their franchises under the IPL framework and franchise agreement; (iv) whether the alleged cover up by N. Srinivasan was proved; (v) whether the amendment to Regulation 6.2.4 excluding IPL and Champions League Twenty 20 from the prohibition on administrators' commercial interests was valid; (vi) whether further probe was required into the conduct of Sundar Raman.
Issue (i): Whether the Board was amenable to writ jurisdiction under Article 226 though not "State" under Article 12
Analysis: The Board was not treated as "State" within Article 12, but its monopoly and pervasive control over cricket, its regulation of selection, discipline, infrastructure and related commercial activities, and the public character of those functions brought its actions within judicial review under Article 226. The distinction between Article 12 and Article 226 was maintained, but public functions performed by a non-statutory body were held reviewable on standards applicable to public action.
Conclusion: The Board was not "State" under Article 12, but it was amenable to writ jurisdiction under Article 226.
Issue (ii): Whether Gurunath Meiyappan and Raj Kundra were team officials and whether betting was proved against them
Analysis: On the material collected by the probe committee, both persons were found to be accredited team officials / persons subject to the IPL regulations. The committee's findings that Meiyappan and Kundra indulged in betting were supported by call records, statements and other material, and the standard applicable to the disciplinary probe did not require strict rules of evidence. The proceedings were held to be fair and the committee's conclusions were not found perverse.
Conclusion: The findings that Gurunath Meiyappan and Raj Kundra were team officials and had indulged in betting were affirmed.
Issue (iii): Whether the misconduct justified sanctions against the concerned persons and their franchises under the IPL framework and franchise agreement
Analysis: The Operational Rules, Anti-Corruption Code and Code of Conduct permitted sanctions including suspension, financial penalties, debarment and other measures against a person found guilty of betting, and in appropriate cases sanctions could extend to the team or franchisee. The franchise agreement also permitted termination where an owner or franchisee acted in a manner causing material adverse effect on the reputation or standing of the league or the game.
Conclusion: Sanctions against the concerned individuals and possible action against the franchises were held permissible.
Issue (iv): Whether the alleged cover up by N. Srinivasan was proved
Analysis: The circumstances relied upon raised suspicion, but there was no sufficient material to prove that Srinivasan attempted a cover up or withheld incriminating material. The probe committee had not recorded a conclusive finding of his complicity in betting or match fixing, and suspicion was held insufficient for a finding of misconduct on this charge.
Conclusion: The allegation of cover up against N. Srinivasan was not proved.
Issue (v): Whether the amendment to Regulation 6.2.4 excluding IPL and Champions League Twenty 20 from the prohibition on administrators' commercial interests was valid
Analysis: The amendment was tested on competence, procedure and legality. Though the authority was competent and procedural objections were rejected, the substantive effect of the amendment was to permit and perpetuate a conflict between the administrator's duty and commercial interest. Applying the principles of natural justice, fairness, probity and public policy, the Court held that a rule enabling such a conflict in public functions could not stand.
Conclusion: The amendment to Regulation 6.2.4 was held void and ineffective.
Issue (vi): Whether further probe was required into the conduct of Sundar Raman
Analysis: The record did not contain a clear finding exonerating or indicting him, but the material raised serious suspicion about his knowledge of and proximity to betting-related persons and about his inaction after receiving information. In the interests of a complete and credible inquiry, further investigation was considered necessary.
Conclusion: Further probe into Sundar Raman's conduct was directed.
Final Conclusion: The judgment upheld writ scrutiny over the Board's public functions, confirmed the betting findings against the two team officials, struck down the conflict-of-interest amendment, declined to accept the cover-up allegation against Srinivasan, and ordered further inquiry and constitution of an independent committee for sanctions and reforms.
Ratio Decidendi: A body that performs pervasive public functions is amenable to writ review under Article 226 even if it is not "State" under Article 12, and a rule that positively permits a conflict between public duty and commercial interest in the discharge of such functions is contrary to natural justice, fairness and public policy.
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