Delhi High Court Refers Six Football Clubs’ Election and Disciplinary Disputes to Arbitration, Directs Expedited Interim Hearing Before Impending Contested Delhi Soccer Association Polls
Delhi High Court Transfers Six Connected Football Club Petitions to Sole Arbitrator, Converts Section 9 Pleas into Section 17 Applications Before Scheduled Delhi Soccer Elections
Facts
Six connected petitions under Section 9 of the Arbitration and Conciliation Act, 1996 were brought by Ajmal FC, Goodwill FC, Hans Capital FC, Growing Stars SC, Ahbab FC and Mughal SC, with their respective co-petitioners, against Anuj Gupta and others. The disputes arose from disciplinary measures affecting club membership and participation in the Delhi Soccer Association (DSA) elections scheduled for 18 October 2026. In the earlier connected Ajmal proceeding, the petitioners alleged that a communication dated 26 September 2026 indefinitely expelled Ajmal FC and banned its co-petitioner from football activities for two years, without notice or hearing. Ajmal FC was also allegedly omitted from the draft electoral list dated 1 October 2026. By an order dated 7 October 2026 in a connected commercial petition, the Court had already appointed Ms. Manisha Suri as Sole Arbitrator and referred the request for interim protection to her under Section 17.
Issues
Whether the six connected petitions, arising from substantially the same DSA disciplinary and election controversy, should proceed before the Sole Arbitrator already appointed; whether the Section 9 applications should be considered as Section 17 applications; and how their interim-protection requests should be addressed given the imminent 18 October election. The Court did not determine whether the expulsions, suspensions or electoral exclusions were lawful.
Petitioner’s Arguments
In the antecedent Ajmal proceedings, the petitioners asserted that the DSA President’s tenure had expired on 19 March 2026 and that the purported disciplinary action violated the association’s constitution and statutes. They alleged absence of a show-cause notice and opportunity of hearing, and apprehended exclusion from voting or participation in the upcoming DSA election. The connected clubs also sought urgent judicial intervention concerning disciplinary action and its consequences for membership and electoral rights.
Respondent’s Arguments
The order records that the petitioners and Respondent No. 2 in the earlier related proceeding consented to arbitration and waived the agreed appointment procedure. It does not substantively record or decide a detailed defence by the respondents to the disciplinary allegations in these six petitions. The Court expressly preserved the parties’ objections, including those concerning arbitrability and the tribunal’s jurisdiction, for determination by the Arbitrator.
Analysis of the Law
Section 9 empowers a court to grant interim measures in aid of arbitration; Section 17 confers power upon the arbitral tribunal to consider interim measures once constituted. The earlier order, reproduced in the present judgment, expressly provided that the Section 9 application would be treated as an application under Section 17 following constitution of the tribunal. Applying the same procedural approach to connected disputes promoted consistent adjudication without prejudging the parties’ substantive or jurisdictional positions. The Arbitrator’s appointment in the related proceeding was subject to disclosures under Section 12(2) and the arbitration was to be administered under the Delhi International Arbitration Centre’s rules and fee schedule.
Precedent Analysis
The brief judgment does not cite or analyse a reported precedent. Instead, it relies on the connected High Court order dated 7 October 2026, which identified a prima facie arbitration clause, appointed Ms. Manisha Suri as Sole Arbitrator by consent of the relevant parties and assigned interim protection to arbitral consideration. This is a procedural disposition; it does not establish a judicial finding on DSA elections, the competence of office-bearers or the validity of any disciplinary sanction.
Court’s Reasoning
Justice Om Prakash Shukla noted that all six matters concerned substantially the same controversy, including disciplinary measures in the context of DSA elections and their effect on the clubs’ membership and electoral rights. In the interest of justice and consistency, separate adjudication was unnecessary when a Sole Arbitrator had already been constituted for the common factual matrix. The Court directed the petitioners to supply the complete records to the Arbitrator and asked her to consider interim applications expeditiously and endeavour to make an appropriate order before the scheduled election. The Court consciously expressed no view on the merits and left all rights and objections open.
Conclusion
On 14 October 2026, the Delhi High Court disposed of O.M.P.(I) Nos. 15–20 of 2026 by referring the six connected disputes to Ms. Manisha Suri, the already-appointed Sole Arbitrator. Their Section 9 petitions were directed to be treated as Section 17 applications, with urgent interim consideration requested ahead of the 18 October DSA election. No reinstatement, voting entitlement, stay of disciplinary action or other substantive interim protection was ordered by the Court in this judgment; those matters were left to the arbitral tribunal.
Case: Ajmal FC & Anr. v. Sh. Anuj Gupta & Ors. (with Goodwill FC, Hans Capital FC, Growing Stars SC, Ahbab FC and Mughal SC petitions)
Court: High Court of Delhi at New Delhi
Case Number: O.M.P.(I) Nos. 15, 16, 17, 18, 19 and 20 of 2026
Judge: Justice Om Prakash Shukla
Date: 14 October 2026 (oral judgment)
Result: All six petitions disposed of; referred to existing Sole Arbitrator; Section 9 applications to be treated as Section 17 applications; merits left open.
