IN THE HONBLE HIGH COURT OF DELHIAT NEW DELHI

(CIVIL ORIGINAL JURISDICTION)

Writ Petition (Civil) No. .................... of 2016
In the matter of:
KIRTI AZAD & OTHERS

PETITIONERS
VERSUS

DELHI & DISTRICT CRICKET ASSOCIATION

& OTHERS
RESPONDENTS
INDEX
PARTICULARS

SL. No.
1.

Urgent Application

3.

Notice of Motion

4.

Memo of Parties

5.

Synopsis & List of Dates

6.

Writ Petition under Articles 226 & 227 of the Constitution

7.

of India with Affidavit

ANNEXURE P-1

A true copy of the Certificate of Incorporation of

Respondent No. 4 dated 19.02.1936 being No. 407 of
1936-1937.
8.

ANNEXURE P-2
A true copy of the Memorandum of Association of
the DDCA.

9.

ANNEXURE P-3
A true copy of the Articles of Association.

10.

ANNEXURE P-4
A true copy of the Order dated ______ passed by this
Honble High Court in in Co. A. (SB) No. 53 of 2015
being Gurpreet Singh v. DDCA.

11.

ANNEXURE P-5
A true copy of the Internal Fact Finding Committee
Report dated 29.12.2014 Chaired by Sh. Sunil Jain.

PAGE NO.

12.

ANNEXURE P-6
A true copy of the Internal Auditor of V.K. Bajaj &
Co.

13.

ANNEXURE P-7
A true copy of the letter dated 20.11.2015 of the
Institute of Chartered Accountants confirming the
misconduct of Sanjay Bhardwaj & Co.

14.

ANNEXURE P-8
A true copy of the letter dated 27.07.2015 of the
Ministry of Sports and Youth Affairs.

15.

ANNEXURE P-9
A true copy of the Report of the SFIO dated
21.03.2013.

16.

ANNEXURE P-10
A true copy of the Judgment dated 13.04.2015 of the
Chief Information Commission in File No.
CIC/LS/C/2012/000714 dated 13.04.2015.

17.

ANNEXURE P-11
A true copy of the Report dated Nil of the
Committee constituted by the Government of the
NCT of Delhi.

18.

ANNEXURE P-12
A true copy of the Letter dated 23.10.2015 by the CBI
to the Officer Bearers of the DDCA.

19.

ANNEXURE P-13
A true copy of the Notification being No. F.
01/66/2015/DOV/15274-15281 dated 22.12.2015.

20.

ANNEXURE P-14
A true copy of the Report of this panel dated
19.09.2015by Shri. G.B. Thareja and Shri. BabuLal,
Former District Judges.

21.

ANNEXURE P-15
A true copy of the Report dated 04.01.2016 of the
Justice Lodha Committee.

22.

ANNEXURE P-16

A true copy of the Report submitted by Justice

MukulMudgal.
23.

ANNEXURE P-17
A true copy of the letter dated 13.09.2015.

24.

ANNEXURE P-18
A true copy of the letter being No. F.18 (5)/ETO/1415/2815/3371 dated 21/23.10.2015.

25.

C.M. No. _______ of 2015 :

An Application for Directions with Affidavit.

26.

Vakalatnama

27.

Court Fee

NEW DELHI
DATE: 01.02.2016

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN
BLOCK, OLD LAWYERS
CHAMBERS, SUPREME
COURT OF INDIA,
NEW DELHI - 01
Tel.: +91 9953557798

IN THE HONBLE HIGH COURT OF DELHIAT NEW DELHI

(CIVIL ORIGINAL JURISDICTION)
Writ Petition (Civil) No. .................... of 2016
In the matter of:
KIRTI AZAD & OTHERS

PETITIONERS
VERSUS

DELHI DISTRICT CRICKET ASSOCIATION

& OTHERS
RESPONDENTS
APPLICATION OF URGENCY
To,
The Registrar,
High Court of Delhi at New Delhi,
New Delhi.
Dear Sir,
Kindly treat the present petition as urgent in accordance with the
provisions of Rule 9, Chapter 3A of the Rules and Orders of the
High Court. The reason why urgency arises in the present case is
that the Respondent No. 1, by its inaction, has ensured that the
administration of cricket in the NCT of Delhi has been gravely
affected.Further, by the Order of this Honble Court, the Respondent
No. 1 has lost the opportunity to host an international cricket match.
Hence, it is most respectfully requested that the present matter be
listed urgently before the Honble Court.
AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
NEW DELHI
OLD LAWYERS CHAMBERS,
SUPREME COURT OF INDIA,
DATE: 01.02.2016
NEW DELHI - 01
Tel.: +91 9953557798
Yours faithfully,
IN THE HONBLE HIGH COURT OF DELHIAT NEW DELHI
(CIVIL ORIGINAL JURISDICTION)

Writ Petition (Civil) No. .................... of 2016

In the matter of:
KIRTI AZAD & OTHERS

PETITIONERS
VERSUS

DELHI DISTRICT CRICKET ASSOCIATION

& OTHERS
RESPONDENTS
NOTICE OF MOTION
To,

1.

Delhi & District Cricket Association

.. Respondent No. 1

Sir /Madam,

PLEASE TAKE NOTICE that the present Writ Petition is being filed
on behalf of the Petitioner in the matter of Gammon India Limited
Vs. Delhi Metro Rail Corporation Limited & Others seeking interim
orders. The advance copy of the Writ Petition is being served on you
and you are requested to be present in the Court on

.02.2016.

Thanking You,

Yours faithfully

NEW DELHI
DATE: 01.02.2016

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
OLD LAWYERS CHAMBERS,
SUPREME COURT OF INDIA,
NEW DELHI - 01
Tel.: +91 9953557798

IN THE HONBLE HIGH COURT OF DELHIAT NEW DELHI

(CIVIL ORIGINAL JURISDICTION)
Writ Petition (Civil) No. .................... of 2016
In the matter of:
KIRTI AZAD & OTHERS

PETITIONERS
VERSUS

DELHI DISTRICT CRICKET ASSOCIATION

& OTHERS
RESPONDENTS
MEMO OF PARTIES
IN THE MATTER OF:
1.

Shri. Kirti Azad,

Petitioner No. 1

Member of Parliament (LS),

25, Pt. Ravi Shankar Shukla Lane,
2.

New Delhi 110001.

Shri. Bishan Singh Bedi,

Petitioner No. 2

Cricket Abode,
Village Jonapur, Mehruli,
3.

New Delhi Shri. AkashLal,

Petitioner No. 3

1196, Sector A, Pocket B,

4.

VasantKunj, New Delhi 110070.

Shri. Maninder Singh,

Petitioner No. 4

52, MausamVihar,
5.

Delhi 110052.
Gurucharan Singh,

Petitioner No. 5

H-279, Rama Krishna Vihar Apts.,

6.

I.P. Extension, Delhi 110092.

Sameer Bahadur,
A-51, IInd Floor,
SwasthyaVihar,
New Delhi 110092.

Petitioner No. 6

1.

Vs.
Delhi & District Cricket Association,

Respondent No. 1

Through its President,

Feroze Shah Kotla Grounds,
2.

New Delhi 110020.

Union of India

Respondent No. 2

Through Secretary,
Ministry of Urban Development,
3.

UdyogBhavan, New Delhi.

Government of NCT of Delhi

Respondent No. 3

Through Chief Secretary,

4.

Delhi Secretariat, New Delhi.

Central Bureau of Investigation,

Respondent No. 4

Through its Director,

CGO Complex,
5.

Lodhi Road, New Delhi 110003.

Municipal Corporation of Delhi,

Respondent No.5

6.

New Delhi.
Shri. Sneh Prakash Bansal,

Respondent No.6

President DDCA,
C-66, Friends Colony (East)
7.

New Delhi-110065
Shri. NarendraBatra,

Respondent No.7

W-11, Greater Kailash 2,

8.

New Delhi Shri. C.K. Khanna,

Respondent No.8

Vice President DDCA

& Vice President BCCI,
192, Kailash hills,
9.

New Delhi-110065
Shri. Chetan Chauhan,
Vice President,
D-202, Nagarjun Appt.,
MayurVihar Phase-I,
New Delhi-110096

Respondent No.9

10.

Shri. Anil Khanna,

Respondent No. 10

Hony. General Secretary,

274, Kailash Hills,
11.

New Delhi-110065.
Shri. Sunil Dev,

Respondent No. 11

Hony. Sports Secretary (DDCA) &

Vice Chairman (NCA),
B-531, New Friends Colony,
12.

New Delhi- 110065.

RavinderManchanda,

Respondent No. 12

Hony. Treasurer,
D-281, Defence Colony,
13.

New Delhi-110024
Shri. Ravi Jain,

Respondent No. 13

Hony. Joint Secretary (Club),

C-II/32, Bapra Nagar,
14.

New Delhi-110003.
Shri. Dinesh Saini,
Hony.

Joint Secretary

Respondent No. 14
(Company

Affairs),
16/9 West Patel Nagar,
15.

New Delhi-110008
Shri. Dinesh Kumar Sharma,
Hony.

Joint Secretary

Respondent No. 15

(Company

Affairs),
WZ-459/1 Street No.24 Shiv Nagar,
16.

Tilak Nagar, New Delhi-58,

Shri. ArunJaitley,

Respondent No. 16

Former President DDCA,

Member of Parliament (RS),
Minister

for

Affairs

and

Finance,

Corporate

Information

Broadcasting,
A-44, Kailash Colony,

and

New Delhi 110048.

17.

Board for Cricket Control in India,

Respondent No. 17

Through its Secretary,

Shri. Anurag Thakur,
18.

14, Janpath, New Delhi 110001.

Vinod Tihara,

Respondent No. 18

B-55, Antriksh Apartments,

Sector 14, Extention,
D-3, Rohini, Delhi 110085

NEW DELHI
DATE: 01.02.2016

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK, OLD LAWYERS
CHAMBERS, SUPREME COURT OF INDIA,
NEW DELHI - 01
Tel.: +91 9953557798

SYNOPSIS
The present writ petition under Article 226 of the Constitution
of India is being filed by Members of Respondent No. 1, being
aggrieved by the financial mismanagement and the general
mismanagement of the affairs of the Respondent No. 1 Delhi &
District Cricket Association by the incumbent Working Committee
and are seeking a writ in the nature of mandamus, by which the

10

illegal activities of some of the Members of the Working Committee

of Respondent No. 1 may be investigated by a SIT or the a court
monitored investigation by Respondent No. 4 Central Bureau of
Investigation, and for the appointment of an administrator to
administer Respondent No. 1, and to ensure the preparation of
electoral rolls, and for the conduct of fresh elections to the working
committee of Respondent No. 1.
The Petitioners apprehend that the CBI (Respondent No. 4 )
will not be able to conduct a free and fair investigation of allegations
made against the DDCA, especially since ArunJaitley (Respondent
No. 16), during whose tenure as President most of the allegation
pertain to, is presently a senior Cabinet Minister in the Union
Council of Ministers and is also the leader of the House is the Rajya
Sabha. Further, it is submitted, the Honble Supreme Court in the
case of VineetNarian v. Union of India, (1996) 2 SCC 199, noting that
influential persons are involved, directed the CBI and the ED that no
settlement or compounding of offence ought to happen without the
prior leave of the Court. Further, the Court held that the CBI and
other government agencies must expedite their actions to complete
the task and prevent pendency of the investigation, due to the great
public interest involved in the matter. It is submitted that the same
parameters ought to be applied here.
The Government of the NCT of Delhi (Respondent No. 3),
upon the complaints made by the Petitioners herein and Shri. Kirti

Azad, Member of Parliament (Lok Sabha), constituted a Committee

to

inquire

into

the

complaints

on

12.11.2015

under

the

Chairpersonship of Shri. Chetan B. Sanghi, Principal Secretary,

PWD/UD. The Committee, in its report dated nil made the
following recommendations:
6.1

Keeping the aforesaid in view as well as the

various complaints that are under investigation in a

variety of fora, the following recommendations are
made:6.2.1

DDCA is responsible for promotion and

development of cricket and for the fate of the budding

crickets in the State of Delhi. It is therefore necessary
that affairs of DDCA should be managed primarily by
cricketers.
6.2.2 BCCI, being a parent body governing cricket in
India, has recognized DDCA as the exclusive
Association for promoting, developing and managing
cricket in Delhi. Therefore, BCCI cannot continue to
have a hands-off approach and should suspend DDCA
as per the Memorandum and Rules and Regulations of
the BCCI per Reulgation 32(vii) and streamline the
administration of DDCA. In the interim, professional
cricketers should manage the affairs of cricket in Delhi.
6.2.3 Government should legislate on various sports,

12

including cricket in Delhi specially regarding

prevention

of sports

infrastructure,

fraud and provisions

facilities,

coaching,

of

training,

transparent selection, free and fair elections and with a

view to bring in professional to deal with the same.
6.2.4

The Government to consider appointing a

Commission of Inquiry under the Commission of

Enquiries

Act

to

probe

various

wrongdoings/allegations among other related issues

against DDCA.
6.2.5

DDCA holds monopoly over the affairs of

arguably the most popular sport in Delhi region,

including selection of Delhi States team. It is
performing public functions and should be able to
withstand the test of accountability, fairness, probity
and transparency in all its activities. Its office bearers
are therefore subject to the Prevention of Corruption
Act, 1988 like public servants by the vigilance
apparatus of the GNCT of Delhi.
6.2.6 The Justice Lodha Committee was formed by the
Honble

Supreme

Court

of

India

to

suggest

amendments to the process followed by BCCI with a

view to prevent sporting fraud and conflict of interest
and also streamline the Boards working.

Considering the large number of allegations against

the DDCA, it is recommended that the Delhi
Government should request the Honble Supreme
Court with request to have Honble Justice Lodha
Committee

advice

regarding

streamlining

the

DDCAs working.
6.2.7

The

DDCA,

which

is

substantially

(directly/indirectly) funded by Government should be

brought under the ambit of the Right to Information
Act at the earliest since this would allow people to
know as to how players are selected and what basic
facilities are made available to the players.
It is further respectfully submitted that one Subhash Chandra
Agarwal, RTI Activist, filed a complaint before the Central
Information Commission, seeking certain information in respect of
the DDCA. The Central Information Commission, while by majority
following its earlier judgments and the stay granted by the Honble
High Court on them, declined to hold that the DDCA came within
the purview of the Right to Information Act, 2005. However, the
minority judgment made the following observations:
A.i. That there was no lease executed between DDCA

and

the

Government,

and

that

the

FerozeshahKotla ground has been allotted to

them on a temporary basis by License Deed dated

14

06.09.1988 for 20 years and then again on

10.07.2002, for a period of 33 years from
01.04.2002. It was further noted that the DDCA is
paying a meagre amount of Rs. 24.64 Lakhs per
annum for prime property which admeasuring
14. 281 acres, which as per the market rent would
have to be around Rs. 115.54 crore per annum as
per the DDA Zonal Average Auction Rate Letter
dated 21.05.2014, and against Rs. 194.4 Crore per
annum as per the DDA given Zone-wise
Commercial rate of 2013-14.
A.ii. There are serious financial and election frauds in

the DDCA between 2006 and 2012, and also noted

that the SFIO had, in its report to the Ministry of
Corporate Affairs, recommended that action be
taken against the guilty.
A.iii. The allegation of round tripping of money made

by Member of Parliament Shri. Kirti Azad,

brought about that there was a grave lack of
transparency in the functioning of the DDCA,
and needed investigation.
The election by proxy system has been perpetuating a fraud
on the genuine members of the DDCA, including the Petitioners,
and ensuring that certain persons are Office Bearers perpetually.

This Honble Court vide Order dated 18.11.2015 in C.M. No. 27246 of
2015 in W.P. (C) No. 7215 of 2011 appointed Justice MukulMudgal,
Former Chief Justice of the Punjab and Haryana High Court to
ensure that the DDCA took steps towards obtaining requisite
clearances/compliances. It is submitted that the in the report
submitted by Justice Mudgal, his Lordship has found several
irregularities and indicted the Working Committee of the DDCA. It
is further submitted that the Honble High Court has refused to
entertain the plea of the Respondent No. 1 DDCA for temporary
permissions, because of which the DDCA has lost the opportunity to
host a crucial match in the upcoming World T-20 Championship.
LIST OF DATES
19.02.1936

Respondent No. 1 - DDCA on 19.02.1936 registered

as a not for profit company under the Companies
Act, 1913 and the Certificate of Incorporation was
issued being No. 407 of 1936-1937.
That the DDCA has illegally constructed 20
Corporate Boxes and illegally sub-leased the same
to Corporate entities for a large sum of Rs. 36 crores
[Rupees Thirty Six Crores]. It is respectfully
submitted that these boxes were created without
the prior approval of the Union of India
(Respondent No. 2) or the Municipal Corporation
of Delhi (Respondent No. 5). Further, it is
submitted that the DDCA Respondent No. 1

16

spent about Rs. 114 crores for renovation of the

FerozeshahKotla Stadium, but have provided no
credible accounts. Further the Respondent No. 4
has with the intention to defraud the exchequer,
under priced its tickets during cricket matches,
thereby causing grave losses to the exchequer.
The elections of the DDCA Respondent No. 1 are
conducted in a dubious manner, and there is a
grave misuse of the proxy system. It is submitted
that the members of the Executive Committee
committed several violations of the Companies Act,
1956, which however came to be compounded by a
series of Orders passed by the LokAdalat of the
Company Law Board. It is submitted that one of
the Members of the Bench of the LokAdalat of the
Company Law Board which passed the above
mentioned Orders was the lawyer for the DDCA in
the past, clearly making out a case of conflict of
interest. It is further submitted that the violations
were during the period of the Presidency of Shri.
ArunJaitley, Ministry of Finance, Corporate Affairs
and Information and Broadcasting (Respondent
No. 16 ).

29.12.2014

That there are serious allegations of unauthorized

payments and round tripping of money that some
of the Members of the Executive Committee have
indulged in, especially Shri. S.P. Bansal, the
incumbent

President

of

the

DDCAwho

in

conjunction with Shri. Anil Khanna, General

Secretary of DDCAillegally transferred money
through

RTGS

to

three

companies

and

an

identically amount of Rs 1.55 crs was subsequently

transferred to Shri. Bansals company. Therefore, an
Internal Fact Finding Committee of 4 Executive
Committee members, Chaired by Shri. Sunil Jain,
Club Secretary, was formed and it confirmed that
huge financial irregularities were committed. It
was found by the Committee that several spurious
and illegitimate payments were made to certain
companies between 2013-14 and till 09.12.2014. It
was

also

found

that

the

persons

involved

transferred the funds without the knowledge and

approval of the Executive Committee, and the
transactions were with Inter-related Companies.
The said Committee brought out several cases of
spurious payments made to companies with inter
related directorships, same addresses, same email

18

ids, multiple payments to professionals and civil

contractors for either imaginary work, or for the
same work, which proved that crores of rupees was
siphoned off by certain office bearers of DDCA.

2014

That the DDCAs own Internal Auditors, Ms V K

Bajaj & Co. while commenting on the accounts
relating to the period 1st April 2013 to 31st March
2014 have raised serious doubts about the practices
and controls being exercised by them. While
mentioning several irregularities, the report has
mentioned about the management not providing
key agreements with Consultants, Caterers, sports
professionals,

and

minutes

of

meetings.

Reconciliation of amounts showed that there were

large differences in what was projected and what
was the actual position. It is therefore clear that the
accounts are wholly unreliable and need to be
20.11.2015

junked altogether.
That the DDCA management has insisted on
retaining a tainted auditor, despite the reservations
voiced

and

recorded

repeatedly

by

several

members in view of their serious misconduct in

preparing

Final

Accounts

of

DDCA.

It

is

respectfully stated that the Government of India

have filed prosecution proceedings against the said
auditor (No 215/3) in Tis Hazari Courts- further,
Institute of Chartered Accountants of India have
found Sanjay Bhardwaj & Co. guilty of professional
misconduct and have decided to take action
against them under the relevant rules enumerated
under Chapter v of the Chartered Accountants
Rules, 2007 vide its letter dated 20.11.2015.
Hence the present Writ Petition

01.02.2016

IN THE HONBLE HIGH COURT OF DELHIAT NEW DELHI

(CIVIL ORIGINAL JURISDICTION)
Writ Petition (Civil) No. .................... of 2016
In the matter of:
KIRTI AZAD & OTHERS

PETITIONERS

VERSUS
DELHI DISTRICT CRICKET ASSOCIATION
& OTHERS
RESPONDENTS
A WRIT PETITION IN THE NATURE OF MANDAMUS
UNDER ARTICLE 226/227 OF THE CONSTITUTION OF
INDIA

AND

SEEKING

COURT

MONITORED

INVESTIGATION BY THE CBI TO INVESTIGATE THE

CRIMINAL

OFFENCES

ADMINISTRATORS

OF

COMMITTED
RESPONDENT

BY
NO.

THE
AND

SEEKING THE APPOINTMENT OF AN ADMINISTRATOR

TO ADMINISTER THE CRICKETING ACTIVITIES OF
RESPONDENT NO. 1 FOR THE NCT OF DELHI.

20

TO,
HONBLE THE CHIEF JUSTICE OF THE
DELHI HIGH COURT AND HER HONBLE
COMPANION JUDGESOF THE HONBLE
HIGH COURT.
THE HUMBLE PETITION OF THE
PETITIONER

ABOVE-

NAMED

MOST RESPECTFULLY SHOWETH: 2) That the Petitioners are members of the Respondent No. 1

Delhi District Cricket Association [hereinafter referred to as

the DDCA]and are former cricketers having played cricket
at the First Class Level and also some have been members of
the Indian Cricket Team, and are filing the present writ
petition under Article 226 as Members of Respondent No. 1
and in the interest of cricket administration and cricketing
activities in the National Capital Territory of Delhi, and for the
proper administration of the Respondent No. 1, which
controls cricketing activities in the NCT of Delhi, and also is a
Full Member of the Board for Cricket Control in India
(Respondent No.

17) and avails of large sums of money as

grants, which has been found to be misappropriated and not

used for the development of cricket. The Petitioners are not
filing the present writ petition with any personal interest, and
the petition is not guided by any self gain or for gain of any

other person/institution/body. It is further submitted that the

principal reason for filing the present Writ Petition under
Article 226 by the Petitioners who are Members of the DDCA
is to ensure that the Cricketing Actitivities in the NCT of the
Delhi do not suffer because of the financial mismanagement of
funds by the Respondent No. 1 DDCA.
3) It is submitted that the Petitioners are Members of the DDCA

and are also Members of the NCT Cricket Association. The

Petitioners

are

Former

Test

and

First

class

cricketers/Dronacharya awardees/coach and many of them

have represented the country in International Cricket Matches.
As members of the DDCA, the Petitioners have witnessed the
continuous

deterioration

in

the

management

and

administration of cricket in Delhi, especially financial

management, by the administrators of the DDCA. It is further
submitted that various committees, reports, etc. have found
that

there

has

been

repeated

violation

of

laws,

mismanagement and embezzlement of monies, etc.

4) That the present writ petition is being filed by the Petitioners

in their capacity as Members of the DDCA, and in the interest

of cricketing activities in the NCT of Delhi, and to ensure that
DDCA is administered in a fair, just and proper manner, and
also to ensure that the mismanagement in the DDCA comes to
an end.

22

5) That by way of the present writ petition, the petitioners are

seeking

an

investigation

by

the

Central

Bureau

of

Investigation into the affairs of the DDCA, monitored by this

Honble Court, and the appointment of an Administrator by
this Honble Court to take over the administration of the
DDCA and to ensure its proper administration.
6) The Petitioner No. 1 is a Member of Parliament, and has made

several

representations

to

various

branches

of

the

Government, and also asked questions in Parliament in this

regard, but to no avail. The Other Petitioners have also made
several representations to the DDCA as well as other
Government Entities, but to no avail.
7) The brief facts of the case, giving rise to the filing of the

present Writ Petition, are as follows:

A. Respondent No. 1 - DDCA is a Company registered as a

not for profit company under the Companies Act, 1913.

A true copy of the Certificate of Incorporation of
Respondent No. 4 dated 19.02.1936 being No. 407 of
1936-1937

is

annexed

herewith

and

marked

as

Annexure P-1 [Pages ____ to _____]. As per the

Memorandum of Association, the DDCA was primarily
aimed

at

encouraging

and

promoting

cricketing

activities and run the club and to take over the assets
and liabilities of the Delhi and District Cricket

Association. The Memorandum of Association also

states that the DDCA would organize and promote the
provincial cricket associations and promote jointly or
hold along with any other Association, club or persons,
Cricket matches or competitions, to give or contribute
towards awards and distinctions and the for the
purposes of the Association to promote and give or
support dinners, balls and other entertainments. A true
copy of the Memorandum of Association of the DDCA
is annexed herewith and marked as Annexure P-2
[Pages ___ to ___]. The DDCA also has an Articles of
Associations, which lays down the Constitution and
functioning of the DDCA and its Members. The Articles
of Associations also lays down the procedure for the
elections of the office bearers of the DDCA, and lays
down the powers of the elected persons. As per the
Articles of Association, the Executive Committee
consists of a President, three Vice Presidents, one Hony.
General Secretary, one Hony. Sports Secretary, one
Hony. Club Secretary, one Hony. Treasurer, eight joint
Secretaries namely Two Joint Secretary (Sports), Two
Joint Secretary (Club), Two Joint Secretary (Accounts)
and Two Joint Secretary (Company Affairs), and Eleven
more members, three of whom can be nominees of the

24

Government of India with full voting rights. It is further

stipulated that the Government Nominees shall be the
Honorary Members of the Association till such time as
they remain on the Executive Committee. Further, it is
stipulated that the Executive Committee has the power
to appoint from time to time a Working Committee with
all the powers of the Executive Committee with all the
powers of the Executive Committee and such other
committees beside Sports Committee and the Club
Committee, for the benefit of different activities of the
Association. It is respectfully submitted, as per the
Articles of Association, the control of the Association
shall be vested in the Executive Committee. A true copy
of the Articles of Association is annexed herewith and
marked as Annexure P-3 [Pages ___ to ___]. This
petition, apart from placing certain material and
information, deals with the broader and significant
questions and seeks this Honble Courts intervention to
monitor the investigation already undertaken by the
Central Bureau of Investigation (Respondent No. 4 ) in
the affairs of DDCA, especially due to the fact that
several

influential

personalities

have

been

administrators of the DDCA during the period when

these serious irregularities and illegalities have taken

place.
B. It is respectfully submitted that the primary illegality

and irregularity is the fact that there is no valid lease

executed between the Government of India and the
DDCA for the use of the FerozeshahKotla Grounds. It is
further submitted that the DDCA occupies 14.28 acres of
prime land in Delhi for which it pays a meagre sum of
Rs. 24.64 lakhs on the basis of the allotment by the
Ministry of Urban Development, Government of India.
It is further submitted that the rentals paid by the
DDCA is grossly short of what the market rate, causing
grave losses to the exchequer. It is further submitted
that the Land & Development Officer, vide letter dated
10.07.2002 stated that there is no lease executed between
the DDCA and the Government. The DDCA also does
not have the requisite permissions of the Delhi Urban
Arts Commission, Archeological Survey of India, Fire
Department, and the Municipal Corporation of Delhi. It
is further submitted that the DDCA has been obtaining
temporary permissions from the Municipal Corporation
of Delhi every time there is a cricket match.
Surprisingly, DDCA have been getting temporary No
Objection Certificates year after year despite the fact
that MCD has no discretionary power or authority to

26

issue such certification, season after season.

C. It is further respectfully submitted that the DDCA has

illegally constructed 20 Corporate Boxes and illegally

sub-leased the same to Corporate entities for a large
sum of Rs. 36 crores [Rupees Thirty Six Crores]. It is
respectfully submitted that these boxes were created
without the prior approval of the Union of India
(Respondent No. 2) or the Municipal Corporation of
Delhi (Respondent No. 5). Further, it is submitted that
the DDCA Respondent No. 1 spent about Rs. 114
crores for renovation of the FerozeshahKotla Stadium,
but have provided no credible accounts. Further the
Respondent No. 4 has with the intention to defraud the
exchequer, under priced its tickets during cricket
matches, thereby causing grave losses to the exchequer.
Further, the elections of the DDCA Respondent No. 1
are conducted in a dubious manner, and there is a grave
misuse of the proxy system. It is submitted that the
members of the Executive Committee committed
several violations of the Companies Act, 1956, which
however came to be compounded by a series of Orders
passed by the LokAdalat of the Company Law Board. It
is submitted that one of the Members of the Bench of
the LokAdalat of the Company Law Board which

passed the above mentioned Orders was the lawyer for

the DDCA in the past, clearly making out a case of
conflict of interest. It is further submitted that the
violations were during the period of the Presidency of
Shri. ArunJaitley, Ministry of Finance, Corporate Affairs
and Information and Broadcasting (Respondent No.
16 ). It is further submitted that the Orders of the
LokAdalat of the Company Law Board have been
stayed by this Honble Court vide Order dated ______
inCo. A. (SB) No. 53 of 2015 being Gurpreet Singh v.
DDCA. A true copy of the Order dated ______ passed
by this Honble High Court in in Co. A. (SB) No. 53 of
2015 being Gurpreet Singh v. DDCA is annexed
herewith and marked as Annexure P-4 [Pages ____ to
____].
D. It is further submitted that there are serious allegations

of unauthorized payments and round tripping of

money that some of the Members of the Executive
Committee have indulged in, especially Shri. S.P.
Bansal,

the

incumbent

President

of

the

DDCA

(Respondent No. )who in conjunction with Shri. Anil

Khanna, General Secretary of DDCA (Respondent
No.

)illegally transferred money through RTGS to

three companies and an identically amount of Rs 1.55

28

crs was subsequently transferred to Shri. Bansals

company.
Committee

Therefore,
of

an

Internal

Executive

Fact

Committee

Finding
members,

Chaired by Shri. Sunil Jain, Club Secretary, was formed

and it confirmed that huge financial irregularities were
committed. It was found by the Committee that several
spurious and illegitimate payments were made to
certain companies between 2013-14 and till 09.12.2014. It
was also found that the persons involved transferred
the funds without the knowledge and approval of the
Executive Committee, and the transactions were with
Inter-related Companies. The said Committee brought
out several cases of spurious payments made to
companies with inter related directorships, same
addresses, same email ids, multiple payments to
professionals and civil contractors for either imaginary
work, or for the same work, which proved that crores of
rupees was siphoned off by certain office bearers of
DDCA. A true copy of the Internal Fact Finding
Committee Report dated 29.12.2014 Chaired by Sh.
Sunil Jain is annexed herewith and marked as
Annexure P-5 [Pages ____ to ____].
E. It is humbly submitted that serious allegations have

been made by newspapers and electronic media about

fake and dubious companies having been paid several

crores for either no work, or for the same work that has
been earlier done by the initial contractor, Ms EPIL who
left after completing the stadium in December 2008.
Several companies which were formed after this date,
some of which have direct links with the office bearers
and officials of DDCA, were favored with various
contracts and have now disappeared. It is clear that an
inquiry by a professional investigative agency will
identify the trail of money that has been defalcated, and
will help in recovering such large amounts of
embezzled/lost money.
F. It is further respectfully submitted that the DDCAs

own Internal Auditors, Ms V K Bajaj & Co. while

commenting on the accounts relating to the period 1 st
April 2013 to 31st March 2014 have raised serious doubts
about the practices and controls being exercised by
them. While mentioning several irregularities, the
report has mentioned about the management not
providing key agreements with Consultants, Caterers,
sports

professionals,

and

minutes

of

meetings.

Reconciliation of amounts showed that there were large

differences in what was projected and what was the
actual position. It is therefore clear that the accounts are

30

wholly unreliable and need to be junked altogether. A

true copy of the Internal Auditor of V.K. Bajaj & Co. is
annexed herewith and marked as Annexure P-6 [Pages
___ to ___].
G. It is further respectfully submitted that the DDCA

management has insisted on retaining a tainted auditor,

despite the reservations voiced and recorded repeatedly
by several members in view of their serious misconduct
in preparing Final Accounts of DDCA. It is respectfully
stated that the Government of India have filed
prosecution proceedings against the said auditor (No
215/3) in Tis Hazari Courts- further, Institute of
Chartered Accountants of India have found Sanjay
Bhardwaj & Co. guilty of professional misconduct and
have decided to take action against them under the
relevant rules enumerated under Chapter v of the
Chartered Accountants Rules, 2007. A true copy of the
letter dated 20.11.2015 of the Institute of Chartered
Accountants confirming the misconduct of Sanjay
Bhardwaj & Co. is annexed herewith and marked as
Annexure P-7 [Pages ____ to ____].
H. It is further submitted that several crores were paid by

DDCA to certain lawyers for embroiling detractors and

inconvenient stakeholders such as members, club

owners, in long drawn out legal cases in a bid to tire

them out. Misusing the due process of law has been a
regular feature as several annexed bills and chart will
show. It is common knowledge that the DDCA office
bearers have been misusing the due process of law by
filing cases in different lower courts in Delhi and
staying elections in DDCA. Even now, the election to
the Executive Committee are pending since the last two
years on the basis of a stay obtained by one office
bearers from the Rohini court, which has not even been
challenged by DDCA so far. It is further submitted that
16 of the 24 Directors have completed their terms.
Without an election all the office bearers are continuing
to be in saddle, and ROC/ Government has taken little
steps to have the elections held.
I. It is submitted that following an assurance to Petitioner

No. 1 in Parliament, Ministry of Sports and Youth

Affairs have written a letter to Delhi Government to
initiate action against DDCA for having carried out
unauthorized

construction

and

for

evasion

of

Entertainment Tax. A true copy of the letter dated

27.07.2015 of the Ministry of Sports and Youth Affairs is
annexed herewith and marked as Annexure P-8 [Pages
____ to ____].

32

J. Pursuant to several complaints, letters and Questions in

Parliament by Petitioner No. 1, the then Government

ordered the institution of an Inquiry under Section 209
A of the Companies Act by the Serious Frauds
Investigation Office who were entrusted the task of
conducting an investigation of the DDCA, and
functioning of the Executive Committee of the DDCA.
The SFIO found that there were several irregularities
and non-compliance of provisions of the Companies
Act, 1956 on the basis of complaints made by Petitioner
No. 1. A true copy of the Report of the SFIO dated
21.03.2013 is annexed herewith and marked as
Annexure P-9 [Pages ___ to ___]. It is submitted that the
constitution of the Inquiry Committee was diluted and
an inquiry under the charge of the then Regional
Director (North) with two other members- one from his
own office and another from the SFIO, was finally
formed to carry out the said investigation. In this way, it
is submitted, the will of Parliament was also sought to
be manipulated and subsequently, even serious charges
of fraud, embezzlement of public money, forgery of
documents, fudging of Balance Sheets etc were all
shown to be compoundable offences, and serious
criminal charges were therefore kept at bay.

K. It is further respectfully submitted that one Subhash

Chandra Agarwal, RTI Activist, filed a complaint before

the Central Information Commission, seeking certain
information in respect of the DDCA. The Central
Information Commission, while by majority following
its earlier judgments and the stay granted by the
Honble High Court on them, declined to hold that the
DDCA came within the purview of the Right to
Information Act, 2005. However, the minority judgment
made the following observations:
K.i. That there was no lease executed between DDCA

and

the

Government,

and

that

the

FerozeshahKotla ground has been allotted to

them on a temporary basis by License Deed dated
06.09.1988 for 20 years and then again on
10.07.2002, for a period of 33 years from
01.04.2002. It was further noted that the DDCA is
paying a meagre amount of Rs. 24.64 Lakhs per
annum for prime property which admeasuring
14. 281 acres, which as per the market rent would
have to be around Rs. 115.54 crore per annum as
per the DDA Zonal Average Auction Rate Letter
dated 21.05.2014, and against Rs. 194.4 Crore per
annum as per the DDA given Zone-wise

34

Commercial rate of 2013-14.

K.ii. There are serious financial and election frauds in

the DDCA between 2006 and 2012, and also noted

that the SFIO had, in its report to the Ministry of
Corporate Affairs, recommended that action be
taken against the guilty.
K.iii. The allegation of round tripping of money made

by Member of Parliament Shri. Kirti Azad,

brought about that there was a grave lack of
transparency in the functioning of the DDCA,
and needed investigation.
A true copy of the Judgment dated 13.04.2015 of the
Chief

Information

Commission

in

File

No.

CIC/LS/C/2012/000714 dated 13.04.2015 is annexed

herewith and marked as Annexure P-10 [Pages ___ to
___].
L. The Government of the NCT of Delhi (Respondent No.

3), upon the complaints made by the Petitioners herein

and Shri. Kirti Azad, Member of Parliament (Lok
Sabha), constituted a Committee to inquire into the
complaints on 12.11.2015 under the Chairpersonship of
Shri. Chetan B. Sanghi, Principal Secretary, PWD/UD.
The Committee, in its report dated nil made the
following recommendations:

6.1

Keeping the aforesaid in view as well as the

various complaints that are under investigation in a

variety of fora, the following recommendations are
made:6.2.1

DDCA is responsible for promotion and

development of cricket and for the fate of the budding

crickets in the State of Delhi. It is therefore necessary
that affairs of DDCA should be managed primarily by
cricketers.
6.2.2 BCCI, being a parent body governing cricket in
India, has recognized DDCA as the exclusive
Association for promoting, developing and managing
cricket in Delhi. Therefore, BCCI cannot continue to
have a hands-off approach and should suspend DDCA
as per the Memorandum and Rules and Regulations of
the BCCI per Reulgation 32(vii) and streamline the
administration of DDCA. In the interim, professional
cricketers should manage the affairs of cricket in Delhi.
6.2.3 Government should legislate on various sports,
including cricket in Delhi specially regarding
prevention

of sports

infrastructure,

fraud and provisions

facilities,

coaching,

of

training,

transparent selection, free and fair elections and with a

view to bring in professional to deal with the same.

36

6.2.4

The Government to consider appointing a

Commission of Inquiry under the Commission of

Enquiries

Act

to

probe

various

wrongdoings/allegations among other related issues

against DDCA.
6.2.5

DDCA holds monopoly over the affairs of

arguably the most popular sport in Delhi region,

including selection of Delhi States team. It is
performing public functions and should be able to
withstand the test of accountability, fairness, probity
and transparency in all its activities. Its office bearers
are therefore subject to the Prevention of Corruption
Act, 1988 like public servants by the vigilance
apparatus of the GNCT of Delhi.
6.2.6 The Justice Lodha Committee was formed by the
Honble

Supreme

Court

of

India

to

suggest

amendments to the process followed by BCCI with a

view to prevent sporting fraud and conflict of interest
and also streamline the Boards working.
Considering the large number of allegations against
the DDCA, it is recommended that the Delhi
Government should request the Honble Supreme
Court with request to have Honble Justice Lodha
Committee

advice

regarding

streamlining

the

DDCAs working.
6.2.7

The

DDCA,

which

is

substantially

(directly/indirectly) funded by Government should be

brought under the ambit of the Right to Information
Act at the earliest since this would allow people to
know as to how players are selected and what basic
facilities are made available to the players.
A true copy of the Report dated Nil of the Committee
constituted by the Government of the NCT of Delhi is
annexed herewith and marked as Annexure P-11 [Pages
___ to ___].
M. Pursuant to the various complaints, a Preliminary

Inquiry has been registered against DDCA, and

investigation has been entrusted to the Respondent No.
4 CBI vide file no. 5845 / PE(S)/15/SCU-II/CBI/New
Delhi. However, it is submitted that there has been no
progress in the investigation. A true copy of the Letter
dated 23.10.2015 by the CBI to the Officer Bearers of the
DDCA is annexed herewith and marked as Annexure P12 [Pages ___ to ___].
N. Respondent No. 3 Government of NCT of Delhi, has

also constituted a Commission of Inquiry headed by

Shri.

Gopal

22.12.2015

Subramanium,
vide

Senior Advocate,

Notification

being

No.

on
F.

38

01/66/2015/DOV/15274-15281. A true copy of the

Notification being No. F. 01/66/2015/DOV/1527415281 dated 22.12.2015 is annexed herewith and marked
as Annexure P-13 [Pages ___ to ___].
O. It is submitted that a two judges panel comprising of

former District Judges which was formed at the instance

of Honble ADJ Shri. Vinod Kumar, Tis Hazari Courts,
Delhi, has come out with startling findings about the
unauthorized and illegal ways adopted by some office
bearers of DDCA in the functioning and shepherding of
the affairs of DDCA. It is submitted that the elections
have been manipulated with the active connivance of
certain key office bearers of DDCA which has
perpetuated these office bearers, much to the detriment
of cricket in Delhi. A true copy of the Report of this
panel dated 19.09.2015by Shri. G.B. Thareja and Shri.
BabuLal, Former District Judges is annexed herewith
and marked as Annexure P-14 [Pages ___ to ___].
P. It is submitted that the Honble Supreme Court in the

case of BCCI v. Cricket Association of Bihar, (2015) 3

SCC 251, has noted the importance of cricket in India
and the ill effects of maladministration on the sport in
the following words:
1. Cricket being more than just a sport for millions

in this part of the world, accusation of malpractices

and conflict of interest against those who hold in
positions of influence in BCCI but also own franchises
and teams competing in the IPL format have left many
cricketing enthusiasts and followers of the game
worried and deeply suspicious about what goes on in
the name of the game. There is no denying the fact that
the lower the threshold or tolerance for any
wrongdoings the higher is the expectation of the
people, from the system. And cricket being not only a
passion but a great unifying force in this country, zero
tolerance approach towards any wrongdoing along can
satisfy the cry for cleaning.
Further, the Honble Supreme Court held:
103. BCCI is a very important institution that
discharges important public functions. Demands of
institutional integrity are, therefore, heavy and need to
be met suitably in larger public interest. Individuals
are birds of passage while institutions are forever. The
expectations of the millions of cricket lovers in
particular and public at large in general, have lowered
considerably the threshold of tolerance for any
mischief, wrongdoings, or corrupt practices which
ought to be weeded out of the system. Conflict of

40

interest is one area which appears to have led to the

current confusion and serious misgivings in the public
mind as to the manner in which the BCCI is managing
its affairs.
Q. It is most respectfully submitted that the dicta of the

Honble Supreme Court in respect of the BCCI

(Respondent No. 17 )apply as it is to the DDCA, as the
DDCA is recognized by the BCCI to have monopoly
over cricket administration in the NCT of Delhi, and the
same has been recognized by the Central Information
Commission in the aforementioned Judgment.
R. The Committee constituted by the Honble Supreme

Court in the aforementioned matter being BCCI v. CAB,

Chaired by Former Chief Justice of India, Justice R.M.
Lodha, has submitted its report, has noted that there is
absolutely no transparency in the functioning of Cricket
Boards in the Country, and has also noted that there
ought to be better financial management, and that the
money resources must be used for the development of
the game and financial prudence must be exercised to
avoid unnecessary expenditure. In addition, the Justice
Lodha Committee has recommended that norms and
procedures shall have to be laid down for the
engagement of service professionals and contractors,

and there shall be full transparency of all tenders

floated and bids invited by or on behalf of the BCCI (or
the State Cricket Association, as the case may be). A true
copy of the Report dated 04.01.2016 of the Justice Lodha
Committee is annexed herewith and marked as
Annexure P-15 [Pages ___ to ____]. It is respectfully
submitted that the recommendations made by the
Committee headed by Former Chief Justice of India,
Justice R.M. Lodha, are pending consideration of the
Honble Supreme Court in the disposed of Civil Appeal
No. 4235 of 2014, etc.
S. This Honble Court vide Order dated 18.11.2015 in C.M.

No. 27246 of 2015 in W.P. (C) No. 7215 of 2011 appointed

Justice MukulMudgal, Former Chief Justice of the
Punjab and Haryana High Court to ensure that the
DDCAtook

steps

towards

obtaining

requisite

clearances/compliances. It is submitted that the in the

report submitted by Justice Mudgal, he has found
several

irregularities

and

indicted

the

Working

Committee of the DDCA. A true copy of the Report

submitted

by

Justice

MukulMudgal

is

annexed

herewith and marked as Annexure P-16 [Pages ___ to

___].
T. The Petitioner No. 1 has written several letters to

42

Respondent No. 16 complaining about the state of

affairs of the Respondent No. 1. On 13.09.2015, the
Petitioner No. 1 again wrote a letter to the Respondent
No. 16, stating all the facts of financial mismanagement
by the Office Bearers of the DDCA, but the same went
unanswered. A true copy of the letter dated 13.09.2015 is
annexed herewith and marked as Annexure P-17 [Pages
___ to ___].
U. The Government of the NCT of Delhi through Office of

the Commissioner of Excise, Entertainment and Luxury

Tax issued a notice dated 21/23.10.2015 to Respondent
No. 1 DDCA for recovery of Entertainment Tax to the
tune of Rs. 24,45,96,000 [Rupees Twenty Four Crores
Forty Five Lakhs Ninety Six Thousand only] towards
Entertainment Tax, interest and penalty. A true copy of
the letter being No. F.18 (5)/ETO/14-15/2815/3371
dated 21/23.10.2015 is annexed herewith and marked as
Annexure P-18 [Pages ___ to ___].
8) The above writ petition is filed before this Honble Court on

the following grounds:

A. Because there is a grave apprehension that the CBI

(Respondent No. 4 ) will not be able to conduct a free

and fair investigation of allegations made against the
DDCA, especially since ArunJaitley (Respondent No.

16), during whose tenure as President most of the

allegation pertain to, is presently a senior Cabinet
Minister in the Union Council of Ministers and is also
the leader of the House is the Rajya Sabha.
B. Because the Respondent No. 16, being the Cabinet

Minister of Corporate Affairs, there exists a grave

apprehension of conflict of interest, in Respondent No.
2 Union of India, acting upon the recommendations of
the SFIO in respect of the serious violations of the
provisions of the Companies Act, 1956 that some of the
office bearers of the Executive Committee of the
Respondent No. 1 DDCA are guilty of.
C. Because the Respondent No. 16 was the President of the

Respondent No. 1 DDCA during which, all the alleged

violations of the Companies Act have taken place and is
presently the Minister of Corporate Affairs in the Union
Government.
D. Because the Honble Supreme Court in the case of

VineetNarian v. Union of India, (1996) 2 SCC 199, noting

that influential persons are involved, directed the CBI
and the ED that no settlement or compounding of
offence ought to happen without the prior leave of the
Court. Further, the Court held that the CBI and other
government agencies must expedite their actions to

44

complete the task and prevent pendency of the

investigation, due to the great public interest involved
in the matter. It is submitted that the same parameters
ought to be applied here.
E. Because great loss is being caused to the exchequer by

the absence of the lease agreement, and the temporary

license deed executed between Respondent No. 1
DDCA and the Respondent No. 2 Union of India. It is
submitted that the property which as per DDA rates is
to be leased out at between Rs. 115 crores and Rs. 193
crores per annum is being let out at a meagre Rs. 24.64
lakhs per annum.
F. Because the Honble Supreme Court in the case of

Centre for Public Interest Litigation v. Union of India,

(2011) 1 SCC 560 and ManoharLal Sharma v. Principal
Secretary, (2014) 2 SCC 532, has granted a Court
Monitored

Investigation

in

matters

involving

corruption at high places.

G. Because in ManoharLal Sharma v. Principal Secretary,

(2014) 2 SCC 532, the Honble Supreme Court has held

that it is the role of the Honble High Courts and that of
the Honble Supreme Court to interpret the anticorruption laws in such a fashion that abuse of public
office for private gain is minimized.

H. Because in BCCI v. Cricket Association of Bihar, (2015) 3

SCC 251, the Honble Supreme Court, while noting the

importance of cricket as a great unifier in the country,
has held that the integrity of the institution needs to be
upheld in order to ensure that the faith in the game of
cricket is maintained.
I. Because the Respondent No. 1 - DDCA has also evaded

Entertainment Taxes, by selling the best tickets at cheap

prices, thereby ensuring that Entertainment Taxes worth
crores of rupees is evaded.
J. Because the Honble High Court of Delhi Order dated

05.10.2015 in Co. A. (SB) No. 53 of 2015 being Gurpreet

Singh v. DDCAstayed the operation of the Orders
passed by the LokAdalat of the Company Law Board,
with Shri. U.K. Chowdhary (former lawyer for the
DDCA) as a Member.
K. Because Shri. ArunJaitley (Respondent No.16

) is

presently the Cabinet Minister holding the Portfolio of

Corporate Affairs.
L. Because the Honble High Court is seized of a

connected matter in W.P. (C) No. 7215 of 2011, in which

the Committee Appointed under Justice Mukul Mudgal
has found several irregularities and discrepancies in the
same.

46

M. Because the election by proxy system has been

perpetuating a fraud on the genuine members of the

DDCA, including the Petitioners, and ensuring that
certain persons are Office Bearers perpetually.
N. Because the institutional integrity of the DDCA and the

game of cricket must be maintained while also ensuring

that the laws are not violated.
O. That the entire matter is seeking a court-monitored

investigation by an SIT or CBI since the same is

necessary to uphold democracy, the rule of law and
rights of the citizens under Articles 14 and 21 of the
Constitution of India.
P. That the prevailing corruption in the country in high

places seriously impairs the right of the people of this

country to live in a corruption free society governed by
rule of law. This is a violation of Article 14 and 21 of the
Constitution. The right to life guaranteed to the people
of this country also includes in its fold the right to live
in a society, which is free from crime and corruption.

PRAYERS
In view of the facts & circumstances stated above, it is
most respectfully prayed that this Honble Court under the
inherent powers under Article 226 may be pleased to: -

a. Issue a writ of mandamus or any other appropriate writ

directing a thorough court-monitored investigation by the

CBI

in

Preliminary

Investigation

File

no.

5845

PE(S)/15/SCU-II/CBI/New Delhi in into the high level of

corruption in the Respondent No. 1 Delhi and District and
Cricket Association.
b. Issue a writ of mandamus or any other appropriate writ

directing the Union of India to cancel the privileges like

subsidized land, etc. that have been extended to
Respondent No. 1 Delhi and District Cricket Association,
and to ensure that no loss is caused to the exchequer.
c. Issue or pass any writ, direction or order, which this

Honble court may deem fit and proper under the facts and
circumstances of the case.

NEW DELHI
DATE: 01.02.2016

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
OLD LAWYERS CHAMBERS,
SUPREME COURT OF INDIA,
NEW DELHI - 01
Tel.: +91 9953557798

48

IN THE HIGH COURT OF DELHI, AT NEW DELHI

CIVIL ORIGINAL JURISDICTION
C.M. NO.
OF 2016
IN
WRIT PETITION (C) NO..OF 2016
In the matter of:
KIRTI AZAD & OTHERS

PETITIONERS

VERSUS
DELHI & DISTRICT CRICKET ASSOCIATION
& OTHERS
RESPONDENTS
AN APPLICATION FOR DIRECTIONS
To
The Honble Chief Justice and
Companion Justices of the Honble
High Court of Delhi at New Delhi

The humble Petition of the

Petitioner above-named.
MOST RESPECTFULLY SHOWETH:
1.

The present writ petition under Article 226 of the Constitution

of India is being filed by Members of Respondent No. 1, being

aggrieved by the financial mismanagement and the general
mismanagement of the affairs of the Respondent No. 1 Delhi &
District Cricket Association by the incumbent Working Committee
and are seeking a writ in the nature of mandamus, by which the
illegal activities of some of the Members of the Working Committee
of Respondent No. 1 may be investigated by a SIT or the a court
monitored investigation by Respondent No. 4 Central Bureau of
Investigation, and for the appointment of an administrator to

administer Respondent No. 1, and to ensure the preparation of

electoral rolls, and for the conduct of fresh elections to the working
committee of Respondent No.
2.

The facts and circumstances for filing the present Writ Petition

has been detailed in the accompanying petition and for the sake of

brevity and convenience the petitioners herein craves to

rely on the same for the purpose of this application.
3.

That there is a lot of mismanagement in the working of Delhi

and District Cricket Association and because of that DDCA has lost
the hosting of T20 World Cup Cricket match. It is further submitted
that the DDCA has not the permanent permission to hold any event
and they take temporary permission from the authorities to hold any
event and work on Ad-hoc basis.
4.

That in the interest of Justice this Hon'ble Court may be

pleased to dissolve the Working Committee of the Delhi and District

Cricket Association, and appoint a Retired Judge of this Honble
High Court or Retired Chief Justice of any High Court as
Administrator to conduct the administration of the Delhi and
District Cricket Association and administration of cricketing
activities till fresh elections are conducted, after the approval of
electoral rolls by the Administrator and without Proxy Voting so that
in future the Delhi and District Cricket Association will not lose any
match.
P RAY E R

50

It is therefore, most respectfully prayed that this Honble

Court may be pleased to :
a)

dissolve the Working Committee of the Delhi and District

Cricket Association, and appoint a Retired Judge of this
Honble High Court or Retired Chief Justice of any High
Court as Administrator to conduct the administration of the
Delhi and District Cricket Association and administration of
cricketing activities till fresh elections are conducted, after the
approval of electoral rolls by the Administrator and without
Proxy Voting.; and

b)

Pass such further order or orders as are deemed fit and proper
in the facts and circumstances of the case.

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN

DUTY BOUND SHALL EVER PRAY.

NEW DELHI
DATE: 01.02.2016

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
OLD LAWYERS CHAMBERS,
SUPREME COURT OF INDIA,
NEW DELHI - 01
Tel.: +91 9953557798
Filed by