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

SL.
No.
1.
3.

INDEX
PARTICULARS

PAGE
NO.

Urgent Application
Notice of Motion

4.

Memo of Parties

5.

Synopsis & List of Dates

6.

Writ Petition under Articles 226 & 227 of

7.

the Constitution 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
Association.

10.

of

the

Articles

of

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.

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
13.09.2015.

24.

of

the

letter

dated

ANNEXURE P-18
A true copy of the letter being No. F.18
(5)/ETO/14-15/2815/3371
dated
21/23.10.2015.

25.

C.M. No. _______ of 2015 :

An Application
Affidavit.

26.

Vakalatnama

27.

Court Fee

NEW DELHI
DATE: 01.02.2016

for

Directions

with

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:
NEW DELHI - 01
01.02.2016
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,

VasantKunj, New Delhi
4.

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,

Petitioner No. 6

A-51, IInd Floor,

SwasthyaVihar,
New Delhi 110092.
1.

Delhi

&

Vs.
District
Cricket

Respondent No. 1

Association,
Through its President,
Feroze Shah Kotla Grounds,
2.

New Delhi 110020.

Union of India

Respondent No. 2

Through Secretary,
Ministry

of

Development,
3.

Urban

UdyogBhavan,

New Delhi.
Government of NCT of Delhi

Respondent No. 3

Through Chief Secretary,

4.

Delhi Secretariat, New Delhi.

Central
Bureau
of

Respondent No. 4

Investigation,
Through its Director,
CGO Complex,
Lodhi

Road,

New

Delhi

5.

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,

Vice President DDCA
& Vice President BCCI,
192, Kailash hills,

Respondent No.8

9.

New Delhi-110065
Shri. Chetan Chauhan,

Respondent No.9

Vice President,
D-202, Nagarjun Appt.,
MayurVihar Phase-I,
New Delhi-110096
10. Shri. Anil Khanna,

Respondent No.

Hony. General Secretary,

10

274, Kailash Hills,

New Delhi-110065.
11. Shri. Sunil Dev,

Respondent No.

Hony. Sports Secretary (DDCA)

11

& Vice Chairman (NCA),

B-531, New Friends Colony,
New Delhi- 110065.
12. RavinderManchanda,

Respondent No.

Hony. Treasurer,

12

D-281, Defence Colony,

New Delhi-110024
13. Shri. Ravi Jain,

Respondent No.

Hony. Joint Secretary (Club),

13

C-II/32, Bapra Nagar,

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

Respondent No.

Hony. Joint Secretary (Company

14

Affairs),
16/9 West Patel Nagar,
New Delhi-110008
15. Shri. Dinesh Kumar Sharma,
Hony. Joint Secretary (Company

Respondent No.
15

Affairs),
WZ-459/1

Street

No.24

Shiv

Nagar, Tilak Nagar, New Delhi58,

16. Shri. ArunJaitley,
Former President DDCA,

Respondent No.
16

Member of Parliament (RS),

Minister for Finance, Corporate
Affairs

and

Information

and

Broadcasting,
A-44, Kailash Colony,
New Delhi 110048.
17. Board for Cricket Control in
India,

Respondent No.
17

Through its Secretary,

Shri. Anurag Thakur,
14,

Janpath,

New

Delhi

110001.
18. Vinod Tihara,

Respondent No.

B-55, Antriksh Apartments,

18

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
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
complete

agencies

the

task

must
and

expedite
prevent

their

actions

pendency

of

to
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, including cricket in Delhi

specially regarding prevention of sports
fraud

and

provisions

of

infrastructure,

facilities, coaching, 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

other related issues against DDCA.

among

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

allegations

against

the

number
DDCA,

it

of
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:
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 Commercial rate
of 2013-14.
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.
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
19.02.193 Respondent No. 1 - DDCA on 19.02.1936
6

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 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 ).

29.12.201 That
4

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

Therefore,

an

Committee

of

Shri.

Bansals

Internal
4

company.

Fact

Executive

Finding

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 201314 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
2014

off by certain office bearers of DDCA.

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,

mentioned

about

the

the

report

management

has
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 junked altogether.
20.11.201 That the DDCA management has insisted on
5

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

enumerated

under
under

the

relevant

Chapter

of

rules
the

Chartered Accountants Rules, 2007 vide its

letter dated 20.11.2015.
01.02.201 Hence the present Writ Petition
6
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
1

AND

SEEKING THE APPOINTMENT OF AN ADMINISTRATOR

TO

ADMINISTER

THE

CRICKETING

ACTIVITIES

OF

RESPONDENT NO. 1 FOR THE NCT OF DELHI.

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.
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.

DDCA

is

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

Secretary,
Hony.

one

Hony.

Treasurer,

eight

Club
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 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
executed

stated
between

that
the

there

is

DDCA

no
and

lease
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 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.
transferred

money

through

RTGS

)illegally
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

knowledge

and

the

approval

funds
of

without

the

the

Executive

Committee, and the transactions were with Interrelated 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 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 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-

Chartered Accountants

further,

Institute

of

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 ____].
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

Commission,

the

seeking

Central

certain

Information

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:
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 Commercial rate
of 2013-14.
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.
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 P10 [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
fraud

and

provisions

of

infrastructure,

facilities, coaching, 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

allegations

against

the

number
DDCA,

it

of
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 P-12 [Pages ___ to ___].
N. Respondent No. 3 Government of NCT of Delhi,
has also constituted a Commission of Inquiry
headed by Shri. Gopal Subramanium, Senior
Advocate, on 22.12.2015 vide Notification being
No. F. 01/66/2015/DOV/15274-15281. A true copy
of

the

Notification

being

No.

F.

01/66/2015/DOV/15274-15281 dated 22.12.2015

is annexed herewith and marked as Annexure
P-13 [Pages ___ to ___].
O. It

is

submitted

that

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

19.09.2015by
BabuLal,

Report
Shri.

Former

of

G.B.

District

this

panel

Thareja
Judges

dated

and
is

Shri.

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 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

expenditure.

In

to

addition,

avoid
the

unnecessary
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,

irregularities

he

and

has

found

several

the

Working

indicted

Committee of the DDCA. A true copy of the

Report submitted by Justice MukulMudgal is
annexed herewith and marked as Annexure P16 [Pages ___ to ___].
T. The Petitioner No. 1 has written several letters to
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 P18 [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.
conduct

free

and

4 ) will not be able to

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 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

Court

Monitored

Investigation

in

matters involving corruption at high places.

G. Because in ManoharLal Sharma
Secretary,

(2014)

SCC

532,

v. Principal
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 anti-corruption
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.
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

perpetually.

persons

are

Office

Bearers

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 courtmonitored 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

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

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

Constitution

writ
of

petition

India

is

under

being

Article

filed

by

226

of

Members

the
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.
PRAYER
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