Delhi High Court Quashes Recognition Of Yogasana Bharat As National Sports Federation, Says Sports Ministry 'Surrendered' To AYUSH
The Delhi High Court today quashed the Union government's recognition of Yogasana Bharat as the National Sports Federation (NSF) for Yogasana, holding that the decision was contrary to the National Sports Development Code and suffered from non-application of mind. [2026 LiveLaw (Del) 640]Justice Purushaindra Kumar Kaurav also set aside the Union Ministry of Youth Affairs and Sports'...
The Delhi High Court today quashed the Union government's recognition of Yogasana Bharat as the National Sports Federation (NSF) for Yogasana, holding that the decision was contrary to the National Sports Development Code and suffered from non-application of mind. [2026 LiveLaw (Del) 640]
Justice Purushaindra Kumar Kaurav also set aside the Union Ministry of Youth Affairs and Sports' speaking order dated October 19, 2021, as well as the annual renewal letters issued to Yogasana Bharat for the years 2022 to 2025, holding that they could not survive after the foundational recognition itself was found to be illegal.
The Court, however, directed that all certificates, medals, rankings, selections and other recognitions granted to the athletes, coaches or participants during the period Yogasana Bharat functioned as the recognised NSF would remain valid.
The petition was filed by the Yoga Federation of India challenging the Sports Ministry's decision dated November 27, 2020, recognising Yogasana Bharat as the NSF for Yogasana.
The Court held that Yogasana Bharat did not satisfy the mandatory eligibility criteria under the Sports Code when recognition was granted.
It observed that the federation had existed for only around three months, lacked the requisite State and Union Territory affiliations and had not conducted the mandatory national championships before being recognised.
The Court also observed that when the Union Sports Ministry received the Ministry of AYUSH's recommendation and treated it as the beginning and end of its inquiry, it did not exercise discretion but rather it “surrendered to it.”
"The distinction between consultation and delegation, and also between weighing a recommendation and being governed by it, is elementary and fundamental. The Government of India (Transaction of Business) Rules, 1961, relied on by the respondents, contemplate inter-ministerial concurrence; they do not contemplate inter- ministerial abdication,” the Court said.
It observed that the entire record before the Court disclosed no document, no file noting, no internal assessment and no comparative analysis in which Sports Ministry independently examined whether Yogasana Bharat satisfied the mandatory criteria.
The recognition was, in the Sports Ministry's own words, the product of AYUSH's recommendation alone, it said.
Further, Justice Kaurav said that the speaking order of 2021 said nothing, whatsoever, about Yogasana Bharat's eligibility against the mandatory criteria of the Sports Code.
The Court said that an order that examines only the challenger and is silent on the very question it was directed to answer does not discharge the mandate that occasioned its passing and merely wears the appearance of compliance while leaving the substance of the direction unaddressed.
The Court directed the Ministry of Youth Affairs and Sports to issue a public notice within 60 days inviting applications from all eligible bodies for recognition as the National Sports Federation for the sport of Yoga.
It added that the recognition exercise shall be completed with due expedition in accordance with law, while also clarifying that the Yoga Federation of India is not declared to be the National Sports Federation for the sport of Yogasana.
“It is further clarified that the quashing and setting aside of the recognition letter dated 27.11.2020 and the speaking order dated 19.10.2021, together with the retrospective protection granted under this judgment, are intended solely to rectify the impugned process and to safeguard the interests of athletes and other stakeholders. They shall not confer, create, or be treated as conferring any right, legitimate expectation, preference, equity, or other advantage in favour of the petitioner, nor shall they be relied upon by the petitioner in support of any application or claim for recognition or any other consequential benefit,” the Court said.
Title: YOGA FEDERATION OF INDIA v. UNION OF INDIA & ORS
Citation: 2026 LiveLaw (Del) 640