The Legal Status of BCCI and Its Accountability: A Supreme Court Scrutiny


The Board of Control for Cricket in India (BCCI), a pivotal figure in the cricketing world, has recently found itself under the judicial microscope of the Supreme Court of India. This legal scrutiny revolves around the complex questions concerning the BCCI’s legal status and its accountability in the wake of alleged misuse of power. Specifically, the spotlight is on whether the BCCI, by virtue of its actions and the significant role it plays in the cricketing domain, should be considered as performing public functions, and thus, fall within the ambit of judicial review under Article 226 of the Indian Constitution. This editorial aims to dissect the layers of this legal debate, offering a clear, concise, and comprehensive overview to aid Judiciary aspirants in understanding the intricacies of the case. Through simple language and structured points, we endeavor to unravel the complexities surrounding the BCCI’s operations and its legal confrontations, fostering a deeper understanding of its implications on Indian jurisprudence and the broader landscape of sports governance. 

  • Simplicity in language: for ease of understanding
  • Formal tone: to maintain editorial integrity
  • Depth and practicality: in analysis to encourage critical thinking
  • Engagement and interactivity: in presentation to support continuous learning


Launch of IPL: 

In 2007, the BCCI decided to launch the Indian Premier League (IPL), marking a significant development in the cricketing world. This move was followed by the appointment of Mr. N. Srinivasan as the secretary of BCCI on 27th September 2008, during which BCCI amended its regulation 6.2.4 to exclude IPL and Champions League T20 from its purview.

Spot-fixing Allegations: 

In April 2013, the Delhi police received information regarding spot-fixing in the IPL, leading to charges against two individuals. This prompted the BCCI to constitute a probe committee initially headed by Shri Sanjay Jagdale, and after his resignation, composed of two retired judges of the Madras High Court.

Legal Challenge: 

The Cricket Association of Bihar approached the Bombay High Court under Article 226 of the Constitution of India, 1950, challenging the constitution of the probe committee as ultra vires (beyond the powers) of the Constitution and sought the appointment of retired Supreme Court Judges to the panel. They also sought the termination of contracts of IPL franchises Chennai Super Kings and Rajasthan Royals with the BCCI and initiation of disciplinary proceedings against N. Srinivasan.

High Court Ruling: 

On 30th July 2013, the Bombay High Court declared the constitution of the Probe Commission in contravention to Provisions 2.2 and 6 of IPL operational rules but denied the relief sought for constituting a commission of retired judges under Article 226.

Supreme Court Appeal: 

The Cricket Association of Bihar filed an appeal before the Supreme Court, raising questions about the legal status of BCCI and its amenability to the writ jurisdiction of the High Court under Article 226 of the Constitution of India, 1950.

Supreme Court’s Observation: 

The Supreme Court ruled that BCCI, while not a government entity, performs public functions and is thus amenable to the writ jurisdiction of the High Court under Article 226. This is due to BCCI’s significant control over cricket in India and its recognition by the government, despite being an autonomous body.

Legal Status of BCCI: 

The judgment clarified BCCI’s status, emphasizing that it performs a public function due to its substantial influence and power in the cricket domain, supported tacitly by the government. Therefore, it falls under the judicial review, making its actions during the discharge of these public functions subject to scrutiny.

This case underscores the intricate relationship between the BCCI, its legal status, and the scope of judicial review, making it a pivotal study for judiciary aspirants to understand the dynamics of law as it intersects with sports administration in India.

Issues Involved

The crux of the matter under deliberation in the Supreme Court revolves around the intricate legal classification of the Board of Control for Cricket in India (BCCI) and its amenability to the writ jurisdiction under Article 226 of the Indian Constitution. This inquiry is pivotal, considering the BCCI’s autonomous status and its expansive influence over cricket in India, juxtaposed with the allegations of misuse of power and governance issues. The court is tasked with dissecting whether the BCCI, despite its non-governmental facade, performs duties so public in nature that they attract judicial scrutiny akin to that of state actions. This examination is not merely academic but has profound implications for the governance of cricket, accountability mechanisms, and the legal landscape concerning autonomous bodies in India. The outcome could redefine the boundaries of judicial intervention in the activities of bodies occupying pivotal positions in sports administration, thereby setting a precedent for future governance and legal challenges in similar domains.

1. The BCCI Conundrum: Navigating the Fine Line Between Autonomy and Accountability

The Board of Control for Cricket in India (BCCI), in its journey of managing the country’s cricketing affairs, has often found itself at the crossroads of autonomy and accountability. This unique position stems from its operational framework, which, while being autonomous, wields considerable influence over a sport followed passionately across the nation. The BCCI’s decision to launch the Indian Premier League (IPL) in 2007 and the subsequent amendments to its regulations to facilitate the league’s operations underline its autonomous power. However, incidents like the 2013 spot-fixing scandal, which prompted judicial intervention, highlight the complexities surrounding its accountability. The Supreme Court’s involvement, especially in deciding whether the BCCI’s actions fall under the ambit of judicial review, underscores the delicate balance the organization must maintain between exercising its autonomy and adhering to standards of accountability akin to those expected of state functions. This scenario not only reflects on the BCCI’s unique legal standing but also on the broader implications of its actions on the national sporting landscape.

2. The Anatomy of IPL’s Legal Battleground: Understanding the Crux of the Controversy

The Indian Premier League (IPL) has not just been a battleground for cricketing prowess but also a legal conundrum that has tested the boundaries of the BCCI’s operational autonomy. The legal challenges began to unfold when spot-fixing allegations emerged in 2013, leading to a probe by the Delhi police. The BCCI’s response, involving the constitution of an inquiry committee, was met with legal scrutiny, particularly from the Cricket Association of Bihar, which questioned the committee’s constitution under the BCCI’s regulations and the broader legal mandate. The Bombay High Court’s ruling that the constitution of the Probe Commission was in contravention to IPL’s operational rules, and the subsequent appeal to the Supreme Court, not only brought to light the procedural missteps by the BCCI but also set the stage for a broader examination of its legal and operational framework within the ambit of public function and judicial review.

3. Judicial Scrutiny of Non-State Actors: The BCCI’s Public Function and Its Implications

The legal discourse surrounding the BCCI has prominently featured the question of its amenability to judicial scrutiny, given its status as a non-state actor performing public functions. The Supreme Court’s observation that the BCCI, though not a ‘State’ under Article 12 of the Constitution of India, falls within the purview of the High Court’s writ jurisdiction under Article 226, marks a significant moment in understanding the judicial oversight of bodies like the BCCI. This recognition, stemming from the BCCI’s substantial control over a sport of immense national interest and its operational dynamics that mimic public functions, underscores the premise that entities performing vital public functions, even if autonomous, are subject to standards of transparency and accountability similar to those expected from state entities.

4. The Dichotomy of Power: BCCI’s Legal Status and Its National Impact

The legal scrutiny of the BCCI’s actions, especially in light of the IPL controversy, has brought to the forefront the complex dichotomy between its legal status as a private body and the public impact of its decisions. The Supreme Court’s ruling elucidates this dichotomy by highlighting the BCCI’s unique position: an autonomous body performing functions that have a profound national impact, supported implicitly by the government. This judicial acknowledgment of the BCCI’s role in the national sporting domain, despite its non-governmental status, challenges the conventional boundaries of authority and governance, suggesting a reevaluation of how legal frameworks interact with entities like the BCCI that wield significant societal influence.

5. From Cricket Pitches to Court Benches: The Evolution of BCCI’s Legal Journey

The legal journey of the BCCI, from the cricket pitches to the benches of the highest court in the land, encapsulates a broader narrative of evolving judicial perspectives on the governance of sports in India. The Supreme Court’s involvement in the BCCI’s affairs, particularly through the lens of the IPL controversy, represents a pivotal shift towards greater judicial engagement with issues of governance, accountability, and transparency in sports. This transition not only highlights the changing dynamics of sports administration in the country but also sets a precedent for the legal scrutiny of non-state actors engaged in public functions, marking a significant evolution in the legal landscape of sports governance.

Key Takeaways for the Reader:

  • The BCCI’s autonomy is tempered by its responsibility towards ensuring transparency and accountability in its operations.
  • Legal controversies, like the IPL spot-fixing scandal, have prompted judicial interventions that redefine the BCCI’s operational and legal boundaries.
  • The Supreme Court’s acknowledgment of the BCCI’s public function role, despite its non-state actor status, underlines the importance of judicial oversight.
  • The dichotomy between the BCCI’s legal status and its national impact necessitates a nuanced understanding of governance in sports.
  • The evolution of the BCCI’s legal journey reflects broader shifts in the judicial approach to sports administration, emphasizing the need for governance mechanisms that balance autonomy with accountability.


The case revolving around the legal status and the actions of the Board of Control for Cricket in India (BCCI) brings forth several nuanced observations about the intersection of autonomy, public function, and judicial oversight. The Supreme Court’s determination that BCCI, despite being an autonomous body and not a ‘State’ under Article 12 of the Constitution, falls within the purview of the High Court’s writ jurisdiction under Article 226 is particularly illuminating. This ruling underscores the principle that entities performing public functions, even if not state-owned or controlled, bear a responsibility akin to that of governmental bodies when it comes to the exercise of their powers. The court’s reasoning that BCCI’s control over cricket in India, coupled with governmental support and the lack of regulation, bestows upon it a public character, opens up broader discussions about the accountability of similar autonomous entities. For judiciary aspirants, this case serves as a critical reminder of the evolving nature of constitutional law, especially in how it applies to non-state actors wielding significant influence over public domains. It prompts future legal practitioners and policymakers to ponder the balance between autonomy and accountability, ensuring that entities like the BCCI operate transparently and justly, given their substantial impact on the public interest. This case, thus, not only clarifies the legal standing of BCCI but also enriches the discourse on governance, public responsibility, and the scope of judicial review, offering vital lessons for those aspiring to shape the future of Indian jurisprudence and society at large.


As we unravel the complexities surrounding the legal status and accountability of the Board of Control for Cricket in India (BCCI), it becomes evident that the judiciary’s intervention has set a precedent for how entities wielding significant influence over public domains are perceived and regulated. This case highlights the nuanced understanding of what constitutes a ‘State’ under Article 12 of the Constitution and extends the ambit of judicial scrutiny to include bodies like the BCCI, which, though not classified as a state, perform pivotal public functions. The Supreme Court’s ruling underscores the imperative for such organizations to operate within the framework of law, ensuring transparency, accountability, and fairness in their actions. For judiciary aspirants, this case presents an intriguing study of constitutional interpretation, the dynamics of power, and the responsibilities of entities that occupy a central role in public life. It encourages a broader reflection on the evolving nature of governance and the importance of legal oversight in safeguarding the interests of the public. As future guardians of justice, it is crucial for aspirants to appreciate the delicate balance between autonomy and accountability, and the role of the judiciary in maintaining this equilibrium for the greater good. This case not only enriches our understanding of constitutional law but also serves as a reminder of the judiciary’s role in adapting legal principles to contemporary challenges, ensuring that justice prevails in an ever-changing societal landscape.