Facts of the Case
The appellant, Youngsters FC, a football club and
permanent member of Football Delhi (DSA), was participating in football
competitions and was placed in the ‘A’ Division.
An order dated 14.07.2018 (communicated on 03.08.2018)
relegated the appellant to ‘B’ Division, imposed a fine of ₹5,000, debarred its
Manager and Coach for one year, and reprimanded 16 players.
The appellant challenged this decision by filing an appeal under the association’s rules. However, despite the rules mandating arbitration, no effective arbitral tribunal was constituted, leading the appellant to approach the court under Section 9 of the Arbitration and Conciliation Act.
Issues Involved
- Whether
the appellant is entitled to interim relief when the arbitral tribunal is
not effectively constituted.
- Whether
delay or bias concerns in constitution of the arbitral tribunal justify
judicial intervention.
- Whether disciplinary actions should be stayed pending arbitration proceedings.
Petitioner’s Arguments (Youngsters FC)
- The
arbitral tribunal was either not properly constituted or not
functional, rendering the remedy illusory.
- One
arbitrator had prior association with the respondent, raising apprehension
of bias.
- The
tribunal proceedings were delayed due to unavailability and intended
recusal of arbitrators.
- The appellant was effectively left without remedy, necessitating court intervention.
Respondent’s Arguments (Football Delhi - DSA)
- The
respondent submitted that a fresh arbitral tribunal was in the process
of being constituted.
- The dispute should be adjudicated through arbitration as per the governing rules of the association.
Court’s Findings / Order
- The
Court observed that the appellant cannot be left remediless due to
delay or inefficiency in constitution of the arbitral tribunal.
- The
disciplinary order dated 14.07.2018 (communicated on 03.08.2018)
was kept in abeyance.
- The
respondent was permitted to constitute a fresh arbitral tribunal,
which would continue the hearing of the appeal.
- The interim protection granted earlier was made absolute until disposal of the appeal before the arbitral tribunal.
Important Clarifications by Court
- Courts
can intervene under Section 9 where arbitration remedy becomes
ineffective.
- Delay
in tribunal constitution or procedural deadlock justifies judicial
protection.
- Interim relief ensures that irreparable harm is prevented pending arbitration.
Link to download the order - https://delhihighcourt.nic.in/app/case_number_pdf/2019:DHC:927/VIG12022019FAO5412018.pdf
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