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
SL. PARTICULARS PAGE
No. 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 of India with Affidavit
7. 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.
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/14-15/2815/3371 dated
21/23.10.2015.
25. C.M. No. _______ of 2015 :
An Application for Directions with
Affidavit.
26. Vakalatnama

27. Court Fee

AMIT A. PAI
NEW DELHI ADVOCATE FOR THE
PETITIONERS
DATE: 01.02.2016
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,
DATE: SUPREME COURT OF INDIA,
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
AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
NEW DELHI
OLD LAWYERS CHAMBERS,
DATE: SUPREME COURT OF INDIA,
01.02.2016 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,
New Delhi 110001.
2. Shri. Bishan Singh Bedi, Petitioner No. 2
Cricket Abode,
Village Jonapur, Mehruli,
New Delhi -
3. Shri. AkashLal, Petitioner No. 3
1196, Sector A, Pocket B,
VasantKunj, New Delhi
110070.
4. Shri. Maninder Singh, Petitioner No. 4
52, MausamVihar,
Delhi 110052.
5. Gurucharan Singh, Petitioner No. 5
H-279, Rama Krishna Vihar
Apts.,
I.P. Extension, Delhi 110092.
6. Sameer Bahadur, Petitioner No. 6
 A-51, IInd Floor,
SwasthyaVihar,
New Delhi 110092.
Vs.
1. Delhi & District Cricket Respondent No. 1
Association,
Through its President,
Feroze Shah Kotla Grounds,
New Delhi 110020.
2. Union of India Respondent No. 2
Through Secretary,
Ministry of Urban
Development, UdyogBhavan,
New Delhi.
3. Government of NCT of Delhi Respondent No. 3
Through Chief Secretary,
Delhi Secretariat, New Delhi.
4. Central Bureau of Respondent No. 4
Investigation,
Through its Director,
CGO Complex,
Lodhi Road, New Delhi
110003.
5. Municipal Corporation of Delhi, Respondent No.5
New Delhi.
6. Shri. Sneh Prakash Bansal, Respondent No.6
President DDCA,
C-66, Friends Colony (East)
New Delhi-110065
7. Shri. NarendraBatra, Respondent No.7
W-11, Greater Kailash 2,
New Delhi -
8. Shri. C.K. Khanna, Respondent No.8
Vice President DDCA
& Vice President BCCI,
192, Kailash hills,
 New Delhi-110065
9. 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, Respondent No.
Hony. Joint Secretary (Company 15
Affairs),
WZ-459/1 Street No.24 Shiv
Nagar, Tilak Nagar, New Delhi-
58,
16. Shri. ArunJaitley, Respondent No.
Former President DDCA, 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 Respondent No.

India, 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

AMIT A. PAI
NEW DELHI ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK, OLD LAWYERS
DATE: 01.02.2016
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 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, 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 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:

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 there are serious allegations of

4 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 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 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 under the relevant rules

enumerated under Chapter v of the

Chartered Accountants Rules, 2007 vide its

letter dated 20.11.2015.

01.02.201 Hence the present Writ Petition

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 A COURT MONITORED
INVESTIGATION BY THE CBI TO INVESTIGATE THE
CRIMINAL OFFENCES COMMITTED BY THE
ADMINISTRATORS OF RESPONDENT NO. 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. 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 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 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

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 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- 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 ____].

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:

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 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

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 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 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 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 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

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 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 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 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.

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
NEW DELHI
OLD LAWYERS CHAMBERS,
DATE: SUPREME COURT OF INDIA,
01.02.2016 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 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.

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.

AMIT A. PAI
ADVOCATE FOR THE PETITIONERS
105, A.K. SEN BLOCK,
NEW DELHI
OLD LAWYERS CHAMBERS,
DATE: SUPREME COURT OF INDIA,
01.02.2016 NEW DELHI - 01
Tel.: +91 9953557798
Filed by