Sports Authority Of INDIA & Ors. vs. Shree Ram Dharmik Ramlila Samiti Regtd & Anr.

Held

The Court held that there is no specific power under Clause 34(a) of SAI's Memorandum of Association for granting discounts or concessions for non-sporting events. The Court found that SRDRS's initial booking for 34 days was altered to 24 days after seeking a concession, which effectively blocked DDDRS's opportunity to book the venue. The Court noted that SAI and its officials failed to act fairly towards DDDRS by granting a concession without any enabling power and by not affording DDDRS an opportunity to book the venue at the applicable rate before granting any concession to SRDRS. The Court found that the actions of SAI officials did not reflect fairness towards DDDRS. Consequently, the Court found no reason to interfere with the Impugned Judgment of the learned Single Judge. The appeals were dismissed.

Facts

The dispute concerns the booking of a venue managed by the Sports Authority of India (SAI) for Ramlila performances. Dakshinii Delhi Dharmik Ramlila Samiti (DDDRS) sought to book the venue for 22 days from 05.10.2023 to 27.10.2023. They were informed that booking required online application 120 days prior. DDDRS discovered that Shree Ram Dharmik Ramlila Samiti (SRDRS) had provisionally booked the venue for 43 days (later reduced to 24 days) from 18.09.2023 to 30.10.2023 for a nominal payment of Rs. 11,800/- plus GST, whereas the actual rental charges were Rs. 2,25,000/- plus GST per day. DDDRS alleged collusion and arbitrariness, leading to a writ petition. The learned Single Judge directed SAI to recover Rs. 2,25,000/- plus 18% GST from SRDRS, which SRDRS deposited.

Key Issues

1. Whether the learned Single Judge erred in directing the recovery of Rs. 2,25,000/- plus GST from SRDRS, considering the powers under Clause 34(a) of SAI's Memorandum of Association and past practice, thereby challenging the legality of the concession granted to SRDRS. (Question of law) 2. Whether the booking process conducted by SAI was fair, transparent, and non-arbitrary, particularly in relation to the opportunity afforded to DDDRS. (Question of mixed law and fact) Contentions: Petitioner (DDDRS): SAI and its officials colluded with SRDRS by initially booking the venue for 34 days and then curtailing it to 24 days, thereby unfairly blocking DDDRS's opportunity to book. The concession granted to SRDRS was arbitrary and lacked any enabling power. Revenue/State (SAI): The booking process was fair and transparent. The Competent Authority rightly exercised its powers under Clause 34(a) of the Memorandum of Association. Therefore, the direction to recover the full rent was erroneous. SRDRS: It booked the venue provisionally and sought a concession, which was allowed by the Competent Authority under Clause 34(a) in accordance with law and past practice. The learned Single Judge's direction to recover the full rent was illegal.