ABSTRACT
The significance of arbitration in sports, the advantages of implementing arbitration in sports, and the reasons why an independent organization other than courts is required for conflict settlement will all be covered in the research paper. After that, the Court of Arbitration for Sports will be the main topic of the paper, along with its procedures and practices. By examining case laws and their developments, the paper aims to trace the origins and evolution of CAS, which has been discussed since its inception. The article also covers the CAS’s processes, conflict kinds, jurisdiction, and legitimacy as established in a number of seminal cases that have shaped the organization’s current standing in the sports industry. The purpose of the paper is to explain the role of arbitration in Indian sports after the aforementioned. The situation in India, where not much has been done to promote arbitration in the sports industry, will be covered in the paper. In order for the area of sports arbitration to advance and benefit the sports community, the article also aims to explain why arbitral awards urgently need to be independent of the judiciary.In order to ensure compliance with global best practices, recommendations include the creation of a national sports arbitration tribunal operating under the auspices of the Arbitration and Conciliation Act, 1996. Along with raising awareness among sports stakeholders and encouraging cooperation between legal professionals and sports regulatory bodies, the paper also promotes capacity building through arbitrators’ training programs. In conclusion, by offering a specialized, effective, and equitable forum for conflict resolution, sports arbitration has great promise to revolutionize dispute settlement in Indian sports. Greater trust and openness in the sports ecosystem can be fostered by positioning India as a leader in sports governance and dispute resolution through the implementation of proactive initiatives and organized reforms.
KEYWORDS: ARBITRATION, EVOLUTION, COURT, SPORTS, JURISDICTION
INTRODUCTION
Arbitration is a mechanism that allows parties to receive prompt justice without going through the difficulties of litigation. Since athletes typically have brief careers, the lengthy and onerous legal procedure can be detrimental to a sports-person’s career in terms of both time and mental harassment1. For this reason, it is more important than ever that matters be resolved quickly.
The resolution of conflicts occurring in the field of sports law assumes a significant role in the increasingly globalized and commercialized sports industry.Many organizations, including FIFA2, the AIFF3, and many more, have recognized sports arbitration as a legitimate practice. The International Tennis Federation’s4 disputes are also heard by the Court of Arbitration for Sports.Many of these organizations even have their own Dispute Resolution Chambers to help athletes resolve disputes within their respective sports. The Court of Arbitration for Sports (CAS) is the organization that uses arbitration to help resolve disputes in sports. The CAS has handled an exceptionally broad variety of cases since its founding. Both commercial and disciplinary problems are settled by this organization. These issues include doping, authorities’ arbitrary rulings, athletes’ eligibility, and many more5.
English and French are the two languages recognized by the CAS as working languages. The regular division and the appellate division are the two divisions of CAS that provide arbitration services. The applicable law in CAS arbitration is Swiss law, unless the parties agree otherwise6. Additionally, the parties are bound by the arbitration awards made by this Court or the interim tribunals it established in the same manner as court rulings.
RESEARCH METHODOLOGY
This article is descriptive in style, and the study is based on both primary and secondary sources to provide a thorough analysis of the exploring the evolution and potential of sports arbitration in India. The research uses primary sources, such as official reports, court rulings, and legislative documents, as well as secondary sources, such as newspapers, journals, and websites. To give a global perspective, comparative studies with other jurisdictions are also used.
1 Antonio Rigozzi and William McAuliffe, Sports Arbitration, Levy Kaufman Kohler,last accessed 14/12/24, 10:00pm IST, https://lk-k.com/wp-content/uploads/RIGOZZI-MCAULIFFE-GAR-Euro.-Middle-East.-and-Afr.-Arb.-Review-2013.pdf
2 Art. 11 5(c) Constitution of All India Football Federation,accessed 14/12/24, 10:00pm IST, available at https://www.the- aiff.com/media/uploads/2019/12/AIFF-Constitution.pdf
3 Art. 104(c) FIFA Statutes, Regulations Governing the Application of Statutes, Standing Orders of the Congress,
4 Maria Sharapova v. International Tennis Federation, CAS 2016/A/4643,last accessed 14/12/24, 10:00 pm IST https://jurisprudence.tas-cas.org/shared%20documents/4643.pdf
5 Eris T.Gilson, “Exploring the Court of Arbitration for Sport”, Law Library Journal, Vol. 98-3,
6 Devyani Jain, Judicial Trend of Intervention in Sports Arbitration and its Future in India, 1 IJAL 36, 37 (2012).
ORIGIN AND EVOLUTION OF CAS
The concept of a sport conflict resolution system first emerged in the 1980s, when international sports- related disputes were on the rise and there was no independent authority specializing in sports-related topics whose decisions would be binding.In 1981, the notion of establishing an arbitral jurisdiction specifically focused on settling conflicts that are either directly or indirectly associated with sports was firmly established. At the 1981 Rome meeting of the International Olympic Committee, IOC President H.E. Juan,IOC member H.E. Judge KébaMbaye, who was a judge at the International Court of Justice in The Hague at the time, was nominated by Antonio Samaranch to lead the working group charged with creating the laws of the soon-to-be “Court of Arbitration for Sport7.”
The CAS laws were formally accepted by the IOC in 1983, and they became operative on June 30, 1984. Under the direction of President Mbaye and Secretary General Mr. Gilbert Schwaar, the Court of Arbitration for Sport commenced operations at that point8.The 1984 CAS statute was accompanied by some set of procedural regulations. The CAS was made up of 60 members nominated by the IOC, the National Olympic Committees (NOCs), the International Federation (IF), and the IOC President. Each of these originations was permitted to appoint 15 members. The president of the IOC must select its members from outside of these three groups. All of CAS’s operating expenses will be covered by the IOC. With the exception of financial disputes, when the parties may be asked to pay a portion of the costs, the CAS hearings were free of charge. The annual budget will only be approved by the CAS president. Only the IOC executive board’s proposal at the IOC session might change the CAS statute9.
Prior to 1994, the CAS statute’s rules and regulations only allowed only one kind of proceeding, regardless of the type of dispute. The claimant has submitted his request to the CAS together with the arbitration agreement.After that, a “Requests’ panel” reviewed the request and determined whether it was admissible. If necessary, the panel of arbitrators would then be called upon to hear the case and render a verdict. Therefore, despite the panel’s decision to dismiss the action, the parties were still free to proceed. In addition to this contentious process, there was an advisory method available to any individual athlete or organization10.
SPORTS ARBITRATION IN INDIA: INDIAN COURT OF ARBITRATION FOR SPORTS (ICAS)
An important step was taken in the Indian context in 2011 when the Indian Olympic Association, acting at the instruction of the International Olympic Committee, established an Indian court of Arbitration for Sports
7 History of CAS, Court of Arbitration for Sport,accessed 14/12/24,10:00pm IST,https://www.tas-cas.org/en/general – information/history-of-the-cas.html#:~:text=The%20CAS%20status%20of%20 1984,President%20(15%20 members%20 each)
8 Ibid
9 Kane, Darren,Twenty Years on: An Evaluation of the Court of Arbitration for Sport [2003] MelbJlIntLaw 10; (2003) 4(2) Melbourne Journal of International Law 611,last accessed 14/12/24, 10:00 pm IST, https://classic.austlii.edu.au/au/journals/MelbJIL/2003/10.html
10 Supra Note 7
(ICAS) with eight panellists to decide disputes that arise in athletic arenas. Retired judges from the Supreme Court of India and many High Courts made up the panel. The panelists included retired Justices R.S. Sodhi,
B.A. Khan, Usha Mehra, Lokeshwar Prasad, and S.N. Sapra, as well as ICAS Chairperson Dr. A.R. Lakshmanan and Mr. M.R. Culla.
Since 2011, when it was first reported that such a panel would be formed, it is believed that no significant action has been accomplished. It is unclear whether the aforementioned panel is in operation, whether particular rules and regulations have been framed, and whether the panel has held hearings or made decisions in the last five to six years, according to the material that is now available11.
INDIAN PROSPECTIVE
The Arbitration and Conciliation Act 1996 (Act) contains the Indian arbitration legislation. The UNCITRAL Model Law on International Commercial Arbitration12 from 1985 and the UNCITRAL Arbitration Rules from 1976 serve as the foundation for the Act.According to the Act’s Statement of Objects and Reasons, India’s monetary reforms would only become persuasive if the nation’s dispute resolution procedures are aligned with universal administration13.Sports, physical education, and allied fields all make use of sports law. It is mentioned as a comprehensive law that regulates the area where sports and law meet. There is currently a growing trend of cooperation between the fields of law and sports, which has raised interest in a more thorough understanding of the relationship between the two14.
Sports arbitration is a developing area of alternative dispute resolution that takes into account fresh ideas and frameworks to meet the unique requirements of sporting conflicts. It aims to provide a reasonable means of resolving conflicts in light of several prevailing elements of sports law. This covers things like the necessity for quick trials to maintain the dignity of exhausting events, the requirement for confidentiality in such awards, and lower dispute settlement costs15.
EFFECTS OF CAS
The international venue provided by the CAS has not been utilized very often in India. In any event, four competitors—Ashwini A.C., Sini Jose, Priyanka Panwar, and Tiana Mary Thomas—have recently brought attention to the significance of CAS as a global platform for sports dispute resolution. In December 2011, the National Anti-Doping Disciplinary Panel (or “NAADP”) punished these athletes for a year for using
11 Rajiv Dutta, Sports Arbitration in India: A Wake-Up Call, Legally India,last accessed 14/12/24, 10:00 pm IST, http://www.legallyindia.com/ Blogs/sports-arbitration-in-india-a-wake-up-call.
12 UNCITRALArbitration Rules General Assembly Resolution 31/98,last accessed 14/12/24, 10:00 pm IST, available at: https://www.uncitral.org/pdf/english/texts/arbitration/ arb-rules/arb-rules.pdf.
13 S Kachwaha & D Rautray, Arbitration In India: An Overview,last accessed 14/12/24, 10:00 pm IST https://ipba.org/media/fck/files/Arbitration%20in%20India.pdf.
14 Government of India Ministry of Youth Affairs and Sports,last accessed 14/12/24, 10:00 pm IST, available at: http://yas.nic.in,
15 Sports arbitral awards have been issued by arbitral bodies within 24 hours under institutional arbitration. For instance, Article 18 of the Arbitration Rules for the Olympic Games of the XXVII Olympiad in Sydney, 29 November 1999, stated that decisions were to be rendered within 24 hours of the application for arbitration is filed. This is a unique feature of Ad Hoc Division (ADH) of the CAS which is set up specifically for particular sporting events to deal with disputes arising during the event.
steroids while representing India in the Asian Games and the CWG. The World Anti-Doping Agency (“WADA”) used other CAS decisions in support of a harsher penalty during the appeal before the NAADP16.
Furthermore, if the verdict is unacceptable, either side might file an appeal with the CAS17. In this way, it produces the belief that when the dissatisfied party has exhausted remedies at the national level, the CAS is typically brought closer at the claim stage.
It is now believed that the Australian Court’s decision in Raguz v. Sullivan and other similar instances has established the CAS’s standing as a global dispute settlement organization by preserving and validating its jurisdiction. However, in the Indian context, the decisions made by international arbitration organizations, such as the CAS, were implausible following the ruling in the Venture Global Case18 by the Indian Supreme Court.The court held that Indian courts could implement their jurisdiction to set aside foreign arbitral awards in pursuance of the ratio of Bhatia International19 case20.But then there are recent cases to give difference to that establishment.
THE JURISDICTION OF INDIAN COURT IN RESPECT TO FOREIGN ARBITRAL AWARDS
Provisions for implementing the New York Convention21 and the Geneva Convention22 on the enforcement of international arbitral verdicts are found in the second section of the Arbitration and Conciliation Act of 199623. This was passed in order to reassure international investors that the enforcement of foreign awards would be more transparent and compliant with the New York Convention. There was no provision to set aside foreign awards in India since Part 1 had not been applied to Part 2 and there was no clause in Part II granting the Indian Courts the authority to entertain an application to contest international awards.However, in the nation where the award was made or in accordance with its regulations, international honors may be revoked or suspended24.
16 Mail Today Bureau, WADA appeal another setback for four quarter milers, India Today,last accessed 14/12/24, 10:00 pm IST, available at:http://indiatoday.intoday.in/story/ wada-appealanother-setback-for-four-quarter-milers/1/172803.html,
17 Times News Network, WADA Seeks Two-Year Ban On Ashwini & Co, The Times Of India,last accessed 14/12/24, 10:00 pm IST, available at: http:// Timesofindia.Indiatimes.Com/Sports/Moresports/Others/WADA-Seeks-Two-Year-Ban-On-Ashwini- Co/articleshow/11815497.cms,
18 (2008) 4 SCC 190
19 (2002)4 SCC 105
20 Supra Note 6
21 The Convention Conndation Action and Enforcenient of Foreign Arbitral Awards (New York, 10 June 1958) (‘the New York Convention). India became a signatory to this Convention on 13 July 1960.
22 The Convention on the Execution of Foreign Arbitral Awards (Geneva, 26 September 1927) (ch Geneva Convention), India became a signatory to this Convention on 23 October 1937 (one Amongst six Asian nations to become a signatory)
23 Arbitration and Conciliation Act, 1996.
24 The 1996 Act, s 48(1)(e), corresponding to Art V(e), The New York Convention, 1958
As per the initial format of the Act there existed a clear division between ‘domestic’ and ‘foreign’ awards. However, the Bhatia International case25 later weakened this divide. The Honorable Supreme Court of India ruled in this case that Section 9 might be invoked to assist arbitral proceedings abroad.
As a result, Part I of the Act could now be applied to foreign awards in addition to domestic arbitral awards. The Supreme Court argued in this case that, in the absence of the word “only,” an inclusive interpretation of Section 2(2) of the Act26 verifies Part I’s applicability to domestic awards but does not preclude its applicability to foreign awards. If, on the other hand, Part I is explicitly or implicitly excluded by the parties in the arbitration agreement, then such an application is not feasible.
The Hon’ble Supreme Court broadened the definition of “public policy”under section 34 to allow for the examination of an arbitral award on its merits in the historic ruling of Oil and Natural Gas Corp v. Saw Pipes Ltds27. Furthermore, it was decided that an award could be contested on the grounds that it violates the Act, any other substantive law that applies to the parties, or the conditions of the contract. In addition, the court declared that an award that violates Indian public policy is“partially illegal” and goes against India’s“interest”as well as its “justice or morality”.
In order to set aside a foreign award in 2008, the SC used the Bhatia International28case’s concept in the Venture Global29case for a S.346 application. The court thus departed from the model legislation framework, which did not grant the domestic court the authority to invalidate foreign awards. According to the Supreme Court’s ruling in ONGC v. Saw Pipes30, Indian courts may permit a challenge under Section 34 of the Act if an award made by an International Commercial Tribunal that is to be carried out in India but violates Indian law. Such a challenge must meet the grounds outlined in Section 34 as well as the grounds under the expanded scope of public policy.But now that the Arbitration and Conciliation Act of 2015 has been passed, there’s a chance that the arbitral ruling will be carried out impartially.
The Supreme Court clearly demonstrated its intention to limit unjustified judicial interference in foreign awards in the Yograj Infrastructure case31. In this case, the court decided that the ruling in Bhatia International32 and the ensuing comparative rulings33 would no longer be relevant after the parties
25 (2003) 5 SCC 22
26 This section lays down the extent of application of the Act.
27 2003 (5) SCC 705.
28 (2008) 4 SCC 190
29 Supra Note 18
30 Supra Note 705
31 Yograj Infrastructure Ltd v. Ssang Yong Engineering and Construction Co Ltd, AIR. 2011 S.C. 3517
32 Appeal (Civil) 6527 (2001)
33 Supra Note 6
specifically agreed that the arbitration procedures would be carried out in accordance with SIAC rules34, including Rule 32.
Both the Supreme Court of India and the Bombay High Court, in their pro-arbitration rulings in World Sport Group (Mauritius) Ltd v. MSM Satellite (Singapore) Ltd35 and HSBC PI Holdings (Mauritius) Ltd v. Avitel Post Studioz Ltd and others36, held that fraud matters should be handled by the arbitral tribunal in accordance with the arbitration agreement entered into between the parties rather than by the courts, renouncing a previous, dubious line of authority that had held otherwise37.
Following the foundation established by the Supreme Court of India in cases like Shri Lal Mahal v. ProgettoGrano Spa38 and Bharat Aluminum Co. Ltd. v. Kaiser Aluminum39, the two cases demonstrate an emerging judicial trend on the part of Indian courts to support legitimate international arbitration agreements between parties and refrain from interfering with the international arbitral process.
INDIAN COURT OF ARBITRATION FOR SPORTS
Sports bodies and the national sports advancement association must be strongly encouraged by the Indian government’s Ministry of Youth Affairs & Sports to update and modify them in order to address the challenges of today’s games, which have become highly competitive and commercialized.
Additionally, the necessity to oversee games has evolved into a need for a sports regulatory framework that is present in several countries due to the growing commercialization of games following the 2010 Delhi XIX Commonwealth Games. It is now much more crucial that the Indian Sports Administrative Association update its structures, frameworks, and forms and become more athlete-driven, responsible, and direct in their roles as a result of the Indian Courts’ intervention.
It was therefore necessary to establish a free assertion and intercession component based on comparative actions conducted in the UK (The UK Sport Dispute Resolution Panel)40 and Australia (The National Sports
34 SIAC, SIAC Rules 2013,last accessed 14/12/24, 10:00 pm IST,available at: http://www.siac.org.sg/our-rules/rules/siac-rules- 2013#siac_rule32.
35Civil Appeal No. 895/2014, Petition for Special Leave to Appeal (Civil) No(s).34978/2010, Supreme Court of India (unreported), (Jan. 24, 2014).
36 Arbitration Petition No. 1062/2012, High Court of Bombay, India, (Jan. 22, 2014).
37 N. Radhadkrishnan v. Maestro Engineers & Ors 1 SCC 72(2010), India Household Healthcare v. LG Household Healthcare 5 SCC 510 (2007), Hindustan Petroleum v. Pink City Midway Petroleums 6 SCC 503(2003)
38(8) SCALE 480(2013)
39Bharat Aluminium Co Ltd v. Kaiser Aluminium Technical Service Inc 9 SCC 649(2012), overruling the much-criticised case of Bhatia International v. Bulk Trading SA 4 SCC 105(2002).
40Sport Resolution, Resolving Disputes in Sports,last accessed 14/12/24, 10:00 pm IST, available at: https://www.sportresolutions.co.uk/,
Dispute Centre)41 in order to identify such issues and ensure that the games progressed in accordance with the Olympic Charter and with regard to the goals and objectives of Comprehensive Sports Policy.
Members of the Rajya Sabha in the Indian Parliament were assured by the Union Cabinet Minister for Youth Affairs & Sports that the Central Government has made recommendations for the establishment of an alternative sports law42. The Minister also assured the Parliament that the government has carefully reviewed the various sports regulation frameworks found in other countries and is weighing its options, including approving a national sports law to improve sports administration43.
An important development in Indian sports law occurred in 2011 when the International Olympic Committee directed the Indian Olympic Association to establish an Indian Court of Arbitration for Sports (“ICAS”), composed of eight panelists, to arbitrate disputes arising within the sports regime. The panelists include retired judges from several High Courts and the Supreme Court of India. HMJ (Retd.) Dr. A.R. Lakshmanan, the ICAS Chair, Mr. M.R. Culla, retired justices R.S. Sodhi, B.A. Khan, Usha Mehra, Lokeshwar Prasad, and S.N. Sapra are on the panel44.
It is unclear whether the previously mentioned board is utilitarian based on an open analysis of all daily paper data and other available data. It is also unclear whether any hearings have been held, whether specific rules and regulations have been restricted, and whether any particular decisions have been made by such a board in the last three to four years. It is believed that no strong action has been taken to establish this board since 2011, when the first rumors circulated that one was to be formed.
In actuality, a recent controversy involving the doping of an Indian swimmer would have been brought to such a panel if it had been functioning. In reality, the aforementioned disagreement was sent to the CAS’s Alternative Hearing Center (or “AHC”) in Abu Dhabi, where the Indian swimmer was found guilty by the Sole Arbitrator in a comprehensive ruling dated April 8, 201545.
The ICAS was a step toward expanding a legal area and effectively resolving disputes as soon as possible without requiring a plan of action or an indulgent litigation procedure. In any case, action must be taken to make such enterprises a reality. Similar actions must be made to promote the Indian Court for Arbitration in Sports, just as the CAS has progressed the AHC in Abu Dhabi, which was established in collaboration with
41 Sportsa, State Sports Dispute Centre,last accessed 14/12/24, 10:00 pm IST, available at: http://www.sportsa.org.au/member- information/state-sport-dispute-centre,
42Dr. M. S. Gill, Minister of Youth Affairs & Sports, Govt. of India, answer the Question No. 2105 in the Parliament of India (Rajya Sabha), (Aug. 12, 2010)
43 R. K. Jain, Sports Regulations in India, Sports Law Knowledge Lecture & Seminar,last accessed 14/12/24, 10:00 pm IST, available at: www.sportslawindia.info,
44 Supra Note 11
45 CAS, The appeal of Amar Muralidharan is dismissed by the CAS following first ever hearing held at the CAS Alternative Hearing Centre in Abu Dhabi,last accessed 14/12/24, 10:00 pm IST,available at: http://www.tas-cas.org/en/general- information/news-detail/article/the-appeal-ofamar-muralidharan-is-dismissed-by-the-cas-following-first-ever-hearing-held-at-the- cas-alternative-hearing-centre-in-abu-dhabi-1.html.
the Abu Dhabi Judicial Department. It is believed that such a tribunal would be very successful in making a decision if proper measures had been implemented to promote and enhance the rationale for sports arbitration within India.
Under Indian law, sports arbitration is still a relatively new concept. It may be suggested that “sports arbitration” be included as a class in the Arbitration and Conciliation Act of 1996, which would give it a sense of parliamentary legitimacy, or it may be consolidated using a system of separate model conduct standards to which leagues may refer.One must imagine that BCCI46 and IPL47-related matters that have taken national consideration could have been decided as quickly as possible without causing excessive melodrama and embarrassment if a strong Alternate Dispute Resolution framework had been established.
CONCLUSION
Facilitating the delivery of justice to all people from all walks of life in a timely and efficient manner is the ultimate human endeavor. Like anything else, sports are one of those industries where it is necessary to guarantee due process of law, which provides prompt justice and fair and equal relief. Sports, and thus lexsportiva, have gained greater importance in terms of careers, money, investment, and profits in this age of globalization and rising economies.
Since a sportsman’s career is frequently short-lived, extensive procedures and time-consuming litigation troubles are too traditional and antiquated to be reserved for him or any other stakeholder in the practical sense. This necessitates the use of an alternate dispute resolution process, which the Court of Arbitration for Sports provides through arbitration proceedings, which settle conflicts more quickly even though they take longer than the legal system.
A hybrid dispute resolution process combines elements of two or more typically distinct processes into a single process. Mediation-arbitration, or “med-arb,” is the most well-known mixed procedure. It is a hybrid of mediation and arbitration. There are therefore no agreed-upon principles for how the process should be conducted. The disagreement is brought to mediation by the parties, and following a mutually agreed-upon period of time or an irrevocable stop, it is transferred to arbitration, where an arbitrator makes the final decision. Arbitration, which comes after mediation, is a process that provides a framework for resolving disputes collectively, meaning that the expense and delay of the judicial system are entirely avoided.
The mediation-arbitration system has the advantage of providing both the possibility of a resolution based on the parties’ personal agreement and, if such an understanding is not reached, the guarantee of a decision based on the arbitrator’s legally enforceable conclusion as the arbitral award.A situation where there seem to
46 Board of Control for Cricket in India,last accessed 14/12/24, 10:00 pm IST, available at: http://www.bcci.tv/
47 Indian Premier League,last accessed 14/12/24, 10:00 pm IST,available at: http://www.iplt20.com/
be potential solutions including agreements that only the parties can make, such enduring or well-established business relationships, is the best fit for this hybrid procedure. As a result, there is a greater chance that they will appropriately share their needs and desires with the mediator at the caucus and present their arguments regarding their rights in the subsequent arbitration phase. As a result, it may be used to settle the sports disagreement more quickly.
Regarding ICAS’s future, it is important to convey that it has started to carry out its mandate in a constructive manner and with an understanding of sports disputes. India has a very lax sports law, and action must be taken to address these disputes so that athletes, sports federations, and other auxiliary organizations involved in Indian sports can move forward with understanding their respective game-related goals rather than pondering how to settle scores with or against one another48.
It can be safely concluded that arbitration in the sports industry is a successful alternative dispute resolution mechanism that benefits athletes as well as their regulatory bodies or authorities, given recent instances of arbitral awards resolving various disputes in the sports industry.
Overall, it is reasonable to conclude that arbitration is a valid, independent, and efficient way to settle conflicts, uphold and establish compliance with laws and regulations, and offer relief and a remedy to support the regime of justice and fairness in competition and other facets of sports.
*****
Name: Jiss Anthony
College: 7th Semester B.A.LL.B(Hons.), JSS Law College, Mysuru
*****
48 Supra Note 11