Is BCCI a ‘State’ under Article 12?

No. The Supreme Court held BCCI is not ‘State’. However, it performs public functions.

Can writs be issued against BCCI?

Yes, under Article 226, because BCCI performs public duties that affect the public at large.

What was wrong with IPL Regulation 6.2.4?

The amendment allowed administrators to have commercial interests. The Court found this against the game’s core anti-corruption principles.

Which Court decided this case?

The Supreme Court of India in 2015, citation: [2015] 3 SCC 251.

Why does this case matter for public law?

It shows that bodies not classified as ‘State’ can still face writs if they carry out public functions.

Board of Cricket Control of India v. Cricket Association of Bihar

[2015] 3 SCC 251 — Article 12 ‘State’, Article 226 writs, and IPL Rule 6.2.4 (conflict of interest)

Supreme Court of India 2015 Bench: Supreme Court Public Law Reading time: ~9 min India

Author: Gulzar Hashmi Published: October 24, 2025 Slug: board-of-cricket-control-of-india-v-cricket-association-of-bihar

PRIMARY_KEYWORDS: BCCI Article 12, Article 226 writ, IPL Rule 6.2.4 SECONDARY_KEYWORDS: public function test, conflict of interest, SCC 2015

Quick Summary

This case settles two points:

BCCI is not ‘State’ under Article 12.
Yet, BCCI’s public functions make it open to writs under Article 226.

The Court also struck down the IPL Regulation 6.2.4 amendment that allowed administrators to keep commercial interests in IPL/CLT20. The Court said this creates a clear conflict of interest and goes against the game’s anti-corruption goals.

Issues

Is BCCI a ‘State’ under Article 12? If not, can High Courts still issue writs against it under Article 226?
Is the IPL Regulation 6.2.4 amendment (permitting administrators’ commercial interests) valid in law?

Rules

Article 12: Defines ‘State’ (Govt of India, State Govts, Parliament/Legislatures, and local/other authorities under Govt control).
Article 226: High Courts can issue writs to any person/body performing public duties within their territory.
Anti-corruption & conflict-of-interest principles in cricket governance: officials must avoid commercial stakes that clash with regulatory roles.

Facts (Timeline)

2007–2008: BCCI launches the IPL. On 27 Sept 2008, N. Srinivasan becomes Secretary. BCCI amends Reg. 6.2.4 to keep IPL/CLT20 out of its conflict rules.

2013: Delhi Police probe spot-fixing. Names crop up around Rajasthan Royals and Chennai Super Kings. Gurunath Meiyappan (linked to CSK; son-in-law of Srinivasan) and Raj Kundra (RR) are in focus.

BCCI forms an internal committee (Sanjay Jagdale + two retired Madras HC judges) to inquire.

PIL by Cricket Association of Bihar in Bombay HC challenges the committee; seeks panel of retired SC judges; asks to end CSK/RR contracts and begin action against Srinivasan.

30 Jul 2013: Bombay HC holds the probe commission contrary to IPL rules (Prov. 2.2 & 6). It declines to set up a new retired-judge panel.

8 Oct 2013: On appeal, the Supreme Court steps in and sets up the Mudgal Committee (Justice Mukul Mudgal) to investigate IPL allegations.

Arguments

Appellant (BCCI)

BCCI is a private body; not controlled by Govt; hence not ‘State’ under Article 12.
Internal rules allow BCCI to run cricket and inquiries.
Reg. 6.2.4 amendment is a policy choice.

Respondent (Cricket Association of Bihar)

BCCI controls Indian cricket and national selection—these are public functions.
Conflict-of-interest change in Reg. 6.2.4 undermines integrity; violates anti-corruption norms.
Courts should supervise to protect the game and the public.

Judgment (Held)

BCCI ≠ ‘State’ under Article 12.
But BCCI is amenable to writs under Article 226, as it performs public functions (team selection, control of cricket in India).
Regulation 6.2.4 amendment (allowing admins’ commercial interests in IPL/CLT20) is unsustainable. It clashes with core anti-corruption values; creates conflict of interest; hence impermissible in law.

Ratio Decidendi

A private body that dominates a public field and affects public rights can be tested on public law standards via Article 226, even if it is not ‘State’ under Article 12. Policies that place regulators in a position of conflict of interest fail legality as they defeat the integrity of the sport.

Why It Matters

Clarifies the public function test for writs under Article 226.
Strengthens sports governance against conflicts of interest.
Guides future cases on private bodies with public impact.

Key Takeaways

Not State, still accountable: Private power with public reach can face writs.
No conflicts for regulators: Commercial stakes + regulatory role = unlawful.
Article 226 is wide: Focus is on duty and effect, not only on status.

Mnemonic + 3-Step Hook

Mnemonic: “Play, Public, Purity”

Play: Cricket body runs the game (BCCI).
Public: Public function → Article 226 writs apply.
Purity: No conflicts (Reg. 6.2.4 struck).

IRAC Outline

Issue

BCCI as ‘State’? Writ under Art. 226? Validity of IPL Reg. 6.2.4 amendment?

Rule

Art. 12, Art. 226; anti-corruption norms; conflict-of-interest principles.

Application

BCCI’s control of cricket affects public; so writs lie; conflict rule is unlawful.

Conclusion

Not ‘State’; writs allowed; Reg. 6.2.4 amendment invalid.

Glossary

Article 12: Defines ‘State’ for Part III (Fundamental Rights).
Article 226: High Courts’ power to issue writs for rights and public duties.
Conflict of Interest: When a person’s personal gains clash with their duty to act fairly.
Public Function: A task that affects the public and carries public responsibilities.