Case Note & Summary
The Supreme Court dismissed the appeal filed by cricketer S. Sreesanth challenging the life ban imposed by the Board of Control for Cricket in India (BCCI) for alleged spot-fixing during an IPL match on 9 May 2013. The appellant was arrested by Delhi Police on 16 May 2013 on allegations of spot-fixing, and BCCI suspended him on 17 May 2013. A one-man commission headed by Mr. Ravi Sawani conducted a preliminary inquiry and submitted reports on 5 June 2013 and 8 July 2013, relying on audio recordings of conversations between the appellant's friend Jiju Janardhan and a bookie. The disciplinary committee issued a show-cause notice on 4 September 2013, alleging violations of Articles 2.1.1, 2.1.2, 2.1.3, 2.2.3, 2.4.1, and 2.4.2 of the BCCI Anti-Corruption Code. The appellant submitted a reply denying involvement, but the disciplinary committee, after hearing him on 13 September 2013, imposed a life ban. The appellant challenged the ban before the Kerala High Court, which dismissed his writ petition. The Supreme Court held that the disciplinary proceedings were conducted in accordance with natural justice, the evidence of audio recordings and the Commissioner's report provided sufficient basis for the ban, and the standard of proof in domestic tribunals is preponderance of probabilities. The Court found no perversity or illegality in the BCCI's decision and upheld the life ban.
Headnote
A) Sports Law - Disciplinary Proceedings - Standard of Proof - BCCI Anti-Corruption Code - The Court examined whether the disciplinary committee's findings based on audio recordings and the Commissioner's report were sufficient to impose a life ban. Held that the standard of proof in domestic disciplinary proceedings is preponderance of probabilities, not beyond reasonable doubt, and the BCCI's decision was not perverse (Paras 1-14).
Issue of Consideration
Whether the life ban imposed by BCCI on the appellant for alleged spot-fixing was valid and whether the disciplinary proceedings were conducted fairly.
Final Decision
The Supreme Court dismissed the appeal and upheld the life ban imposed by BCCI on the appellant.
Law Points
- Natural justice
- Disciplinary proceedings
- Standard of proof in domestic tribunals
- Anti-corruption code
- Sports law
