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Bombay High Court

MISS. PRACHITI SUJIT CHANDRATREYA THR NATURAL GUARDIAN MOTHER MRS. SWATI SUJIT CHANDRATREYAversusMISS. PRACHITI SUJIT CHANDRATREYA THR NATURAL GUARDIAN MOTHER MRS. SWATI SUJIT CHANDRATREYA

Decided
Disposal
Rejected

Holding

The Court held that the grounds advanced do not amount to an error apparent on the face of the earlier order, and therefore the interim application for review is dismissed.

Summary

The Bombay High Court considered an interim application filed by the All India Chess Federation (respondent No.1) seeking review of its order dated 17 February 2025 that directed the federation to restore the National Junior Girls Online Championship 2021 title to Ms Prachiti Sujit Chandratreya. The federation claimed that its newly elected governing body, which took office in March 2024, only became aware of the case in September 2025 and that essential documents were missing, arguing that these circumstances warranted a recall of the earlier order. The Court observed that the contentions related to internal disputes between the federation’s former and current committees, matters beyond its jurisdiction, and that service of notice on the respondent had been properly effected. It further held that the grounds raised did not reveal any apparent error in the earlier order and that the respondent had not contested the proceedings. Accordingly, the Court rejected the interim application and ordered no costs.

Issues considered

  • Whether the grounds raised in the interim application constitute a valid basis for review or recall of the earlier order dated 17 February 2025
  • Whether the Court can entertain inter‑se disputes between the federation’s former and current governing bodies
  • Whether proper service of notice on the respondent was effected

Subjects

  • review of order
  • interim application
  • service of notice
  • inter se dispute
  • court jurisdiction
  • administrative body
  • sports federation

Judgment

                                                                                      IA6724_2026.DOC
2026:BHC-AS:39947-DB

         Vidya Amin
                         IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                 CIVIL APPELLATE JURISDICTION

                               INTERIM APPLICATION NO. 6724 OF 2026
                                               IN
                                  WRIT PETITION NO. 7271 OF 2022

              All India Chess Federation, through its
              Secretary & Ors.                                                 … Applicants/
                                                                               Org. Respondents
              In the matter between
              Ms. Prachiti Sujit Chandratreya, through Natural
              Guardian Mother Mrs. Swati Sujit Chandratreya             … Petitioner
                     Vs
              All India Chess Federation, through its
              Secretary & Ors.                                          … Respondents
                                                  _________
              Mr. Sukand Kulkarni a/w. Mr. Eshaan Saroop i/b. Mr. Hoshang S. Tafti for the
              applicant/original respondent.
              Mr. Shriram S. Kulkarni a/w. Pranjal M. Khatavkar i/b. Sujay Palshikar for the
              petitioner.
                                                 __________

                                          CORAM:         G. S. KULKARNI &
                                                         ADVAIT M. SETHNA, JJ.
                                                         (In Chamber at 5.15 p.m.)
                                          DATE:          29 SEPTEMBER 2026

              P.C.

              1.      This Interim Application is filed effectively praying for review/recall of the

              order dated 17 February, 2025 passed by this Bench, thereby allowing the Writ

              Petition filed by the original petitioner - Ms. Prachiti Sujit Chandratreya. The

              petition was allowed in terms of prayer clause (d), namely, by issuing a direction

              to applicant/respondent no. 1 in the Writ Petition to implement the decision

              dated 16 February, 2022 taken by respondent no. 2, whereby respondent no. 1

              was called upon to restore the winning title of National Junior Girls Online

              Championship, 2021 to the petitioner.

                                                  Page 1 of 3
                                              29 September 2026
                                                                               IA6724_2026.DOC



2.     The reply affidavit filed on behalf of the petitioner-Ms. Prachiti Sujit

Chandratreya is taken on record.


3.     The record of the original proceedings would indicate that respondent no.

1 was served and an affidavit of service was placed on record, accordingly, the

Court proceeded to hear the appearing parties and passed an order dated 17

February, 2025.


4.     The primary contention on the basis of which the review is prayed for is

as urged on behalf of applicant/respondent no. 1, as set out in paragraphs 4 to 7,

which read thus:


        “4. The new elected body of the applicant came into being only in March,
        2024. Annexed hereto and marked as Annexure A is a copy of the election
        result.

        5.    Prior to the said date, the applicant’s affairs were being conducted by
        the previous committee which were indolent in its approach towards the
        captioned Writ Petition, among other issues.

        6.     Till 15 September, 2025, the applicant was completely unaware as to
        the existence of the present case. In fact, on 18 September, 2025 only upon
        receipt of the petitioner’s email, did the applicant become aware of the
        existence of the present case. Annexed hereto and marked as Annexure B is a
        copy of the emails.

        7.     Due to the previous administrations lackadaisical attitude, the
        appellant’s current governing members are unable to locate the details of the
        case. Several of the documents which are necessary, are untraceable.

5.     There are other contentions raised in paragraph 13 of the Interim

Application. We find that such contentions are in regard to the inter se disputes

between respondent nos. 1 and 2. The Court cannot delve into such inter se

disputes. Also, it is clear from the averments made by the applicant that the



                                      Page 2 of 3
                                  29 September 2026
                                                                                                IA6724_2026.DOC



                        newly elected body took charge in March, 2024 and, thereafter, upon gathering all

                        the records, the present Interim Application came to be filed. Such contentions

                        including the aforesaid contentions certainly cannot form the basis for this Court

                        to review the orders passed on the writ petition.


                        6.       We have accordingly heard learned counsel for the parties. We have also

                        perused the record.


                        7.       We find ourselves in agreement with the learned counsel for the petitioner,

                        when he contends that the grounds set out in the Interim Application certainly

                        cannot constitute a ground for review/recall of the order dated 17 February, 2025,

                        as there is no error apparent on the face of the order of which review is sought.


                        8.       We are also more than satisfied, upon calling for the record and as observed

                        in our previous order, that service was effected on respondent no. 1 and it is

                        applicant/respondent no. 1 who has not contested the proceedings.


                        9.       In the aforesaid circumstances, no case is made out to interfere with and/or

                        review/recall the order dated 17 February, 2025. Interim Application is rejected.

                        No costs.



                        (ADVAIT M. SETHNA, J.)                                   (G. S. KULKARNI, J.)




Signed by: Vidya S. Amin                                     Page 3 of 3
Designation: PS To Honourable Judge                      29 September 2026
Date: 01/10/2026 11:26:40


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