The Central Information Commission (CIC) on Monday held that the Board of Control for Cricket in India (BCCI) does not fall within the ambit of a “public authority” under the Right to Information (RTI) Act, 2005, observing that the cricket board continues to function as an autonomous private body and is neither “directly nor indirectly” financed by the government.
Information Commissioner P.R. Ramesh held that the BCCI, registered under the Tamil Nadu Societies Registration Act, 1975, was “neither established by the Constitution, nor created by any legislation or government order”.
“Since the Board of Control for Cricket in India is neither materially dependent upon nor sustained by government funds, it does not satisfy the requirement of being “substantially financed, directly or indirectly, by funds provided by the appropriate government” under Section 2(h)(d) of the Right to Information Act, 2005 and therefore cannot be regarded as a ‘Public Authority’ thereunder”, held the CIC while dismissing the plea, filed by Geeta Rani.
The detailed order arose from a 2018 CIC ruling passed by then Information Commissioner M. Sridhar Acharyulu, which had directed the BCCI to appoint Public Information Officers and put in place an RTI compliance mechanism. The order was subsequently challenged by the BCCI before the Madras High Court, which remitted the matter to the CIC for fresh adjudication in light of Supreme Court judgments holding that the BCCI did not qualify as a “public authority” under the RTI Act.
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No ‘substantive’ government control
Relying on a host of Supreme Court judgments, the CIC held that the statutory requirements under Section 2(h) of the RTI Act were mandatory and had not been fulfilled in the case of the BCCI. It observed that there was no “substantial and pervasive” government control over the board’s functions, finances, administration, management or affairs.
“Its functions are regulated and governed by its own Rules and Regulations, independent of any statute and are only related to its members. The Rules and Regulations of the BCCI have neither any statutory force nor does it possess any statutory authority to frame rules or regulations having statutory force. Further, the Working Committee elected from amongst its members in accordance with its own Rules controls the entire affairs and management of the BCCI. It is pertinent to mention that there is no representation of the Government or any statutory body of whatsoever nature in the BCCI,” the order stated.
The Commission further relied on the Supreme Court’s decision in Zee Telefilms Ltd. v. Union of India (2005), which held that “mere supervision or regulation by the state is insufficient to alter the private character of the organisation”. In the judgment, the apex court had observed that although the BCCI performs significant public functions in regulating cricket in India, it does not qualify as “State” within the meaning of Article 12 of the Constitution owing to the absence of deep and pervasive governmental control over its affairs.
The CIC also held that “incidental benefits” such as tax exemptions or concessions extended to the cricket body could not amount to “substantial financing” by the State under the RTI Act. It observed that such exemptions were available uniformly to all non-profit entities satisfying the prescribed conditions under the Income Tax Act, 1961, and were not a “special dispensation” granted exclusively to the BCCI.
Referring to the Supreme Court’s ruling in Board of Control for Cricket in India v. Cricket Association of Bihar (2016), where the apex court had observed that bodies discharging functions affecting public interest must adhere to “standards of fairness, transparency and institutional integrity”, the CIC pointed out that the judgment did not declare the BCCI to be a “public authority” under the RTI Act.
“The judgment does not hold that the BCCI is financially dependent upon the Government or substantially financed by governmental funds. On the contrary, the BCCI’s financial structure was understood to be independently sustained through media rights, sponsorships, broadcasting revenues, ticketing, licensing, and commercial cricketing operations,” the order added.
‘Unintended consequences’
In obiter dicta accompanying the ruling, the Commission observed that “overly simplistic” assumptions that greater governmental supervision necessarily leads to the “fairness of institutions” failed to account for the “complexities of modern economic institutions”.
“The evolution of the Board of Control for Cricket in India from a colonial-era administrative body into the financial epicentre of global cricket reflects one of the most significant transformations in contemporary sports economics,” the CIC observed.
It also pointed to the Indian Premier League (IPL), observing that its franchise-based model and lucrative media rights regime had redefined the financial architecture of the sport and accounted for a “substantial portion” of the BCCI’s revenues, running into “tens of thousands of crores”.
“Beyond the IPL, the Board derives income from international media rights, sponsorship arrangements, and its significant share in global revenues distributed by the International Cricket Council, further reinforcing its centrality to the global cricket economy,” the order stated.
The Commission cautioned that imposing a “model of oversight” premised solely on governmental control could risk “unintended consequences, including inefficiencies or disruptions in a finely balanced economic structure”.
Published – May 18, 2026 03:03 pm IST
