Board of Control for Cricket in India

Why in news? The Central Information Commission held in May 2026 that the BCCI is not a “public authority” under the RTI Act and therefore cannot be compelled to disclose information under the law.
Background
Board of Control for Cricket in India was officially established in 1928 to regulate and promote cricket in India.
Cricket spread in India during British rule through clubs, presidency matches, princely patronage, and touring international teams.
Princely states such as Patiala, Nawanagar, and Vizianagaram played a major role in nurturing Indian cricket before Independence.
India became a Full Member of the Imperial Cricket Conference (now ICC) in 1929, enabling participation in official Test cricket.
India played its first Test match in 1932 at Lord’s under the captaincy of C. K. Nayudu.
The BCCI gradually transformed from a cricket-administration body into a major economic and governance institution in world cricket through media rights, sponsorships, and leagues like the Indian Premier League and Women's Premier League.
Present Context
·       An applicant sought information under Right to Information Act, regarding player selection, government support to cricket infrastructure, and state control over cricket administration.
·       The CIC reaffirmed that the BCCI is a private society registered under the Tamil Nadu Societies Registration Act, 1975, and not a government-created institution.
RTI Act – Section 2(h)
Section 2(h) defines a “public authority” as a body established by the Constitution, parliamentary law, state law, or government notification.
The section also includes bodies that are substantially financed, owned, or controlled by the government.
Article 12 of the Constitution
Article 12 defines “State” for the purpose of Fundamental Rights enforcement.
Experts suggest that courts have expanded Article 12 through judicial interpretation to include bodies performing public functions under significant government control.
 
Whether BCCI Performs Public Functions ?
BCCI effectively controls cricket in India, selects the national team, represents India internationally, and regulates professional cricket.
Such functions have strong public significance and therefore require transparency and accountability.
Whether Government Control Exists ?
The CIC held that government regulation alone does not amount to “deep and pervasive control”.
The Commission observed that BCCI office-bearers are internally elected and government approval is not required for decision-making.
Whether Public Resources Amount to State Financing
Questions were raised regarding use of government stadiums, tax concessions, and police deployment during cricket matches.
The CIC ruled that these facilities do not amount to “substantial financing” under the RTI Act.
Important Judicial and Institutional Developments
Zee Telefilms Case (2005) - In Zee Telefilms Ltd v Union of India, the Supreme Court held that the BCCI is not “State” under Article 12 because it lacks governmental financial and administrative domination.
Thalappalam Judgment (2013)
In Thalappalam Service Cooperative Bank Ltd v State of Kerala, the Supreme Court clarified that “control” under the RTI Act must be substantial and pervasive, not merely regulatory.
Lodha Committee Recommendations (2015)
Experts suggested bringing the BCCI under RTI to improve transparency and governance.
Law Commission Report (275th Report, 2018)
The report recommended that sports bodies performing public functions should fall within the RTI framework.
National Sports Governance Act, 2025
The Act provides that sports bodies receiving government grants will be treated as public authorities to the extent of utilisation of such funds.
Since the BCCI does not receive government grants, it remains outside the RTI framework.