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    N Srinivasan questions his removal as BCCI president, files affidavit

    On March 28, the Supreme Court had ordered removal of Srinivasan as BCCI president for a fair probe into the IPL spot-fixing and betting scandal.

    On March 28, the Supreme Court had ordered removal of Srinivasan as BCCI president for a fair probe into the IPL spot-fixing and betting scandal. (Getty Images)

    N Srinivasan, the suspended BCCI president, on Tuesday filed an affidavit in the Supreme Court questioning his removal from the top post of the Indian cricket board.

    On March 28, the Supreme Court had ordered removal of Srinivasan as BCCI president for a fair probe into the IPL spot-fixing and betting scandal in which Srinivasan's son-in-law and former CSK Team Prinicipal Gurunath Meiyappan's involvement has been proved. As per SC's order, Srinivasan - the India Cements and Chennai Super Kings owner - then stepped aside as the apex court appointed Sunil Gavaskar and Shivlal Yadav to look after IPL and BCCI's operations, respectively.

    ALSO SEE The rise and fall of BCCI czar Srinivasan

    "I am highly aggrieved by the unfair and unsubstantiated allegations made against me in the course of hearing of the above matter on 27-03-2014," Srinivasan said in the affidavit. "Further, I am personally not aware of the reason why this Hon'ble Court orally expressed that I should not continue as President of BCCI.

    "My term as BCCI President ends in September and I should be allowed to complete it. I'm not under any inquiry or probe, no conclusive evidence against me. There is no provision in the BCCI Constitution for an interim President," the affidavit further read.

    The SC, while asking the BCCI to remove Srinivasan as president, had also said that no employee of Indian Cements should any way be associated with the BCCI, following which all India Cements employees holding positions in the BCCI were removed.

    "Unfair to ask India Cements employees in BCCI to stand down. India Cements employees in BCCI stand tarnished in the eyes of the public," the ex-president said in his employees' defence.

    Srinivasan also alleged "collusion" between the former BCCI president AC Muthiah and Bihar Cricket Association's Aditya Verma, who had filed the petition. "There is obvious collusion between AC Muthiah and Aditya Verma the petitioner," he said.

    The Supreme Court, which is due to resume hearing in the case on Wednesday, has in its possession a sealed envelope provided by Justice Mukul Mudgal that allegedly contains names of the players and IPL officials involved in illegal activities. But Srinivasan said it is unsubstantiated. "Sealed envelope presented by Mudgal panel is unsubstantiated and unverified," the axed BCCI chief said.

    Here's the full text of the affidavit:

    REPLY AFFIDAVIT OF N.SRINIVASAN-RESPONDENT NO.2

    I, N.Srinivasan son of late Mr.T.S.Narayanaswamy, aged 69 years, residing at No.6, ABM Avenue, Boat Club, Chennai-600 018 do hereby solemnly affirm and sincerely state as follows:

    1. I am the second respondent in the above Special Leave Petition and I am well acquainted with the facts and circumstances of the case.

    2. The above petition was originally filed by the Petitioner herein questioning the Code of Conduct Committee appointed by the BCCI for inquiring into the allegations of betting and spot fixing. Though I was made a party to the proceedings, the relief sought against me was not pressed in the Bombay High Court. Against the order passed by the Hon'ble High Court of Bombay, the BCCI and the Petitioner filed cross appeals and I continue to be a party to the proceedings. By order dated 08.10.2013, this Hon'ble Court was pleased to appoint a probe Committee consisting of three Honourable members to go into allegations of betting and fixing in IPL matches by Mr. Gurunath Meiyappan, Chennai Super Kings, Mr. Raj Kundra and Rajasthan Royals. The report of the Probe Committee, in two parts, was submitted to this Hon'ble Court on 10.02.2014. My interaction with the Committee is recorded in the report. The report concluded that my statement that he was a "Mere Cricket Enthusiast" was incorrect and Mr. Gurunath Meiyappan was the public face of the IPL Team Chennai Super Kings.

    3. The report concluded that the BCCI had fully cooperated in the proceedings. I was advised that I need not file any response or objections to the report of the Probe Committee, considering the fact that the terms of reference did not include my functions in the BCCI or my role in the India Cements Ltd. Apart from that, I was advised that the appreciation of the BCCI's cooperation by the Committee would extend to its officials, including me, and that there was no taint on me in the report. There are two events which have occurred since the matter was taken up for hearing on 25.03.2014 which compels me to file this reply affidavit.

    4. On 25.03.2014, this Hon'ble Court orally expressed its deep displeasure to my continuance as BCCI President, based upon material in a sealed cover submitted by the Probe Committee. On 27.03.2014, Senior Counsel appearing for the petitioner apparently argued that I was guilty of corruption and "cover up" as per BCCI Anti Corruption Code since my purported statement to the Committee that Mr. Gurunath Meiyappan was a mere "Cricket Enthusiast" was found to be false. I have not stated anything to the Probe Committee which even remotely suggests that I was trying to cover up acts of alleged betting or fixing. Parts of the report of the Committee were being twisted out of context which requires an explanation on my side. Further, an intervention application has been filed by Mr. G.Sampath Kumar, a suspended Police Officer, which reveals material most likely available in the sealed envelope that may have created an impression in the mind of the court that I was interfering with the CB-CID investigation into betting. I wish to clarify my position on this issue also and bring the true facts to the knowledge of this Hon'ble Court. It is for these reasons that I wish to file my reply affidavit, confining it to only the issues raised from the report of the Probe Committee and arguments made in Court by Petitioner's counsel.

    5. I respectfully state that by an order dated 28-03-2014 in the above Special Leave Petition, this Hon'ble Court recorded my offer that I would not be discharging any functions as President of Board for Control of Cricket in India and posted the matter for final hearing on 16-04-2014. I submit that my Counsel informed me that on 25-03-2014 when the Special Leave Petition was first heard after receiving the objection from the parties to the Report of the court appointed Probe Committee, this Hon'ble Court made remarks which have caused injury and prejudice to me and my continuance as elected President of BCCI. I was told that the BCCI Counsel was asked to submit proposals on the way forward without me continuing in office. Upon hearing the observations made by this Hon'ble Court that were widely reported, I volunteered to step aside from my duties and functions as President, BCCI till an independent investigation agency ordered to go into the acts of betting and match fixing complete such investigation. This was communicated as part of the list of proposals submitted to this Hon'ble Court by BCCI Counsel on 27-03-2014.

    6. Further I was informed by my Counsel that this Hon'ble Court was pleased to receive the said proposals and asked the Counsel appearing for parties to commence arguments in the above SLP as well as SLP No 25027 of 2013 filed by BCCI. The Senior Counsel appearing for the petitioner commenced and completed his arguments on 27-03-2014. In the course of his submissions, Counsel for the petitioner made extremely serious allegations against me as well as Mr.M.S.Dhoni that both of us were guilty of a cover up since we had not spoken the truth to the Probe Committee and had in fact said that Mr.Gurunath Meiyappan was a "mere cricket enthusiast". Serious allegations were made against me that I was guilty of committing corrupt acts since, as per applicable rules, a person who gives false information would also be guilty of a corrupt act. I was informed by my Counsel that Mr.Harish Salve, Senior Advocate, appearing for the petitioner, began his arguments by submitting that he had listened to the tape recorded conversation between one Mr.Vindoo Dara Singh and Mr.Gurunath Meiyappan, that totally filthy language was being used by the said two persons, that he would not recommend for this Hon'ble Court to hear the tapes, that the conversations clearly prove that betting has taken place and that insider information was also shared. Several persons were named as employees of the India Cements Limited, of which I am the Vice-Chairman and Managing Director. Several of these persons were alleged to have dual role in the said company as well as in BCCI to facilitate permeation of my power and influence into BCCI so that I can misuse and abuse my elected position to further the prospects of India Cements Limited which owns IPL Team Chennai Super Kings, its employees and also protect my son-in-law Mr.Gurunath Meiyappan and IPL Team Chennai Super Kings from being implicated in the betting and match fixing scandal.

    7. I respectfully state that practically every news channel and newspaper carried the gist of arguments advanced in this Hon'ble Court by Mr.Harish Salve, Senior Advocate, appearing for the petitioner as well as the proposed interim order expressed by this Hon'ble Court. Meanwhile, this Hon'ble Court had, through the Registrar, ascertained consent of Mr.Sunil M. Gavaskar to be the Interim President of BCCI. I am told that at the conclusion of the morning session on 27th March, 2014 this Hon'ble Court on hearing these submissions made by the petitioner's Counsel, had expressed that it proposed to pass an interim order barring Chennai Super Kings and Rajasthan Royals from playing IPL and also directing me to step aside. Stating so, the court asked Mr.C.A.Sundaram, Senior Advocate, appearing for BCCI to place his submissions on the interim order so proposed to be passed by this court on 28-03-2014.

    8. On 28-03-2014, I am told, even prior to the commencement of argument by BCCI Counsel, Senior Advocate for the petitioner drew the attention of this Hon'ble Court to the role of Mr.Sundar Raman, Chief Operating Officer of IPL and sought for his removal on the ground that he was also guilty of a cover up before the Probe Committee. I am told that thereafter upon hearing BCCI Counsel for a short while, this Hon'ble Court expressed its view that the matter will be placed for final hearing on 16-04-2014 and the participation of any of the teams in IPL-7 would not be disturbed.

    9. I respectfully submit that I am constrained to place the above sequence of facts on record because I am highly aggrieved by the unfair and unsubstantiated allegations made against me in the course of hearing of the above matter on 27-03-2014. Further, I am personally not aware of the reason why this Hon'ble Court orally expressed that I should not continue as President of BCCI. On the factual assertions made by Senior Advocate appearing on behalf of the petitioner on 27-03-2014, I wish to place on record the following facts.

    10. To the best of my knowledge, there are no audio tapes of conversations between Mr.Vindoo Dara Singh and Mr.Gurunath Meiyappan available in public domain. The report of the Probe Committee has not enclosed any such audio tapes. I am not aware if the sealed envelope submitted to this Hon'ble Court by the Probe Committee contains such material but I am advised that such recordings would be part of the charge-sheet filed by Mumbai Police in the court of Additional metropolitan Magistrate, 37th Court Esplanade Mumbai. Therefore, there is absolutely no possibility of anyone being in possession of such audio recording, much less the petitioner. The circumstances under which such audio tapes, to which reference was made during submissions, were heard by counsel for the petitioner who made submissions under instruction has to be disclosed to this Hon'ble Court by the petitioner.

    11. I submit that one Mr. K. S. Viswanathan joined India Cements Limited in the year 1974. Being a Cricketer in the Senior Division of the Tamil Nadu Cricket Association league, over the years he had involved himself in the activities of the Sports Division of India Cements Limited. He also started involving himself from the year 1994 in the Tamil Nadu Cricket Association, a full member of BCCI.

    12. I was elected as Treasurer, BCCI at the Annual General Meeting held on 29-30th November, 2005. When I took over as Hony. Treasurer of BCCI, Sri Sharad Pawar was the President, BCCI (President, Mumbai Cricket Association) and Sri Niranjan Shah was Hony. Secretary (Saurashtra Cricket Association). Mr.K.S.Viswanathan, was then the Assistant Secretary, Tamil Nadu Cricket Association. He was appointed as Chief Manager at the Treasurer's Office at the meeting of the Finance Committee of BCCI held on 15-08-2006. The said meeting was attended by various officers of the BCCI including Mr.Pawar. A copy of the minutes of meeting of the said Committee held on 15-08-2006 is annexed hereto and marked as ANNEXURE R/1.

    13. When I was elected as Secretary to BCCI in 2008, Mr.K.S.Viswanathan was appointed as Special Assistant to Secretary, with the approval and knowledge of one and all office bearers of the BCCI. Thereafter, when I was elected as President of BCCI in September, 2011, Mr.K.S.Viswanathan was appointed as my Special Secretary to assist me to carry out my functions. I must mention here that since December 2005 when Mr.K.S.Viswanathan first stepped in to assist me, he has not received any remuneration from the first respondent BCCI. The BCCI has only covered his travel expenses and no allowance of any nature has been paid to him.

    14. Mr. Prasanna Kannan, an employee of India Cements Ltd was employed in the Hony. Treasurer's office in 2006 and was appointed as Assistant Manager (Accounts) pursuant to a resolution passed by the BCCI Finance Committee which has been annexed asAnnexure .R/1 hereinabove. After first season of IPL 2008, Mr. Lalit K.Modi, the then Chairman of IPL Governing Council, made a written recommendation seeking the appointment of Mr.Prasanna Kannan, as Finance Personnel in IPL. His appointment was in the Agenda of the Governing Council meeting of 16th September, 2008. Though the said agenda was deferred then, Mr.Prasanna Kannan was re-designated as Manager - Business and Commercial Service, IPL since October, 2008. His appointment was ratified by the Governing Council headed by Mr.Lalit K.Modi. As afore-mentioned, I had by 2008, been elected as Secretary, BCCI and Mr.Prasanna Kannan extended his assistance to me as Secretary of the BCCI. After Mr.Lalit K.Modi was suspended pursuant to the show-cause-notice issued to him in April, 2010 Mr.Prasanna Kannan was replaced by Mr.Hemang Amin. Mr.Hemang Amin was personally recommended by Mr.Sashank Manohar, the then President of BCCI. Though his role in IPL came to an end, Mr.Prasanna Kannan continued to work in the BCCI Secretary's Office drawing salary from the Secretary's office. After I became the President of BCCI, Mr.Prasanna Kannan was appointed as Compliance Manager, IPL and was to report to Chief Operating Officer of IPL and to me as President of BCCI.

    15. Mr.Satheesh, a former first class cricketer, has been employed with India Cements for over 20 years. He was taking care of the Logistics of Chennai Super Kings for four years from 2008-2011. In June, 2011, the then Logistics Manager of the Indian Team, Mr.Mayank Parikh did not want to continue in that position and hence Mr.Satheesh was appointed as Logistic Manager (even before I took charge as President) and continued to hold the position. Soon as he took over as the Logistics Manager of the Indian Team, Mr.Satheesh has stopped rendering services to Chennai Super Kings.

    16. Having set out details of persons associated with India Cements and BCCI, I would also like to bring to the knowledge of this Hon'ble Court the various personnel who had been brought in from time to time by various office bearers of BCCI for their assistance and convenience. I am saying this to bring out the fact that recommending known resource has been the practice in BCCI and singling me out as though I have committed a grave indulgence for my personal benefits without an iota of proof is very unfair.

    17. Mr. Lalit K.Modi during his tenure had brought in Ms. Radhika Moolraj, as his Executive Assistant. Ms. Moolraj was an employee of M/s Godfrey Philips, a company promoted by Mr. Lalit K.Modi's family and Mr. Lalit K.Modi was himself an Executive Director of the said company. During his role as President of BCCI, Mr.Sharad Pawar appointed one Mr.D.K.Singh as his Special Assistant. When Mr. Sharad Pawar became the Vice-President of ICC in 2008, Mr.D.K.Singh continued to serve in BCCI on Mr.Sashank Manohar's approval. I reliably understand that the said Mr.D.K.Singh was an employee of Government of India and an Officer on Special Duty under the Ministry of Agriculture during the same period when he was receiving salary and emoluments from BCCI. Mr.I.S.Bindra during his Presidency, appointed Mr.A.K.Behl as his Personal Secretary and the BCCI took care of all his expenses including travel and stay. Mr. Bindra's son, Amar Bindra, was then employed with Nimbus in 2007 while Mr.I.S.Bindra was in the Committee to decide on the reduction claim made by the said broadcaster for reduction of the License fee payable to BCCI. In fact, the License fee was reduced by Rs.255 Crores on the recommendations of Mr.I.S.Bindra and Mr.Lalit Modi who was Chairing the said Committee. Later, Mr.Amar Bindra was employed with IPL Franchisee Kings XI Punjab as Chief Executive Officer when Mr. Bindra was part of the IPL Governing Council. When Mr.Dalmiya was the President, one Mr. Kunal Gosh was appointed by him as his Executive Assistant. The said Mr. Gosh was drawing salary from the BCCI.

    18. A further allegation made against me is that I control Mr.Sundar Raman COO of IPL since he is also an employee of India Cements Ltd, which is absolutely false. It appears that the petitioner would resort to making any sort of allegation with little regard for the consequences in this Hon'ble Court.

    19. It is submitted that from the above incontrovertible facts, it would be noticed by this Hon'ble Court that the above named employees of India Cements Ltd were also involved in BCCI activities for nearly a decade now and were put there not at my specific instance and certainly not to perpetuate any sinister activity as alleged or otherwise. The BCCI has far from suffering any loss or harm due to the involvement of the above persons, has in fact benefitted immensely. These persons have been asked to leave the BCCI for absolutely no fault of their making, without giving them, or for that matter me, an opportunity to explain. Today, these employees of India Cements Ltd. stand tarnished in the eyes of public and the society at large as if they were unceremoniously thrown out by this Hon'ble Court upon being found guilty of conspiring against the interest of the BCCI.

    20. As regards the allegations made against me, it is highly relevant that whatever material was placed in the secret envelope has been qualified to be unsubstantiated and unverified by the Probe Committee. It is also highly relevant that I was not the subject matter of the Probe. The report of the probe Committee suggests that several persons volunteered their personal views about me suffering conflict of interest and duty. The Probe Committee has itself mentioned in Volume 1 that the scope of the probe did not include such an issue and yet for reasons best known to them, found it necessary to place this issue in Court as part of the main report.

    21. I respectfully state that the Probe Committee had a specific scope of work that was defined by this Hon'ble Court. Extraneous issues, particularly those involving prior litigation ought not to be made subject matter of scrutiny of the Probe Committee. The fact that Mr. A.C.Muthiah had interacted with the Probe Committee is evident and quite obviously he has pleaded his case that was set out in the two suits filed by him in the Madras High Court.. Persons inimical to me, including former Presidents of the BCCI, such as Mr. I.S. Bindra, have interacted with the Committee and as indicated in the report, surely spoken also of issues extraneous to the scope of the reference, specifically to implicate me. It would be most unfair if such statements of people who have an axe to grind, form the basis of comments made against me in the report, since the whole issue stood closed with the principal proponent of this allegation having withdrawn his suits unconditionally. What is also missed out by the Probe Committee is the obvious collusion between Mr. A.C.Muthiah and the Petitioner, to somehow denigrate and disconnect my involvement with the BCCI. Soon after the suits were withdrawn by Mr. A.C.Muthiah, the Petitioner filed yet another PIL in the Bombay High Court against BCCI and others, including me, verbatim repeating the averments made in the withdrawn suits referred earlier. Therefore, this Hon'ble Court need not go into any issue which did not fall within the original terms of reference.

    22. At any event, I have already disclosed in the said earlier suit proceedings that I am not the owner of India Cements Ltd, that it is a Public Company with more than 1 lakh share holders,that foreign institutional investors own upto 37.02% and constitute the single largest block of share holders. There are institutional investors such as LIC of India and others. All these facts were gone into in great detail while considering the merits of interim applications filed by Mr. A.C. Muthiah in the suits referred above and a bench of two Hon'ble Judges of this Court heard the matter and by reported judgment have expressed difference of opinion. The suits were withdrawn when ripe for trial. Now, the same issues have been raised in a PIL filed by the petitioner herein which is pending in the Bombay High Court.

    23. I respectfully state one Mr. Sampath Kumar, IPS, a police officer under suspension, pending inquiry into corruption charges, has filed an intervention application in the above matter. From the intervention application filed by the said Mr. Sampath Kumar, I can gather that he has told the Probe Committee that high ranking BCCI official interfered with the investigation and conspired with Senior Police Officers to not only transfer him but also implicate him in a false case and suspend him from service. It would not require any speculation to understand that G.Sampath Kumar was obviously accusing me. The statements so made by him are not only hearsay in terms of what he allegedly heard from an accused under interrogation, but wholly uncorroborated. Further, no credibility can ever be attached to what he said to the Probe Committee since he is a suspended public servant facing serious charges of corruption and will say anything to divert attention from his acts of corruption. From news reports, I can gather that Mr.G.Sampath Kumar had received huge amounts as bribe from various bookies and was caught by superiors.

    24. I submit that I have gone through the report filed by the Probe Committee and have noted that the name of Mr. Sampath Kumar is not reflected in the list of people inquired by the Committee, as set out in Volume 1 of the report. Volume 3 of the report which contains the order sheets of the Probe Committee also makes no reference to interaction with Mr. Sampath Kumar. His name however, finds mention in Volume II of the report, where one of the Committee members refers to the availability of his deposition in the record of the committee. Mr. Sampath Kumar, in his affidavit filed before this Hon'ble Court, claims to have deposed before the Committee. I fail to understand why the Probe Committee has not enlisted his name and would certainly like to know if he had deposed before the Committee in person and also if such deposition was prior to my deposition or subsequently.

    25. Without prejudice, I further submit that in his intervention application, Mr. Sampath Kumar has not mentioned when he was subject to transfer. I reliably understand that he was transferred out of his then posting even before Mr. Gurunath Meiyappan was arrested by the Mumbai Police. I categorically state that I had absolutely no knowledge of any investigation by the CB-CID or Mr.G.Sampath Kumar interrogating the bookie by name Uttam Jain alias Kitty. This Hon'ble Court would appreciate that I would have had absolutely no idea of any statement made by the said Kitty under interrogation pertaining to some meeting in a party hosted by one Mr. Vikram Agarwal on 27th April 2013. It would also be clear to this Hon'ble court that absolutely no credence can be given to anything said by Mr. G Sampath Kumar to the probe committee about me. In this regard, I wish to rely upon news reports which suggests that various bookies including the said Kitty having given statements to the Magistrate recorded under Section 164 CRPC which are highly damaging to Mr. G Sampath Kumar. Indeed, I am moving an application to this Hon'ble Court seeking directions be issued to to the CB-CID Tamil Nadu to inform this Hon'ble Court of exact reasons why Mr. G Sampath Kumar was suspended from the force and what is the stage of the investigation or enquiry against him. News reports also suggests that Mr. G Sampath Kumar was found with a stash of currency notes and other material possessions way beyond his known sources of income. In these circumstances, I would respectfully submit that there is absolutely no reason why I should not be permitted to resume my office as elected President of BCCI unless and until this Hon'ble Court conclusively finds material suggesting that I had interfered with investigations by CB-CID and/or compromised the tenure of Mr. G Sampath Kumar in service. I have never interfered with any part of the disciplinary proceeding or the criminal investigation into my son in law and I unconditionally undertake that I will continue to do so in the event this Hon'ble court directs any such proceeding

    A copy of news paper reports dated 14/3/2014 and 28/2/2014 are annexed hereto and marked as ANEXURE R/2 "COLLY".

    26. I respectfully state that I did make the offer to step aside from my position from the BCCI till the conclusion of independent enquiry and it was made part of the proposals given by the BCCI to this Hon'ble Court on 27.03.2014. I have already explained the circumstances under which that offer was made. I categorically state that I have never heard the name of Mr. G Sampath Kumar or any other officer who allegedly interrogated one Kitty at least till after the constitution of the Probe Committee. Indeed, I have absolutely no truck with any police officials either in Tamil Nadu or in any other state. In fact, I am myself facing false cases filed by one Mr. Mehmood Abdi who is the Power of Attorney of Mr.Lalit Modi and one Mr. Naresh Makhani a close associate of the petitioner. Therefore, I humbly request this Hon'ble Court to reconsider the interim order dated 28.03.2014 in so far as it relates to my position in the BCCI. I wish to resume my elected office. My term ends with September 2014 and I should be allowed to complete my tenure. Already, vested interests behind the petitioner have charged me with violating this Hon'ble Court's order by attending the ICC meetings in Dubai last week. Even though this Hon'ble Court clearly observed orally as informed to me by counsel that the interim order is restricted to only BCCI activities, a hue and cry was made by vested interests who have been vocal in the media that I should not represent BCCI in the ICC. That apart, the Memorandum, Rules and Regulations of the BCCI do not contemplate an interim President. That does not imply that the President, BCCI would be immune to a disciplinary action since the regulation 32 (iv) would apply to any misconduct or other action against the interest of the Board being committed by an administrator of the BCCI. President, BCCI is included in the definition of 'administrator'. Therefore, there is no lacuna in the BCCI constitution. At the risk of repetition, I am not under any enquiry or probe and hence, there is absolutely no reason for me to be kept away from my office.

    27. I respectfully state that another very serious charge leveled against me by the Petitioner's counsel on 27.03.2014 I am told is that I am guilty of corrupt act in indulging in a cover up before the probe committee in order to save the IPL Franchisee Chennai Super Kings and also my son-in-law Mr. Gurunath Meiyappan. Firstly, the probe committee appointed by the Hon'ble Court was not a substitute to the code of conduct committee under the IPL Operational Rules. Instead, it was a fact finding committee which took upon itself the responsibility of assimilating as much information as could be gathered not only from the BCCI and police but also from the public at large. All those who had any information pertinent to the terms of reference were invited to share their views. The statements given to the committee were not on oath. The interactions of various persons with the committee were recorded and there was no one present from either the BCCI or from the side of the persons being enquired into while the information was being assimilated through such informal interactions. Thus, there is absolutely no scope for application of either the IPL Operational rules or the BCCI Anti Corruption Code to the probe committee proceedings. Infact, the portion of the BCCI Anti Corruption Code relied on by the Petitioner's counsel is Section 2.5.2 of Article 2 and is extracted below:

    "A Participant who authorises, cause, knowingly assists, encourages, aids, abets, covers up or is otherwise complicit in any acts or omissions of the type described in Articles 2.1 - 2.4 committed by his/her coach, trainer, manager, agent, family member, guest or other affiliate or associate shall be treated as having committed such acts or omissions himself and shall be liable accordingly under this Anti-Corruption Code."

    The definition of Participant under the Code is reproduced below:

    "Participant. Any Player, Player Support Personnel, Umpire, Match Referee or Umpire Support Personnel"

    A bare reading of these two provisions will show that they do not apply to me at all. I am not a "Participant". Nevertheless, I was openly accused of corruption and worse, of a "cover up".

    28. Secondly, I respectfully state that I never made any statement to the committee that Mr. Gurunath Meiyappan was "mere cricket enthusiast". I appeared and met the Probe committee on 19th December 2013. I never made any comment pertaining to Mr. Gurunath Meiyappan's role or the lack of it in the IPL franchise Chennai Super Kings. Any suggestion to the contrary in the report of the committee is incorrect. To my knowledge, the members of the committee began asking me on Mr. Gurunath Meiyappan betting and I told them that I don't believe he had done anything wrong, that I asked him and he denied it. The committee then asked me whether I knew of his betting. I pointed out that even before his name came up in the Mumbai police investigation, Mr. Y P Singh head of the ICC Anti Corruption and Security Unit had been invited to attend the meeting of the Working Committee of the BCCI held on 18th May 2013 at Chennai soon after some players were arrested by the Delhi Police and was asked specifically whether he had any information concerning betting or match fixing in IPL 6 and he replied that there was no such information at all. There was no possibility of me having prior knowledge of Mr.Gurunath Meiyyappan betting. Apart from this, I do not remember the Probe Committee asking me any question pertaining to alleged acts of betting by Gurunath Meiyappan or his role in Chennai Super Kings. I was asked about allegations made by Mr. Mehmood Abdi, Power of Attorney of Mr. Lalit Modi, steps taken by BCCI to prevent interaction of players with anti social elements and other issues which I do not recollect. I do recollect that I gave them a brief back ground of my involvement in sports, that I had represented my college in Cricket, Tennis and Hockey. I also remember mentioning to the Committee the yeomen service rendered by India Cements Ltd to Cricket and cricketers.

    29. I have been passionate about Cricket since my college days and have, to the best of my ability, nurtured and supported talent. My contributions to the game and BCCI per se, is in every facet and functioning of the organization. I have performed my duties as the President of the organization and in all other offices that I held, with utmost sincerity and integrity. I have always been a great supporter of the game of cricket. Even during the days when there was no sponsorship available, no money available for cricket, India Cements Ltd has supported Cricket and more importantly, cricketers, by offering employment to them. India Cements was one of the pioneers from the Corporate world who extended support to the game of cricket. India Cements has had on its rolls State and National Cricketers from the mid 1960s, including players like Mr. P.K.Belliappa, K.R.Rajagopal, Nijam Hussain, P.K.Dharmalingam, K.V.R.Moorthy, K.Balaji Rao, B.Kalyanasundaram, Venkatsundaram etc., all of whom represented Tamil Nadu in the Ranji Trophy. Others like Mr.S.Venkatraghavan, Mr.V.B.Chandrashekar, Mr.L.Sivaramakrishnan, Mr.Rahul Dravid, Mr. Lakshmipathy Balaji, Mr. R.Ashwin, Mr. M.S.Dhoni, Mr. S.Badrinath, Mr. Dinesh Karthik and Mr. Hemang Badani have even played for the country, with three of them captaining the Indian team with honours. The company took pride in employing such cricketers of eminence on its permanent rolls. I have played a large role in leading the India Cements Ltd in this direction. In earlier days, employment for cricketers actually provided a reasonable source of income and security and it was only after 2005 or so that cricketers have started to see heavy remuneration from BCCI, IPL and endorsements. Therefore, I can proudly claim to have played a part in promoting and supporting cricketers through India Cements Ltd.

    30. Apart from supporting Cricketers, I steered the management of India Cements Ltd to also sponsor tournaments such as Moin-ud-Daula, Arlem Trophy in Goa, Thirupanithura Tournament in Kerala, Buchi Babu Tournament in Chennai and KSCA Diamond Jubilee Tournament in Bangalore. At the request of Mr. Sunil Gavaskar, the India Cements Ltd sponsored the replay of the 1987 tied test between India and Australia when the Australian team toured India and played a test match in Chennai in 2003, for which a sum of Rs.25 Lakhs was paid to Professional Management Group, managed by Mr. Sunil Gavaskar. Further, I have personally cleared several requests from retired cricketers for sponsorship support during benefit games. An instance of my uncompromising dedication to the cause of Indian Cricket would be the move to reward past cricketers during my term as the President, BCCI. A onetime benefit ranging from Rs.25 Lakhs to those who played 75-99 First Class Games and Rs.1.5 Crores to those who played more than 100 Test matches was given by means of a detailed scheme of payment that was formulated, debated and approved by the BCCI during my tenure. Under this scheme, almost every player who had played a test for India, received a onetime benefit. In the event the player was no more, and his spouse was living, the amount was paid to her. In all, over Rs.110 Crores was distributed to over 200 cricketers.

    31. I have always had the best interest of BCCI at heart. When I took over as Treasurer in 2005, I discovered that the BCCI had not filed its annual returns for the preceding 25 years, with the registrar of Societies Tamil Nadu. None of the predecessors office bearers, for over two and half decades had bothered to comply with the statutory requirement of filing returns. Recognizing the seriousness of the situation, I took all necessary steps to file the returns for 25 years, applied to the Government for condonation, which was duly received Many of my detractors, including Mr. I.S.Bindra, Mr. A.C.Muthiah, have all exerted energy and strained much in denigrating me, while having miserably failed to discharge such a fundamental duty.

    32. I further submit that I have been involved in representing BCCI in International Cricket Council (ICC), since the year 2008. I was on the chief Executive Committee of ICC from 2008-11. From 2011, I have been on the Executive Board of ICC. During my tenure at ICC, I have at all times, furthered the interests of BCCI. My crowning achievement has been to effect a re-structuring of the ICC and a re-working of the financial distribution model to reflect India's contribution to the economics of world Cricket. As a result, BCCI now stands to receive 21.6% of the top line of the media rights and sponsorship income of ICC, for ICC events between 2015-23. Further, it has been agreed that even in the subsequent cycle, 2023-31, BCCI cannot get anything lower. This would translate, in my estimate, to additional revenue of upwards of Rs.3000 Crores for an eight year cycle. It is important for me to point out that this proposal was stiffly opposed initially by my detractors in India who wanted to attack me without having any regard to the interests of Indian Cricket, and at times, even at the cost of BCCI's image. Persons like Mr. Lalit Modi, Mr. I.S. Bindra and journalists who have always adopted a permanently hostile attitude against me were literally crying for my blood. Certain vested interests tried playing politics with the other Cricket Boards, but finally, wisdom prevailed over all the full members of ICC, who have now expressed their complete support to the re-working. The support is not only to the reforms propounded by BCCI, but also to my assumption of office as the Chairman of the ICC, a position which has been created for the first time, as part of the reforms. As against these achievements, the earlier regime in BCCI successively let down BCCI's interests in ICC, by accepting a meager 3% of the ICC revenues, which at last count amounted to a little over Rs.200 Crores for the 8 year period, 2007-15.

    33. I humbly submit that the reason for me to bring out my avid interest in cricket and my passion to support the game is to place before this Hon'ble Court the fact that my track record of unflinching and unconditional support and involvement in cricket ought not to be side lined while considering anything which Mr. G.Sampath Kumar, a discredited public servant facing corruption charges, has to say about me. I have been an able Administrator and I have never compromised on my principle to uphold all that is best in Cricket. As a testament of the complete support and faith that I enjoy amongst BCCI members, I was re-elected President, BCCI on 27.09.2013, for the term ending September, 2014, unanimously, despite the mudslinging efforts of the Petitioner and my detractors who were repeatedly attacking me on news shows and interviews.

    34. I humbly submit that I have already set out the circumstances under which I gave my offer to this Hon'ble Court to step aside from my position as President BCCI, till an independent investigation was completed. Now the circumstances are quite different in that it clearly appears to me that the only the unsubstantiated allegations made by G. Sampath Kumar to the Probe Committee that I was responsible for his transfer and suspension and therefore I interfered with CB-CID investigation contributed to the severe comments made by this Hon'ble Court on 25.03.2014. I am filing an interim application for urgent directions that the CB-CID, Tamil Nadu be directed to immediately furnish a report to this Hon'ble Court on their case against Mr. Sampath Kumar and the reasons for his transfer and suspension, which may be considered in the facts of the case. As stated earlier, I had nothing to do with any investigation done by the said person, or any other agency for that matter. Hence, I wish to assume office as President BCCI as there is no reason at all why I should step aside, pending any investigation into any crime being investigated by CB-CID or other agency.

    In the above circumstances, this Hon'ble Court may be pleased to pass appropriate orders in the interests of justice and dismiss the above SLP and thus render justice.