A five-judge Constitution Bench, splitting 3:2, held that the Board of Control for Cricket in India is not 'State' under Article 12 — so no writ under Article 32 lay against it. A digest of the facts, the instrumentality test, and the Article 12 / Article 226 divide the case crystallised.
In 2016 a three-judge Bench of the Supreme Court accepted the Justice R.M. Lodha Committee's recommendations and directed the BCCI to implement sweeping structural reforms. A digest of the two-judgment litigation born of the 2013 IPL betting scandal, the holding that the Board performs public functions amenable to Article 226, and how several reforms were later relaxed.