If you have installed the app on all of the devices then in all probability yes, if the device supports push (pretty much any smartphone) then you can use the push service to synchronize the devices based on geofencing (ie, 10m from my location), there are some other discovery routes you could try to (without using the B word) pinging other devices
the app would need to be able to provide some sort of server service if it was to create its own private network based on the IP addresses of the devices it found nearby, as those devices would have to connect to that phone acting as a server. the network interface shouldn't be important, but connecting the satellite devices to the server should be. You could try doing it based on which device can provide data services, aka hotspot. You can easily connect devices to networks programmatically.
at that point your faced with the classic client server problem. There is going to be a huge amount of work to get devices configured, network creation, client server infrastructure if it has to be done without data, packet optimization. Very expensive and very high risk depending on how many restrictions there are.