Jagwant Kaur vs. Union of India
Citation: 2025 INSC 112; Supreme Court of India
Bench: Justice Sudhanshu Dhulia, Justice K. Vinod Chandran
Background
Jagwant Kaur challenged the selection process and subsequent allotment of an LPG distributorship at Balachaur, Punjab, conducted by Indian Oil Corporation Ltd. (IOCL) under the Union of India. She alleged irregularities and arbitrariness in the evaluation of applications, contending that the chosen candidate did not meet the eligibility criteria and that the selection process lacked transparency and fairness. Kaur’s application for the distributorship had been rejected, and her subsequent representations to IOCL and relevant authorities were unsuccessful, prompting her to approach the High Court.
Proceedings and Issues
The High Court dismissed Kaur’s writ petition, finding no procedural impropriety or violation of guidelines in the selection process. Kaur appealed to the Supreme Court, seeking judicial intervention to set aside the allotment and direct a fresh selection.
The primary issues before the Supreme Court were:
Whether the selection and allotment process for the LPG distributorship was vitiated by arbitrariness or violation of established guidelines.
Whether the courts could interfere in contractual matters involving public sector undertakings unless there was clear evidence of mala fides or illegality.
Supreme Court’s Analysis
Scope of Judicial Review: The Court reiterated that judicial review in contractual matters, especially those involving public tenders or allotments by government agencies, is limited. Courts will not substitute their own judgment for that of the administrative authorities unless the process is shown to be arbitrary, discriminatory, or in violation of statutory rules.
Evaluation of Evidence: The Supreme Court examined the evaluation process and found that IOCL had followed the prescribed guidelines and that the selection committee’s decision was based on objective criteria. There was no evidence of mala fides, favoritism, or violation of the principles of natural justice.
No Grounds for Interference: The Court held that mere dissatisfaction of an unsuccessful applicant is not a ground for judicial intervention. In the absence of proven illegality or procedural lapses, courts must exercise restraint and respect the autonomy of administrative decision-making.
Decision
The Supreme Court dismissed the civil appeal, upholding the High Court’s judgment and the allotment made by IOCL. The Court found no merit in the allegations of arbitrariness or illegality and declined to interfere with the selection process.
Significance
This judgment reinforces the principle that judicial review in public contract and tender matters is circumscribed, and courts will not intervene unless there is clear evidence of procedural irregularity, mala fides, or violation of statutory norms. The decision upholds the autonomy of public sector undertakings in managing their contractual affairs, subject to fairness and transparency.
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