Tapas Kumar Das vs. Hindustan Petroleum Corporation Ltd. [March 19, 2024]
Citation: 2024 INSC 225
Background and Facts
Tapas Kumar Das applied for an LPG distributorship under an advertisement issued by Hindustan Petroleum Corporation Ltd. (HPCL). His candidature was rejected by HPCL on the grounds that the land he offered for the showroom did not comply with the “location” requirements stipulated in the advertisement and the Unified Guidelines for LPG distributorships. Das challenged this rejection before the Calcutta High Court.
A Single Judge of the High Court ruled in favor of Das, directing HPCL to proceed with his candidature. However, HPCL appealed, and the Division Bench reversed the Single Judge’s order, upholding HPCL’s decision to reject Das’s application. Das then appealed to the Supreme Court.
Legal Issues
Whether the land offered by Das for the LPG showroom satisfied the “location” requirements as per the advertisement and Unified Guidelines.
Whether HPCL’s decision to reject Das’s candidature was arbitrary or in violation of principles of natural justice.
Supreme Court’s Analysis and Ruling
The Supreme Court analyzed the terms of the advertisement and the Unified Guidelines, emphasizing that strict compliance with the “location” criteria was essential for fairness and transparency in the selection process for LPG distributorships. The Court observed that the guidelines were designed to ensure accessibility, safety, and convenience for the public.
It was found that the land offered by Das was not within the area specified as “location” in the advertisement. The Court noted that HPCL had acted in accordance with the guidelines and had not deviated from the prescribed process. The Court also held that the decision-making process was neither arbitrary nor violative of natural justice, as Das had been given an opportunity to present his case and the reasons for rejection were clearly communicated.
The Supreme Court upheld the Division Bench’s judgment, setting aside the Single Judge’s order. The Court reaffirmed that public sector undertakings like HPCL must strictly adhere to the terms of their advertisements and guidelines to maintain integrity and public confidence in such selection processes.
Significance
This judgment underscores the importance of strict compliance with eligibility criteria and guidelines in public sector allotments. It clarifies that courts will not interfere with administrative decisions made in accordance with clearly stated criteria, unless there is evidence of arbitrariness or violation of natural justice. The ruling reinforces the principle that fairness and transparency are paramount in public allotment processes.
Citation
2024 INSC 225.
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