1. E.P. Royappa v State of Tamil Nadu (1974)

This is a foundational case linking Article 14 with non-arbitrariness.

Facts:

A senior IAS officer was transferred to a relatively less significant post. The transfer was challenged as arbitrary and politically motivated.

Issue:

Whether administrative discretion in postings can be exercised without clear standards.

Judgment:

The Supreme Court held that equality under Article 14 is violated not only by discrimination but also by arbitrariness.

Principle on transparency:

• If prioritisation (like seniority, merit, administrative need) is not based on transparent criteria, it becomes arbitrary.
• Even administrative decisions must be guided by reasoned and rational standards, not subjective preference.

Importance:

This case laid the foundation that “arbitrariness is antithetical to equality”, which directly impacts prioritisation systems.

2. Maneka Gandhi v Union of India (1978)

Facts:

Maneka Gandhi’s passport was impounded without detailed reasons or a fair hearing.

Issue:

Whether State action affecting rights must follow fair procedure.

Judgment:

The Court expanded Article 21 to include fair, just, and reasonable procedure.

Principle on transparency:

• Government must disclose reasons for decisions, especially when prioritising or deprioritising individuals.
• Decision-making cannot be secretive or purely discretionary.
• Procedure must be non-arbitrary and transparent in reasoning.

Importance:

It introduced the idea that fairness in process = transparency in criteria and reasoning.

3. Ramana Dayaram Shetty v International Airport Authority of India (1979)

Facts:

A contract was awarded to a party who did not meet eligibility conditions stated in the tender notice.

Issue:

Whether public authorities can deviate from stated eligibility criteria.

Judgment:

The Supreme Court strongly held that the State must act fairly, consistently, and according to declared norms.

Principle on transparency:

• If eligibility or prioritisation criteria are declared, they must be strictly followed.
• Any hidden or changed criteria violates Article 14.
• Public authorities cannot change rules mid-way or apply undisclosed preferences.

Importance:

This case is central to transparent prioritisation in tenders and government contracts.

4. Sterling Computers Ltd v M & N Publications Ltd (1993)

Facts:

Dispute arose over award of government contract where evaluation was alleged to be biased and inconsistent.

Issue:

How far courts can intervene in tender decisions involving prioritisation.

Judgment:

The Court held that while judicial review is limited, decisions must still be fair, transparent, and based on objective criteria.

Principle on transparency:

• Evaluation of bids must follow pre-declared criteria.
• Authorities must not use vague or undisclosed benchmarks.
• Transparency ensures accountability even in discretionary areas.

Importance:

Reinforced that selection/purchase priorities must be measurable and reviewable.

5. Tata Cellular v Union of India (1994)

Facts:

Challenge to government decision in awarding telecom tender.

Issue:

Extent of judicial interference in administrative discretion.

Judgment:

The Court emphasized that courts do not sit as appellate bodies in tenders, but can intervene where:

• decision is arbitrary
• criteria are not transparent
• mala fides exist

Principle on transparency:

• Prioritisation in public contracts must follow transparent evaluation standards
• Even if discretion exists, it must be structured and accountable
• Courts ensure “decision-making process” is transparent, not just outcome

Importance:

This case is key for modern procurement law.

6. Sachidanand Pandey v State of West Bengal (1987)

Facts:

Government allocated land involving discretion in favour of a private hotel project.

Issue:

Whether such discretionary allocation required structured prioritisation criteria.

Judgment:

The Court held that while policy discretion exists, it must not be arbitrary or opaque.

Principle on transparency:

• Government must consider relevant factors and ignore irrelevant ones
• Absence of clear prioritisation criteria can lead to misuse of power
• Public interest decisions must show rational basis

Importance:

Strengthened requirement of reasoned prioritisation in allocation of public resources.

Core Legal Principles Emerging from These Cases

From all these judgments, Indian constitutional law establishes that:

1. No arbitrary prioritisation

Decisions must not depend on personal discretion alone.

2. Pre-declared criteria

Eligibility, ranking, or priority rules should be known in advance.

3. Reasoned decision-making

Authorities must be able to justify why one person was preferred over another.

4. Non-discrimination under Article 14

Unequal treatment is valid only if backed by rational and transparent criteria.

5. Judicial review of process

Courts examine how a decision was made, not just what decision was made.

Conclusion

“Transparency of prioritization criteria” is not just administrative best practice—it is a constitutional requirement under Article 14. The Supreme Court has consistently ruled that wherever the State prioritizes individuals or entities, it must:

• define clear standards,
• apply them consistently,
• avoid hidden preferences,
• and provide rational justification.

Without transparency, prioritisation becomes arbitrariness—and arbitrariness is unconstitutional.