Samsuddin Sekh vs. The State Of West Bengal

Court:Supreme Court of India
Judge:Hon'ble M.R. Shah
Case Status:Disposed
Order Date:13 Apr 2022
CNR:SCIN010050382022

AI Summary

The Supreme Court has dismissed a Special Leave Petition challenging the Calcutta High Court's decision to cancel a tender awarded to the petitioner. The core issue revolved around the petitioner's bid being significantly lower than the reserve value, even after negotiation, leading the High Court to direct a fresh tender. This ruling emphasizes adherence to tender process integrity.

Ratio Decidendi:
A High Court does not commit an error in cancelling a work order/tender and directing fresh tenders where the highest bid, even after negotiation, remains lower than the stipulated reserve bid value, thereby ensuring adherence to fundamental tender principles.

Case Identifiers

Primary Case No:5191/2022
Case Type:Special Leave Petition (Civil)
Case Sub-Type:SLP - Tender/Contract Dispute
Secondary Case Numbers:5038/2022
Order Date:2022-04-13
Filing Year:2022
Court:Supreme Court of India
Bench:Division Bench
Judges:Hon'ble M.R. Shah, Hon'ble B.V. Nagarathna

Petitioner's Counsel

Ranjan Mukherjee
Advocate on Record - Appeared
Aayushi
Advocate - Appeared

Advocates on Record

Ranjan Mukherjee

eCourtsIndia AITM

Brief Facts Summary

A public works tender had a reserve bid value of Rs. 1,42,325/-. The petitioner, Samsuddin Sekh, offered Rs. 1,25,500/-, which was less than the reserve value. He was then called for negotiation and increased his offer to Rs. 1,35,987/-, but this was still below the reserve bid. Consequently, the High Court cancelled the work order/tender in his favour and directed a fresh tender process. This High Court decision was challenged in the Supreme Court.

Timeline of Events

Prior to 2022-02-01

Public works tender initiated with a reserve bid value of Rs. 1,42,325/-.

Prior to 2022-02-01

Petitioner Samsuddin Sekh submitted an offer of Rs. 1,25,500/-.

Prior to 2022-02-01

Petitioner was called for negotiation and enhanced his offer to Rs. 1,35,987/-.

2022-02-01

High Court at Calcutta passed judgment in MAT No. 46/2022 cancelling the work order/tender and directing fresh tenders.

2022-02-16

Special Leave Petition (C) No. 5191/2022 was filed in the Supreme Court.

2022-04-13

Supreme Court heard and dismissed the Special Leave Petition.

Key Factual Findings

The reserve bid value was fixed at Rs. 1,42,325/-.

Source: Recited from Lower Court Judgment

The petitioner offered Rs. 1,25,500/-.

Source: Recited from Lower Court Judgment

The petitioner alone was called for negotiation.

Source: Recited from Lower Court Judgment

Petitioner enhanced offer to Rs. 1,35,987/-.

Source: Recited from Lower Court Judgment

Both offers were lower than the reserve bid value.

Source: Current Court Finding

The work order/tender in favour of the petitioner has been cancelled by the High Court and it was directed to invite the fresh tender.

Source: Recited from Lower Court Judgment

Primary Legal Issues

1.Whether the High Court was justified in cancelling a tender/work order when the highest bid was below the reserve bid value, even after negotiation.
2.Scope of judicial intervention in tender processes.

Secondary Legal Issues

1.Adherence to reserve bid value in public procurement.
2.Fairness and transparency in tender negotiations.

Petitioner's Arguments

The petitioner, Samsuddin Sekh, implicitly argued that the High Court erred in cancelling the work order, despite his enhanced offer after negotiation, and sought to overturn the High Court's decision.

Respondent's Arguments

While not explicitly stated, the respondents (State of West Bengal & Ors.) implicitly argued for upholding the High Court's decision, likely emphasizing the principle that a bid below the reserve price cannot be accepted and that adherence to tender rules is paramount for public contracts.

Court's Reasoning

The Supreme Court reasoned that the petitioner's highest offer, even after negotiation, remained below the fixed reserve bid value. Since the High Court cancelled the work order and directed a fresh tender on this ground, the Supreme Court found no error in the High Court's decision, thereby upholding the integrity of the tender process and public procurement norms.

Judicial Philosophy Indicators:
  • Emphasis on Procedural Fairness
  • Strict Adherence to Contractual/Tender Terms
Order Nature:Substantive
Disposition Status:Disposed
Disposition Outcome:Dismissed

Impugned Orders

High Court At Calcutta
Case: MAT No. 46/2022
Date: 2022-02-01

Specific Directions

  1. 1.The Special Leave Petition stands dismissed.
  2. 2.Pending application stands disposed of.

Precedential Assessment

Binding (SC)

This is a Supreme Court order, dismissing a Special Leave Petition on the merits related to a fundamental principle of tender law (reserve price), reinforcing the High Court's position. While a short order, it affirms existing legal principles.

Tips for Legal Practice

1.Advise clients involved in public tenders to strictly adhere to reserve bid values; even post-negotiation offers below the reserve price are unlikely to be upheld by courts.
2.Be aware that the Supreme Court is generally reluctant to interfere with High Court decisions that uphold the integrity and fairness of public procurement processes, especially when clear violations of tender conditions (like reserve price) are involved.
3.Emphasize clear documentation of all negotiation stages and compliance with tender terms to avoid subsequent litigation.

Legal Tags

Special Leave Petition dismissal tender cancellationPublic procurement rules reserve price complianceJudicial review of administrative decisions tenderGovernment contract validity below bid valueIntegrity and fairness in bidding processesHigh Court powers in tender dispute resolution

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

FRESH

Before:

Hon'ble M.R. Shah, Hon'ble B.V. Nagarathna

Stage:

FRESH (FOR ADMISSION) - CIVIL CASES

Remarks:

Dismissed

Listed On:

13 Apr 2022

In:

Judge

Category:

UNKNOWN

Original Order Copy

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Order Text

ITEM NO.7 COURT NO.12 SECTION XVI S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS

Petition(s) for Special Leave to Appeal (C) No(s). 5191/2022

(Arising out of impugned final judgment and order dated 01-02-2022 in MAT No. 46/2022 passed by the High Court At Calcutta)

SAMSUDDIN SEKH Petitioner(s)

VERSUS

THE STATE OF WEST BENGAL & ORS. Respondent(s) (FOR ADMISSION and I.R. and IA No.43257/2022-EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT) Date : 13-04-2022 This petition was called on for hearing today. CORAM : HON'BLE MR. JUSTICE M.R. SHAH HON'BLE MRS. JUSTICE B.V. NAGARATHNA For Petitioner(s) Mr. Ranjan Mukherjee, AOR Ms. Aayushi, Adv. For Respondent(s) UPON hearing the counsel the Court made the following O R D E R

From the material placed on record, it appears that the reserve bid value was fixed at Rs. 1,42,325/-. The petitioner offered the highest rate at Rs.1,25,500/- only, which was less than the reserve bid value. However, subsequently the petitioner alone was called for negotiation and he enhanced his offer to Rs.1,35,987/-, which was also lower than the reserve bid value.

Considering the aforesaid facts and circumstances, when the work order/tender in favour of the petitioner has been cancelled by the High Court and it was directed to invite the fresh tender, it cannot be said that the High Court has committed any error.

The Special Leave Petition stands dismissed.

Pending application stands disposed of.

(R. NATARAJAN) (NISHA TRIPATHI) ASTT. REGISTRAR-cum-PS BRANCH OFFICER Digitally signed by R Natarajan Date: 2022.04.18 11:21:45 IST Reason: Signature Not Verified