Great Eastern Energy Corporation … vs Union Of India & Anr on 23 May, 2026

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    Delhi High Court

    Great Eastern Energy Corporation … vs Union Of India & Anr on 23 May, 2026

                         $~
                         *  IN THE HIGH COURT OF DELHI AT NEW DELHI
                         %                     Judgment reserved on: 04.05.2026
                                            Judgment pronounced on: 23.05.2026
                                               Judgment uploaded on: 23.05.2026
                         +        W.P.(C) 4959/2026, CM APPL. 24383/2026, CM APPL.
                                  24384/2026 and CM APPL. 27530/2026
                                  GREAT EASTERN ENERGY CORPORATION LIMITED
                                                                         .....Petitioner
                                              Through: Mr. Rajiv Nayyar, Sr. Adv.
                                                       with Mr. Ajay Bhargava, Mr.
                                                       Aseem      Chaturvedi,        Mr.
                                                       Shivank Diddi, Mr. Anuj
                                                       Shrotriya and Mr. Arsh Alok,
                                                       Advs.
                                                    versus
                                  UNION OF INDIA & ANR.                      .....Respondents
                                                Through:        Mr. Brijesh Kumar Tamber,
                                                                Ms. Arani Mukherjee, Mr.
                                                                Vinay Singh Bist and Mr.
                                                                Shubendhu Kaushik, Advs. for
                                                                R-1.
                                                                Mr. Chetan Sharma, ASG with
                                                                Mr. Nakul Sachdeva, Mr. Sagar
                                                                Arora, Mr. Shreyansh Rathi,
                                                                Ms. Shrinkhla Tiwari, Mr.
                                                                Abhinandan Sharma, Mr. Amit
                                                                Gupta and Mr. Naman, Advs.
                                                                for R-2.
                                  CORAM:
                                  HON'BLE MR. JUSTICE ANIL KSHETARPAL
                                  HON'BLE MR. JUSTICE AMIT MAHAJAN
                                                    JUDGMENT
    

    ANIL KSHETARPAL, J.:

    1. Through the present Petition, the Petitioner by invoking writ

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 1 of 23
    15:07:21
    jurisdiction of this Court under Article 226 of the Constitution of
    India, essentially seeks directions to treat its bid for Coal Bed Methane
    (CBM) Block SR-ONHP(CBM)-2025/2 in Raniganj Coalfield, West
    Bengal, as validly submitted in the Special CBM Bid Rounder-2025
    and to consider the same along with other bids, or, in the alternative,
    to reconduct the bidding process for the said block.

    2. The primary grievance of the Petitioner is that its bid could not
    be completed due to an alleged technical malfunction/error that arose
    at the critical stage of online price bid submissions on the e-bidding
    portal, which displayed that the net worth of the Petitioner was
    insufficient.

    3. The question that arises in the present case is as to whether the
    Petitioner stood deprived of opportunity to submit its financial bid
    owing to a technical malfunction in the bid portal?

    4. To answer the aforesaid question, it would be appropriate to
    understand the turn of events that took place. Pursuant to the
    Hydrocarbon Exploration and Licensing Policy („HELP‟), Respondent
    No.1 through Respondent No.2, floated a Notice Inviting Offers
    („NIO‟) dated 15.04.2025 under the Open Average Licensing Policy
    („OALP‟), thereby inviting online bids for three Onland CBM Blocks,
    including the subject CBM Block, on a revenue sharing basis.

    5. The NIO prescribed, inter alia, minimum net worth
    requirements, architecture of bidding process and the twin
    requirement of valid bid submission, namely, timely online
    submission through the DGH/Respondent No.2 e-portal, and

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 2 of 23
    15:07:21
    mandatory submission of hard copies of documents along with bid
    bond and supporting Bank Guarantee or Insurance surety Bond in lieu
    of net worth. Additionally, in terms of the NIO, where the net worth of
    a bidder was less than the prescribed minimum net worth, the bidder
    had the option of topping up the same through a Bank Guarantee.

    However, the bid including the financial bid was requested to be
    uploaded online.

    SPONSORED

    6. Initially, the deadline for closure of bid submission was
    18.02.2026, however, the same was extended till 05.03.2026 (12:00
    hrs.) for all bidders. Upon closure of the bidding window, the online
    bids were opened by the Respondents and four entities namely, Oil
    India Limited, Essar Oil and Gas Exploration and Production
    Limited, Consortium of: Oilmax Energy Pvt. Ltd. and SAS Infotech
    Pvt. Ltd. and lnvenire Petrodyne Limited were found to have
    submitted their complete bid.

    7. It may be noted that while the system displayed the status of
    other bidders as submitted on the portal, the Petitioner‟s status
    reflected as not submitted.

    8. It is the Petitioner‟s case that on 05.03.2026, after physically
    submitting the mandatory documents, it proceeded to complete the e-
    filing formalities on the e-portal. However, during the course of
    submission, the e-bidding portal allegedly closed, resulting in
    termination of the Petitioner‟s session and consequent non-submission
    of its bid.

    9. Immediately thereafter, the Petitioner on the same date

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 3 of 23
    15:07:21
    addressed an email communication to Respondent No.2, alleging a
    technical malfunction in the bidding portal and requesting
    consideration of its bid. Upon receipt of the said representation,
    Respondent No.2 sought comments from C-1 India Private Limited
    [hereinafter after referred to as the „Portal Operator‟], the operator of
    the e-bidding portal. In response, the Portal Operator furnished an
    Audit Trail Report detailing the sequence of events recorded on the
    system logs with the following comments:

    “Dear Sir,
    With reference to the concern raised regarding bid submission, the
    matter has been examined.

    “As per the system Audit logs (Attached), the vendor initiated the bid
    on 05-03-2026 at 09:43:15 and updated the Techno-Commercial
    details, which is the first step for initiating the bid submission process.
    Subsequently, the vendor paid the tender fee and uploaded the
    reference copy of the fee on 05-03- 2026 at 11:01:02. Thereafter, the
    vendor uploaded the technical documents as required by DGH until
    05-03-2026 at 11:47:26.

    Further, the vendor started filling the price bid at 05-03-2026 at
    11:51:56, which continued until 11:59:32.
    Additionally, another vendor, Mis Invenire Petrodyne Limited, also
    submitted their bid around the same time on 05-03-2026 at 11:47:10,
    which indicates that the system was functioning smoothly during the
    bid submission period.

    Regards,
    Sandeep Bhandari”

    10. Subsequently, the representation made by the Petitioner was
    considered and in view of the aforesaid response of the Portal
    Operator, the allegations raised by the Petitioner were found to be
    unsubstantiated. Consequently, when the Petitioner visited the office
    of the Respondent No.2, seeking reconsideration of its bid, the said
    request was declined. Aggrieved thereby, the Petitioner approached
    the Court seeking interference.

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 4 of 23
    15:07:21

    11. Learned senior counsel representing the Petitioner has
    contended that, its net worth as on 31.03.2025 was USD 86.60
    million, far exceeding the prescribed minimum net worth requirement
    of USD 2.5 million as well as its own committed work programme bid
    of USD 41.65 million for 40 wells.

    12. It has also been urged that the Petitioner had obtained and
    submitted requisite bid bond Bank Guarantee in favour of Respondent
    No.1 in the amount of USD 1,05,000, to Respondent No.2 on
    05.03.2025, against which a Document Submission Receipt (DSR)
    was also issued.

    13. In substance, it is the Petitioner‟s case that it had abided by all
    the terms and conditions provided in the NIO to qualify as a bidder
    and it was solely due to the malfunction of the e-bidding portal that it
    could not proceed further and submit its bid.

    14. Per contra, learned ASG representing the Respondents has
    argued that the entire process was a system driven programme and
    there is no material on record to prove that it was on account of any
    technical glitch, that the Petitioner failed to upload its financial bid.

    15. While relying upon the portal logs and the Audit Trail Report
    furnished by the Portal Operator, it has been urged that no system side
    error or malfunction was recorded during the relevant period,
    particularly when other bidders had successfully uploaded their bids
    during the same timeframe as the Petitioner.

    16. At the outset, we deem it necessary to briefly highlight that,
    learned senior counsel representing the Petitioner is, in essence,
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 5 of 23
    15:07:21
    inviting this Court to resolve a technical and fact-intensive dispute
    between a bidder and tendering authority. However, such scrutiny
    would necessarily require examination of the correctness and
    completeness of activity logs maintained by the Portal Operator and
    internal computational logic applied by the system while processing
    the financial data of the Petitioner, thereby generating the alleged
    message of insufficient net worth.

    17. Learned senior counsel representing the Petitioner has
    contended that the Petitioner had manually entered the correct figures
    reflecting a net worth of USD 86.60 million and a bid value of USD
    41.65 million. On the other hand, learned senior counsel representing
    the Respondent, has urged that the system recorded no error and other
    bidders had successfully completed their submissions on the portal,
    more so, at the same time frame as that of the Petitioner.

    18. The aforesaid submissions, if taken into consideration for the
    purpose of adjudication in the present case, would lead to delving into
    a detailed scrutiny of factual matrix of the case, which, as evident,
    remains disputed. Such an exercise would be inconsistent with the
    restraint ordinarily observed by a Writ Court in judicial review of
    contractual and tender matters, where the Court is concerned primarily
    with the decision-making process rather than the merits of competing
    factual positions.

    19. The contention of learned senior counsel representing the
    Petitioner that its bid should be considered since it has already
    submitted the hard copy of the mandatory documents is devoid of
    merit. The NIO mandated submission of bids both online through the
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 6 of 23
    15:07:21
    e-bidding portal as well as in physical form with requisite documents,
    thereby making compliance with both requirements essential. As is
    evident, the Petitioner has failed to submit its financial bid.
    Additionally, since the submission of mandatory documents in hard
    copies, did not contain the submission of financial bids, the twin
    requirement of the bid process remained incomplete at the behest of
    the Petitioner, thereby making it ineligible for participation in the
    bidding process of the NIO.

    20. In this regard, we shall also advert to the terms of the NIO,
    governing the entire bidding process. While Clause 7 of the NIO
    provided for rejection upon non-submission of hard copies, the same
    cannot be read in isolation or to the exclusion of Clause 1(iv) which
    provides that an e-bidding portal has been specifically set up for the
    purpose of the NIO, as well as Clause 4(i), which mandates
    submission through the said portal. The above stated inclusions in the
    NIO, makes it crystal clear that online submission remained a sine qua
    non for participation in the bidding process.

    21. The main contention of the learned senior counsel for the
    Petitioner that Respondents‟ inaction against the malfunction of their
    own portal is in violation of Article 14 of the Constitution, is equally
    devoid of merit. To deal with the said contention, reference is to be
    made to the emails dated 17.02.2026, 24.02.2026, 26.02.2026 and
    03.03.2026 issued to bidders by the Respondents, intimating them
    about the last date for submission of the bids, i.e., on 05.03.2026,
    thereby also requesting them to complete registration. Despite these
    communications, the Petitioner commenced the bidding process only

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 7 of 23
    15:07:21
    on 05.03.2026, i.e., on the last date of submission.

    22. In order to deal with the aforesaid contention of the learned
    senior counsel, it further becomes imperative to highlight the activities
    performed by the Petitioner as well as other bidders on the portal,
    marking a completion, or in case of the Petitioner non-completion, of
    the bidding process. Set out below, in tabular format, are the activities
    undertaken by the bidders, on the basis of the Audit Trail Report
    provided by the Portal Operator:

    OILMAX ENERGY PVT LTD.

                             S.        Sub             Activity Name       Operation    Date and
                             No.      Module                                              time
    
                             1.    Upload       Save clicked on Upload Save            04-03-2026
                                   Tender Fee   Tender/RFP document Tab.               23:53:38
    
                             2.    Upload       Save clicked on Upload Save            04-03-2026
                                   Tender Fee   Tender/RFP document Tab.               23:54:42
    
                             3.    Preview      Proceed call first page.   Update      04-03-2026
                                   Formed                                              23:56:06
                                   Consortium
    
                             4.    Techno     Set Priority.                Save        04-03-2026
                                   Commercial                                          23:56:16
                                   Submission
    
                             5.    Techno     Set Priority.                Save        04-03-2026
                                   Commercial                                          23:56:25
                                   Submission
    
                             6.    Preview      Proceed call first page.   Update      04-03-2026
                                   Formed                                              23:58:32
                                   Consortium
    
                             7.    Techno     Set Priority.                Save        04-03-2026
                                   Commercial                                          23:58:44
                                   Submission
    
                             8.    Upload       Save clicked on Upload Save            04-03-2026
    
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026                                            Page 8 of 23
    15:07:21
                                    tender Fees   Tender/RFP document Tab.                 23:59:16
    
                             9.    Add           View Formed Consortium.         View     05-03-2026
                                   Authorized                                             10:21:54
                                   Subsidiary
                                   Vendor
    
                             10.   Preview       Proceed call first page.        Update   05-03-2026
                                   Formed                                                 10:22:00
                                   Consortium
    
                             11.   Price Bid     Price Bid       Data       Save Save     05-03-2026
                                                 Successfully.                            10:23:09
    
                             12.   EMD           Saved      EMD         During Save       05-03-2026
                                   Payment       Bidding.                                 10:25:38
    
                             13.   EMD           Save     EMD           Record Save       05-03-2026
                                   Payment       document Details.                        10:26:03
    
                             14.   Undertaking Saved vendor Undertaking          Save     05-03-2026
                                                                                          10:26:41
    
                             15.   Forms         During bidding, envelope Save            05-03-2026
                                   Submission    saved by supplier.                       10:26:56
                                   in Bidding
    
                             16.   Forms         Bid submission password View             05-03-2026
                                   Submission    verified.                                10:27:06
                                   in Bidding
    
                             17.   Forms         During bidding, envelope Save            05-03-2026
                                   Submission    saved by supplier.                       10:27:08
                                   in Bidding
    
                             18.   Forms         During bidding, envelope Save            05-03-2026
                                   Submission    saved by supplier.                       10:28:37
                                   in Bidding
    
                             19.   Forms         Bid submission password View             05-03-2026
                                   Submission    verified.                                10:29:02
                                   in Bidding
    
                             20.   Forms         During bidding, envelope Save            05-03-2026
                                   Submission    saved by supplier.                       10:29:04
                                   in Bidding
    
                             21.   Bid           Final Bid Submission            Submit   05-03-2026
                                   Creation                                               10:29:19
    
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026                                               Page 9 of 23
    15:07:21
                                    &
                                   Submission
    
    

    ESSAR OIL AND GAS EXPLORATION AND PRODUCTION
    LIMITED

    S. Sub Activity Name Operation Date and
    No. Module time

    1. Preview Proceed call first page. Update 05-03-2026
    Formed 09:37:48
    Consortium

    2. Preview Proceed call first page Update 05-03-2026
    Formed 10:36:10
    Consortium

    3. Upload Save clicked on Upload Save 05-03-2026
    Tender Fees Tender/RFP document Tab. 10:36:29

    4. Techno Set Priority Save 05-03-2026
    Commercial 10:36:35
    Submission

    5. Price Bid Price Bid Data Save Save 05-03-2026
    Successfully. 10:38:26

    6. EMD Saved EMD During Save 05-03-2026
    Payment Bidding. 10:41:50

    7. EMD Save EMD Record Save 05-03-2026
    Payment document Details. 10:44:07

    8. Undertaking Saved Vendor Undertaking. Save 05-03-2026
    10:44:58

    9. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier. 10:45:34
    in Bidding

    10. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier. 10:45:57
    in Bidding

    11. Forms Bid submission password View 05-03-2026
    Submission verified. 10:46:03
    in Bidding

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 10 of 23
    15:07:21

    12. Forms Bid submission password View 05-03-2026
    Submission verified. 10:46:22
    in Bidding

    13. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier. 10:46:24
    in Bidding

    14. Forms Bid submission password View 05-03-2026
    Submission verified. 10:46:36
    in Bidding

    15. Forms Bid submission password View 05-03-2026
    Submission verified. 10:46:49
    in Bidding

    16. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier. 10:46:51
    in Bidding

    17. Bid Final Bid Submission Submit 05-03-2026
    Creation & 10:47:31
    amp;

    Submission

    GREAT EASTERN ENERGY CORPORATION
    LIMITED/PETITIONER

    S. Sub Activity Name Operation Date and
    No. Module time

    1. Preview Proceed call first page. Update 05-03-2026
    Formed 09:43:15
    Consortium

    2. Techno Techno Commercial Update 05-03-2026
    Commercial Submission Updated 09:43:23
    Submission Successfully.

    3. Preview Proceed call first page. Update 05-03-2026
    Formed 09:58:05
    Consortium

    4. Tender Fee Online Payment Initiate. Save 05-03-2026
    Payment 09:58:47

    5. Tender Fee Online Payment Initiate. Save 05-03-2026
    Payment 10:20:57
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 11 of 23
    15:07:21

    6. Tender Fee Online Payment Initiate. Save 05-03-2026
    Payment 10:55:53

    7. Tender Fee Online Payment Success Save 05-03-2026
    Payment 10:57:43

    8. Upload Upload Fee Record Upload 05-03-2026
    Tender Fee Document Details. 11:01:02

    9. Preview Proceed call first page. Update 05-03-2026
    Formed 11:02:39
    Consortium

    10. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:06:40

    11. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:07:06

    12. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:08:13

    13. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:09:09

    14. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:10:02

    15. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:11:22

    16. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:12:54

    17. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:17:39

    18. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:21:05

    19. Preview Proceed call first page. Update 05-03-2026
    Formed 11:32:27
    Consortium

    20. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:36:04

    21. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:37:15

    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 12 of 23
    15:07:21

    22. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:41:04

    23. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:43:08

    24. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:43:34

    25. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 11:47:07

    26. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:47:12

    27. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:47:17

    28. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:47:26

    29. Price Bid Price Bid data saved Save 05-03-2026
    successfully 11:51:56

    30. Price Bid Price Bid data saved Save 05-03-2026
    successfully 11:52:12

    31. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:52:36

    32. Price Bid Price Bid data saved Save 05-03-2026
    successfully 11:53:49

    33. Price Bid Price Bid data saved Save 05-03-2026
    successfully 11:58:11

    34. Price Bid Price Bid data saved Save 05-03-2026
    successfully 11:59:32

    INVENIRE PETRODYNE LIMITED

    S. Sub Activity Name Operation Date and
    No. Module time

    1. Preview Proceed call first page Update 05-03-2026
    Formed 09:52:55
    Consortium

    2. Upload Delete Additional NIO Docs Delete 05-03-2026
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 13 of 23
    15:07:21
    Tender Fee 09:53:12

    3. Upload Upload Additional NIO Save 05-03-2026
    Tender Fee Vendor Doc. 10:00:37

    4. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 10:00:45

    5. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 10:03:37

    6. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 10:03:37

    7. Upload Upload NIO Vendor Doc. Save 05-03-2026
    Tender Fee 10:12:42

    8. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 10:29:01

    9. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:14:18

    10. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:28:59

    11. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:35:40

    12. Upload Save clicked on Upload Save 05-03-2026
    Tender Fee Tender/RFP document Tab. 11:35:40

    13. Techno Set Priority Save 05-03-2026
    Commercial 11:35:50
    Submission

    14. Price Bid Price Bid Data Save Save 05-03-2026
    Successfully 11:38:40

    15. Price Bid Price Bid Data Save Save 05-03-2026
    Successfully 11:39:29

    16. Price Bid Price Bid Data Save Save 05-03-2026
    Successfully 11:40:30

    17. Undertaking Saved Vendor Undertaking. Save 05-03-2026
    11:44:12

    18. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier. 11:44:33
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 14 of 23
    15:07:21
    in Bidding

    19. Forms Bid submission password View 05-03-2026
    Submission verified. 11:44:44
    in Bidding

    20. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier. 11:44:46
    in Bidding

    21. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier 11:44:58
    in Bidding

    22. Forms Bid submission password View 05-03-2026
    Submission verified. 11:45:08
    in Bidding

    23. Forms During bidding, envelope Save 05-03-2026
    Submission saved by supplier 11:45:10
    in Bidding

    24. EMD Save EMD Record Save 05-03-2026
    Payment document Details. 11:45:58

    25. Undertaking Saved Vendor Undertaking. Save 05-03-2026
    11:46:39

    26. Bid Final Bid Submission Submit 05-03-2026
    Creation 11:47:10
    &

    Submission

    23. Upon perusal of the above produced tables, it is evident that
    after the price bid data was saved successfully, the bidders were to
    carry out the following activities, “save vendor undertaking during
    bidding, envelop to be saved by supplier, bid submission password
    was to be verified, envelop was to be saved by the supplier, password
    verified, envelop saved by the supplier, EMD to be saved, during
    bidding, save EMD Record document details (which could be done at
    any time either prior or post the price bid submission) and after the
    completion of the above steps, the final bid submission was to take
    Signature Not Verified
    Signed By:JAI
    NARAYAN
    Signing Date:23.05.2026 W.P.(C) 4959/2026 Page 15 of 23
    15:07:21
    place”. However, as is apparent from the above table, in relation to the
    Petitioner‟s activities, neither of these subsequent steps were ever
    taken by the Petitioner.

    24. At this stage, the activities undertaken by the Petitioner, in
    comparison with the other bidders, also merit consideration. A perusal
    of the table reflects that Oilmax (Supra) commenced its process on
    04.03.2026 at 23.53.38 hours and concluded the activities relating to
    upload of tender fees at 23:59:16 hours on the same date. Thereafter, it
    logged into the portal again on 05.03.2026, starting at 10:21:54 hours
    and successfully submitting its final bid by 10:29:19 hours.

    25. Similarly, Essar Oil (Supra), commenced its bid process,
    including uploading of documents, on 05.03.2026 at 09:37:48 hours
    and successfully completed the bid process at 10:47:31 hours.
    Likewise, Invenire (Supra) initiated the process on 05.03.2026 at
    09:52:55 hours and successfully submitted its final bid at 11:47:10
    hours.

    26. However, when the timeline of activities performed by the
    Petitioner is examined, the same does not persuade the Court to accept
    that it acted with due diligence and bona fide intent while completing
    its bidding process, which is evident from the sequence of events,
    reflected in the Audit Trail Report.

    27. The Petitioner initiated the process on 05.03.2026 at 09:43:15
    hours but completed the online payment only at 10:57:43 hours.
    Thereafter, there was a gap of nearly 10 minutes before the Petitioner
    commenced uploading its “NIO Vendor Documents” at 11:06:40

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    hours. The said activity continued till 11:21:05, subsequently, an entry
    reflecting “proceed call first page” was recorded at 11:32:27 hours,
    whereafter the Petitioner again reverted to the activity of uploading
    “NIO Vendor Documents” at multiple instances between 11:36:04
    hours and 11:47:07 hours, showing an approximate time of 41 minutes
    being consumed for upload of NIO documents alone.

    28. The Petitioner, while making its case has not provided any
    explanation whatsoever for the aforesaid delay, nor has it argued that
    such delay was caused on account of the malfunction of the portal.
    Even otherwise, Invenire (Supra) was able to successfully complete
    its final bid submission, around the same time stamp, i.e., 11:47:10
    hours, thereby, indicating that there was no error in the portal.

    29. Moreover, the Audit Trail Report reflects that the Petitioner, at
    11:47:12 hours, under the sub module “upload tender fee”, performed
    the activity “save clicked on upload tender document/RFP document
    tab”, which was also reflected at multiple time stamps of 11:47:17
    hours, 11:47:26 hours and again at 11:52:36 hours. Notably, after
    11:47:26 hours, an activity reflecting “Price Bid data save
    successfully” has been recorded at 11:51:56 hours, 11:52:12 hours,
    11:53:49 hours, 11:58:11 hours and 11:59:32 hours.

    30. The significance of the above-mentioned timestamps lies in the
    fact that despite successful saving of “price bid submission” recorded
    at 11:51:56 hours and 11:52:12 hours, the portal recorded an activity
    of “save clicked on upload tender document/RFP document tab” again
    at 11:52:36 hours. Whereafter, the activity of “Price Bid Data Save
    Successfully”, was again registered till its active last time stamp of
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    11:59:32 hours. The Petitioner has also failed to furnish any
    explanation for the change in activity back to the sub-module of
    “upload tender fee”, after price bid success.

    31. Despite the aforesaid sequence of incomplete and repetitive
    activities, the Petitioner, while arguing its case, has made an attempt
    to alter its original stand. For the first time, in its Rejoinder Affidavit,
    the Petitioner has claimed that it was forcibly logged out at 11:59:32
    hours, i.e., prior to 12:00 hours, a stand which was never taken by it in
    its representation or the Writ Petition. Such plea, in our considered
    opinion, is clearly an afterthought. The same is also evident from the
    communication dated 05.03.2026, addressed by the Petitioner to the
    Respondent, wherein the Petitioner merely referred to an alleged
    technical error at the final stage and made no assertion regarding any
    forcible logout from the portal.

    32. Be that as it may, what is of utmost importance is that despite
    the continuous and rather inconsistent activities recorded on part of
    the Petitioner, it has only argued that it was wrongly logged out a few
    seconds prior to the closure of the bidding deadline. However, such a
    plea cannot be considered as it lacks merit. Firstly, the Audit Trail
    Report clearly reflects multiple fragmented and incomplete activities
    on the part of the Petitioner, coupled with substantial lapses of time
    between one stage and another, despite being fully aware that the
    deadline for bid submission was imminently approaching. The
    aforesaid action of the Petitioner clearly demonstrates a clear lack of
    diligence in completing the bidding process within the prescribed
    time.

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    33. Secondly, the Petitioner has evidently attempted to alter its
    stand, by taking a new plea in its Rejoinder Affidavit. In these
    circumstances, the conduct of the Petitioner does not inspire
    confidence so as to persuade this Court to accept the allegation of
    forcible logout or technical malfunction as the cause for non-
    submission of the bid.

    34. Upon a perusal of the material placed on record, in particular
    the Audit Trail Report, it remains undisputed that the session of the
    Petitioner remained active and bid related activities were carried out
    until 11:59:32 hours, though no completed submission was ultimately
    recorded. However, what remains disputed is whether the session
    termination and alleged failure to submit the bid was attributable to a
    genuine technical malfunction in the portal or connectivity issues at
    the behest of the user/Petitioner or the normal operation of a
    session/time-out mechanism.

    35. In view of the detailed examination undertaken in the preceding
    paragraphs, we are convinced that the Petitioner has not shown any
    bona fide intent in its attempt to submit the final bid. Moreover, the
    detailed examination of record in Audit Trail Report, tends to negate
    any systematic malfunction, a position which remains uncontroverted
    by the Petitioner, especially in respect of successful submission of one
    of the bidders.

    36. As such, the Petitioner‟s allegation of a bid value or net-worth
    validation error is neither manifestly corroborated nor disproved by
    the logs as provided by the Portal Operator. Accordingly, in absence
    of material to prove that the Petitioner was prevented from submitting
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    its bid successfully on account of technical glitch or forcible logging
    out, it would not be appropriate to order re-tender. More so, the
    existence and cause of the claimed technical glitch remain a live
    factual controversy rather than an established fact.

    37. The contention made by the Petitioner that the issuance of DSR
    and acknowledgment of its active session till shortly before the
    deadline amount to an admission supporting its case is also liable to be
    rejected. While the aforesaid circumstances show participation on
    account of the Petitioner, and also remain uncontested by the
    Respondents, they fall short of constituting an admission that the
    portal malfunctioned or that the Petitioner‟s bid ought to be deemed as
    successfully submitted online despite the record reflecting a contrary
    position. There is no occasion to draw presumption in favour of the
    valid and completed submission bid of petitioner‟s bid in absence
    concrete supporting material.

    38. During the course of arguments, learned senior counsel
    representing the Petitioner contended that, since the bids of other
    bidders allegedly did not include the Bank Guarantee in lieu of
    shortfall of net worth, the Petitioner‟s case stands on a pari materia
    footing and ought to be considered. The said contention, however, is
    legally untenable. The User Guide for CBM Tender Bidding
    specifically identifies „BG in lieu of shortfall of Net Worth vis-à-vis
    value of Bid Work Programme, as applicable‟ as a mandatory
    document required to be uploaded online.

    39. In this regard, it also becomes important to note that, as per the
    Compliance Affidavit filed by the Respondent, the remaining four
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    bidders had submitted their bids without furnishing any Bank
    Guarantee. Consequently, there was no occasion for the portal to insist
    upon the Petitioner uploading a Bank Guarantee, a case originally
    made out by the Petitioner.

    40. Significantly, the Note appended thereto expressly stipulates
    that where any mandatory document is not relevant or applicable to a
    bidder, a self-certified declaration stating „Not Applicable‟ is required
    to be uploaded against the concerned document. It further clarifies that
    the system would not permit submission of the bid if any mandatory
    document field was left blank. It is pertinent to note that each of the
    concerned bidders complied with the said stipulation by uploading a
    self-certified declaration marked “Not Applicable”. In contrast, the
    Petitioner has failed to bring to the notice of this Court any self-
    certified declaration abiding by the said requirement.

    41. In view of the aforegoing, the argument of learned senior
    counsel representing the Petitioner that the alleged e-portal
    malfunction was attributable to the Respondents lacks merit and has
    no nexus with the material placed on record. In particular, the logs
    provided by the Portal Operator show that another bidder, who had
    initiated the process later than the Petitioner, was nevertheless able to
    successfully complete bid submission within the stipulated timeline.

    42. In exercise of writ jurisdiction, the Court is expected to examine
    matter within the limited contours of judicial review. The
    Respondents, having taken a considered decision on the basis of the
    contemporaneous system records, cannot be faulted, especially when
    the entire bidding process was automated and system-driven rather
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    than manual.

    43. Learned senior counsel‟s reliance on the judgment passed in
    W.P.(C) 9183/2022 captioned Adani Welspun Exploration Limited v
    Union of India
    , is misplaced. It is evident that vide order dated
    07.10.2022, the same Division Bench clarified that the said judgment
    is in the peculiar facts of the case. Thus, it cannot be read as an
    authority for the proposition that, in every case where a portal error is
    alleged, the writ Court must assume the mantle of a technical
    fact-finding tribunal and investigate server logs and algorithms. In the
    present case, the divergence between the parties on the core factual
    narrative is far too wide to permit summary adjudication.

    44. Similarly, the reliance placed on Cineom Broadcast India Ltd.
    v Municipal Corporation of Gr. Mumbai1
    , is also misplaced. In the
    said case, the Court found an undisputed, unresolved portal
    malfunction not attributable to the bidder, combined with the
    authority‟s failure to invoke its own curative three-day intimation
    clause and therefore granted a one-time opportunity to participate
    without rewriting the tender. On the contrary, in the instant case, the
    NIO contained no equivalent curative notice clause, and the
    Respondent No.2, after seeking technical assistance from the Portal
    Operator, has ruled out the technical glitch narrative.

    45. Likewise, the reliance placed on L&T Hydrocarbon
    Engineering Ltd. v Oil and Natural Gas Corporation Ltd. & Anr.2
    is
    also misplaced, since it is an electronic commerce case on when an

    1
    2022 SCC OnLine Bom 1178
    2
    2018 SCC OnLine Del 9254
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    already dispatched electronic bid is deemed received under Article 15
    of the Model Law, in a situation where the tender conditions and
    statutory framework accommodate that construct. On the contrary, the
    present case concerns an admittedly non-submitted bid under the NIO
    which makes online submission of bids a condition precedent.

    46. Keeping in view the aforesaid discussions, no ground for
    interference under Article 226 of the Constitution of India is made out.

    47. Accordingly, the present Petition is dismissed. The pending
    applications also stand closed.

    ANIL KSHETARPAL, J.

    AMIT MAHAJAN, J.

    May 23, 2026
    jai/hr

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