High Court Dismisses Writ Petition by Petitioner Challenging Tender Rejection by KPTCL - No Violation of Natural Justice Found in Battery Energy Storage System Tender Process

Sub Category: Karnataka High Court Bench: BENGALURU
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Case Note & Summary

The petitioner, filed a writ petition under Articles 226 and 227 of the Constitution of India challenging the rejection of its bid in a tender process for a Battery Energy Storage System by Karnataka Power Transmission Corporation Limited (KPTCL) -- The petitioner claimed violation of natural justice as no reasons were communicated for the rejection -- The Court examined the principles of judicial review in contractual matters, citing the Supreme Court decision in Jagdish Mandal v. State of Orissa -- The Court held that judicial interference in tender matters is limited and should not be invoked to protect private interests at the cost of public interest -- The Court found that the petitioner had access to the tender portal where the rejection was displayed, thus there was no violation of natural justice -- The writ petition was dismissed with costs imposed on the petitioner

Headnote

The High Court of Karnataka dismissed a writ petition challenging the rejection of a bid in a tender process for setting up a grid-connected standalone Battery Energy Storage System -- The petitioner, Forceone SD Private Limited, participated in the tender invited by Karnataka Power Transmission Corporation Limited (KPTCL) but was declared non-responsive -- The petitioner sought writs of certiorari and mandamus, claiming violation of natural justice due to non-communication of rejection reasons -- The Court held that judicial review in contractual matters is limited and courts should not interfere unless there is arbitrariness, irrationality, or mala fides -- Relying on Jagdish Mandal v. State of Orissa (2007) 14 SCC 517, the Court emphasized that evaluating tenders is a commercial function and principles of natural justice have limited application -- The Court found no violation of natural justice as the petitioner had access to the tender portal where the rejection was displayed -- The petition was dismissed with costs of Rs. 25,000/-

Issue of Consideration: The Issue of consideration was whether the rejection of the petitioner's bid without communication of reasons violated natural justice and warranted judicial interference in tender matters

Final Decision

The writ petition was dismissed with costs imposed on the petitioner

2026 LawText (KAR) (01) 16

WP No. 26719 of 2025 (GM-TEN)

2026-01-27

Suraj Govindaraj J.

HC-KAR NC: 2026:KHC:4395

Sri. Sahil Sood, Sri. Mohsin Khan Pathan for Petitioner; Smt. D.J. Rakshitha for Respondent 1; Sri. K. Shashi Kiran Shetty, Smt. K.P. Yashodha for Respondent 4; Sri. Venkatanarayana for Respondent 5

Forceone SD Private Limited

Karnataka Power Transmission Corporation Limited, Karnataka Electricity Regulatory Commission, Karnataka State Load Dispatch Centre, Government of Karnataka Energy Department, Ministry of Power Government of India

Nature of Litigation: Writ petition challenging tender rejection

Remedy Sought

Petitioner seeking writs of certiorari and mandamus to declare the rejection of its bid as illegal and to direct re-evaluation

Filing Reason

Petitioner's bid was declared non-responsive in a tender process without communication of reasons

Previous Decisions

No previous decisions mentioned in the judgment

Issues

Whether the rejection of the petitioner's bid without communication of reasons violated principles of natural justice Whether judicial interference is warranted in the tender process under Articles 226 and 227 of the Constitution of India

Submissions/Arguments

Petitioner argued that rejection without communication of reasons violated natural justice and rendered the decision bad in law Petitioner claimed clear violation of natural justice and infirmity in decision-making process Petitioner relied on Jagdish Mandal v. State of Orissa to support maintainability of writ petition

Ratio Decidendi

Judicial review in contractual matters is limited and courts should not interfere unless there is arbitrariness, irrationality, unreasonableness, bias, or mala fides -- Evaluating tenders is a commercial function where principles of natural justice have limited application -- Courts will not interfere if the decision is bona fide and in public interest -- Access to tender portal where rejection was displayed satisfied communication requirements

Judgment Excerpts

Judicial review of administrative action is intended to prevent arbitrariness, irrationality, unreasonableness, bias and mala fides Evaluating tenders and awarding contracts are essentially commercial functions Principles of equity and natural justice stay at a distance If the decision relating to award of contract is bona fide and is in public interest, courts will not, in exercise of power of judicial review, interfere

Procedural History

Tender issued on 11.06.2025 -- Pre-bid meeting on 18.06.2025 -- Bid submission last date 03.07.2025 -- Petitioner submitted bid on 08.07.2025 -- Bid declared non-responsive on 19.08.2025 -- Reverse auction held on 19.08.2025 -- Petitioner approached Court on 29.08.2025 -- Writ petition filed under Articles 226 and 227 of Constitution of India -- Case reserved for orders on 11.12.2025 -- Judgment pronounced on 27.01.2026

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