Case Note & Summary
The appellants, Manipal Technologies Limited (MTL) and its shareholder, filed a writ appeal against an interim order of a Single Judge declining interim relief in a tender dispute. MTL had submitted a bid pursuant to a Request for Proposal (RFP) issued by Bank of Baroda (BoB) for empanelment of vendors for printing and supply of magnetic strip and variable QR code printed self-service passbooks. MTL's bid was not evaluated because it did not meet the pre-qualification criteria under point No.14 of the tender conditions, which required specific experience in printing of magnetic strip and QR code passbooks. The disqualification was reflected on the Government eMarketplace portal on 26.05.2026. The appellants challenged the disqualification as arbitrary and discriminatory. The Single Judge declined interim relief, leading to the present appeal. The Division Bench held that the tender conditions are binding and the authority's interpretation, if plausible, should not be interfered with unless mala fides or arbitrariness is shown. The court found that MTL did not demonstrate that it met the criteria, and the evaluation was consistent. The appeal was dismissed.
Headnote
A) Tender Law - Pre-qualification Criteria - Judicial Review - The court examined whether the Bank of Baroda's decision to disqualify Manipal Technologies Limited for not meeting the specific experience requirement under point No.14 of the RFP was arbitrary. Held that the tender conditions are binding and the authority's interpretation, if plausible, should not be interfered with unless mala fides or arbitrariness is shown. (Paras 1-10)
B) Tender Law - Level Playing Field - The court considered the argument that the disqualification was discriminatory as other bidders were allowed. Held that the appellant failed to demonstrate that it met the criteria, and the evaluation was consistent. (Paras 5-8)
Issue of Consideration
Whether the disqualification of the appellant's bid for not meeting the pre-qualification criteria under point No.14 of the tender conditions was arbitrary and liable to be set aside.
Final Decision
The appeal is dismissed. The impugned order dated 08.06.2026 passed by the learned Single Judge in W.P. No.16741/2026 is upheld.
Law Points
- Tender law
- Judicial review of tender conditions
- Pre-qualification criteria
- Arbitrariness
- Level playing field
Case Details
2026 LawText (KAR) (07) 20
WA No. 1602 of 2026 (GM-TEN)
Vibhu Bakhru, Chief Justice, K.S. Hemalekha, Justice
Sri K.G. Raghavan, Senior Advocate for Sri Raghuram Cadambi, Advocate for appellants; Sri K. Shashi Kiran Shety, Advocate General/Senior Advocate a/w Sri Vignesh Shetty, Advocate for C/R-1; Smt. Amrutha B.R., Advocate for R-3
Manipal Technologies Limited and Jyothi G. Nayak
Bank of Baroda, Seshaasai Technologies Limited, KL Hi-Tech Secure Print Limited
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Nature of Litigation
Writ appeal against interim order declining interim relief in a tender disqualification matter.
Remedy Sought
Appellants sought to set aside the impugned order dated 08.06.2026 passed by the learned Single Judge in W.P. No.16741/2026 insofar as it declines the interim reliefs sought by the appellants.
Filing Reason
Appellant No.1's bid was not evaluated because it did not meet the pre-qualification criteria under point No.14 of the tender conditions.
Previous Decisions
The learned Single Judge declined to grant any interim relief by order dated 08.06.2026.
Issues
Whether the disqualification of the appellant's bid for not meeting the pre-qualification criteria under point No.14 of the tender conditions was arbitrary and liable to be set aside.
Submissions/Arguments
Appellants argued that the disqualification was arbitrary and discriminatory as other bidders were allowed.
Respondent Bank of Baroda contended that the appellant did not meet the specific experience requirement and the evaluation was consistent.
Ratio Decidendi
Tender conditions are binding and the authority's interpretation, if plausible, should not be interfered with unless mala fides or arbitrariness is shown. The appellant failed to demonstrate that it met the pre-qualification criteria.
Judgment Excerpts
The appellants have filed the present appeal impugning an interim order dated 08.06.2026 passed by the learned Single Judge in Writ Petition No.16741/2026 (GM-TEN) [impugned order].
Appellant No.1 [MTL] had submitted its bid pursuant to the Request for Proposal for Empanelment of Vendors for Printing and Supply of Magnetic Strip and Variable QR code Printed Self-Service Passbook (SSPB) [RFP] issued by Respondent No.1 – Bank of Baroda [BoB].
However, MTL's bid was not evaluated because it did not meet the pre-qualification criteria under point No.14 of the tender conditions.
Procedural History
The appellants filed W.P. No.16741/2026 before the High Court of Karnataka challenging the disqualification. The learned Single Judge declined interim relief by order dated 08.06.2026. The appellants then filed the present writ appeal under Section 4 of the Karnataka High Court Act, 1961. The appeal was reserved on 24.06.2026 and judgment pronounced on 16.07.2026.
Acts & Sections
- Karnataka High Court Act, 1961: Section 4
