HIGH COURT OF JUDICATURE FOR RAJASTHAN, BENCH AT JAIPUR
MANEESH SHARMA, J.
Pawan Kumar Meena, S/o. Shri Shiv Charan Meena - Petitioner
Versus
State of Rajasthan, Through The Principal Secretary, Urban Development And Housing Department – Respondent
S.B. Civil Writ Petition No. 9109 of 2026
Decided On : 21-05-2026
| Table of Content |
|---|
| 1. factual overview of the auction and rejection. (Para 1 , 2 , 3 , 4 , 5) |
| 2. petitioner's contention regarding arbitrary bid rejection. (Para 6 , 7) |
| 3. authority's right to reject sole bids for public interest. (Para 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16) |
| 4. restrictive scope of judicial review in bid cancellation. (Para 17 , 18 , 19 , 20) |
| 5. distinguishing precedents; absence of irreparable personal loss. (Para 21 , 22) |
| 6. conclusion upholding the validity of the authority's decision. (Para 23 , 24 , 25) |
Order :
MANEESH SHARMA, J.
1. The present writ petition has been filed by the petitioner, assailing the rejection letters/orders dated 30.04.2026 and 01.05.2026 passed by respondent No. 3.
2. Brief facts giving rise to the present writ petition are that the Urban Improvement Trust, Alwar, issued an e-auction programme for the sale of various residential/commercial plots, including the property in question, i.e., Plot No. K165 (Corner Plot), Ambedkar Nagar, Alwar (hereinafter referred to as the 'Subject Plot'), which was listed at Serial No. 40.
3. The petitioner participated in the e-auction for the Subject Plot and accordingly submitted his bid. After the closure of the bid process, the petitioner sought official confirmation via e-mails dated 23.04.2026 and 27.04.2026. Upon seeking the said confirmation, the petitioner was orally informed that his bid had been rejected.
4. Subsequently, upon detailed representations dated 28.04.2026 and 02.05.2026 filed by the petitioner, respondent No. 3 issued letters dated 30.04.2026 and 01.05.2026, wherein it was stated that the petitioner's bid was rejected under Condition 12 of the terms and conditions of the e-auction and Rule 14 , Annexure- A, Clause (j) of the Rajasthan Municipalities (Disposal of Urban Land) Rules, 1974 (hereinafter referred to as "the Rules of 1974"), since the Subject Plot K-165 had not fetched its appropriate value as the opposite Plot No. K-166 sold in e-auction held in November 2025 @ Rs. 79,500/-.
5. Upon a query being made to learned counsel for the petitioner by this Court, learned counsel for the petitioner fairly admits that the petitioner was the sole bidder in respect of the e-auction of the Subject Plot K-165.
6. Learned counsel for the petitioner submits that the respondent-Authorities have arbitrarily rejected the petitioner's bid despite his being the sole and highest bidder for the Subject Plot. He further submits that the alleged reason for rejection of the bid vis-a-vis Condition 12 of the terms and conditions of the e-auction as well as Rule 14 , Annexure-A, Clause (j) of the Rules of 1974 is unsustainable in the eye of law, as the discretion of the Chairman cannot be arbitrary. He further submits that the reason for rejection of the bid qua inadequate bid amount or auction did not realize the potential value similar to the opposite Plot No. K-166 is also contrary to the mandate of the law. He, therefore, prays that the rejection letters/orders dated 30.04.2026 and 01.05.2026 may be quashed and set aside among other consequential prayers.
7. In order to buttress his contention, he places reliance upon a judgment passed by the Co-ordinate Bench of this Court in the matter of Kamla Jain Vs. State of Rajasthan and Ors. , S.B. CWP No.15608/2025 and a judgment of the Hon'ble Apex Court in the matter of Golden Food Products India Vs. State of Uttar Pradesh and Ors. , 2026 SCC Online SC 24.
8. Heard and considered the submissions made by learned counsel for the petitioner and perused the material available on record.
9. The fundamental objective of an e-auction is to guarantee transparency, encourage competition, and maximize revenue through the active participation of multiple bidders. Where an auction elicits a response from merely a single bidder, the process is divested of its inherent competitive character. To accept the bid of a sole bidder, particularly when adequate bid amount is not quoted in comparison to the previous auction held in t

The court affirmed that auction authorities have discretion to reject bids, even if they are the highest, based on competitive bidding considerations.
Point of Law - Once State decides to grant any right or privilege to others, then there is no escape from rigour of Article 14.
The authority has the right to cancel the highest bid and the bids must be competitive. The authority reserves the right to accept or reject any bid without assigning any reason.
Bidders participating in tender process have no other right except right to equality and fair treatment in matter of evaluation of competitive bids offered by interested persons in response to notice....
The authority conducting an auction has the right to reject the highest bid and the decision-making process must be fair and reasonable.
The BDA has the authority to reject bids in e-Auctions without justification, as per its Rules, and such discretion is not subject to judicial review unless proven arbitrary.
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