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2026 Supreme(Raj) 433

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

Advocates Appeared:
For the Petitioner: Mr. Ashish Poonia.

The highest or sole bidder in an e-auction of public property lacks an indefeasible right to bid acceptance. Authorities retain the discretion to reject bids to maximize revenue and ensure fair market value, provided the decision is transparent, reasonable, and free from manifest arbitrariness or mala fides.

Headnote:(A) Rajasthan Municipalities (Disposal of Urban Land) Rules, 1974 - Rule 14, Annexure-A, Clause (j) - E-auction of public property - Authority of Chairperson to accept or reject bids - Judicial review - Interference under Article 226 of the Constitution of India is permissible only in instances of manifest arbitrariness, mala fide, or violation of statutory mandates - Sole bidder does not possess an indefeasible right to mandatory acceptance of a bid - Primary objective of disposal of public assets through auction is to ensure transparency, competition, and realization of maximum revenue. (Paras 9, 13, 17 and 19)

(B) Administrative Discretion - Scope of - Financial assessment and policy decisions regarding public property management are within the purview of the governing authority - Courts should not sit in appeal over legitimate assessments of fair market value intended to safeguard public interest. (Paras 16 and 18)

Facts of the case:
The petitioner participated as the sole bidder in an e-auction for a corner plot. The bid offered was only marginally higher than the reserve price. The auctioning authority rejected the bid, benchmarking the potential value against a similar nearby property sold previously at a significantly higher rate. The petitioner challenged this rejection, asserting that being the highest and sole bidder entitled him to the acceptance of his bid, and questioning the basis of the rejection under the relevant municipal rules.

Findings of Court:
The court determined that the absence of multiple participants stripped the auction of its competitive character. The rejection of the bid was found to be a reasoned, prudent, and non-arbitrary exercise of authority aimed at protecting public interest by seeking maximum potential value for public land. The authority's decision aligned with the objective of ensuring financial transparency and fairness in the disposal of assets.

Issues: The main issues were whether a sole bidder in an e-auction has an indefeasible right to have their bid accepted, and whether the respondent authority’s decision to reject the bid based on a comparison of potential market value was arbitrary or contrary to law.

Ratio Decidendi: An authority conducting an e-auction for public property reserves the right to reject bids to ensure optimal revenue realization. When an auction process fails to elicit competitive participation, the authority is justified in rejecting a sole, low-value bid in the broader public interest, provided no evidence of mala fide intent is shown. Judicial interference is restrained when the decision-making process is based on reasonable financial assessments.

Result: Petition dismissed.

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

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