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2026 Supreme(Online)(Chh) 12013

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Amitendra Kishore Prasad, J
Vijay Laxmi Joshi – Appellant
Versus
State Of Chhattisgarh – Respondent
WPC No. 2575 of 2021

Advocates:
For the Appellants/Petitioners: Roop Ram Naik
For the Respondents: D.R. Minj

A writ of mandamus for agricultural procurement or loan waiver cannot be issued where the claimant fails to satisfy objective eligibility criteria stipulated under a state-monitored portal-based policy, as legitimate expectation cannot override mandatory administrative conditions.

Headnote:(A) Constitution of India - Article 226 - Writ of Mandamus - Agricultural procurement - Eligibility - Petitioner sought directions for procurement of paddy, loan waiver and scheme benefits - Held, procurement is portal-based and requires valid registration in digital records - Petitioner failed to establish eligibility as name was not in the procurement database - Mandamus cannot be issued contrary to governing policy - Loan liability and procurement operate in distinct fields - No enforceable legal right established. (Paras 7-10, 12, 13)

(B) Legitimate Expectation - Doctrine of - Applicability - Issuance of a procurement token is a procedural step and does not create an indefeasible right to procurement if eligibility conditions are not met - Legitimate expectation cannot override mandatory statutory or policy requirements. (Paras 8, 11)

(C) Scope of Judicial Review - Executive Policy - Courts should not interfere in matters of agricultural policy and financial concessions unless patent arbitrariness or violation of statutory right is shown. (Paras 10, 14)

Facts of the case:
The petitioner was a farmer who availed a loan under the KCC scheme and was initially issued a procurement token for paddy. However, the procurement centre later refused to purchase the crop, citing non-compliance with digital portal entry requirements. The petitioner sought relief for compelled procurement, loan waivers, and agricultural scheme benefits.

Findings of Court:
The court found that the procurement process is strictly governed by digital portal entries and registered land records. Since the petitioner was not properly reflected in the system, the authorities were legally restricted from acting. The token provided was merely a provisional document and did not confer a vested right.

Issues: Whether the court can issue a mandamus to compel paddy procurement, waive loans, or grant scheme benefits in the absence of portal-based eligibility.

Ratio Decidendi: A writ of mandamus requires a clear subsisting legal right and a corresponding public duty. Since the procurement policy mandated specific eligibility criteria that the petitioner did not fulfill, and legitimate expectation cannot override these policy conditions, the court cannot interfere.

Result: Writ petition dismissed.

Table of Content
1. summary of petitioner claims and state resistance regarding paddy procurement. (Para 1 , 2 , 3 , 4 , 5)
2. procurement is governed by portal registration and strictly policy-bound eligibility. (Para 6 , 7 , 8)
3. limitations of writ jurisdiction regarding loan waivers and doctrine of legitimate expectation. (Para 9 , 10 , 11 , 12 , 13)
4. judicial restraint in policy matters and formal dismissal of the petition. (Para 14 , 15 , 16)

NAFR

SB- Hon'ble Shri Justice Amitendra Kishore Prasad

Order On Board

24.03.2026

1. The petitioner has filed the instant petition before the Hon’ble High Court seeking a direction to the respondent authorities to purchase the registered and prescribed paddy from the petitioner forthwith and to recover the loan amount of Rs. 2,70,052/- without interest and further to grant benefits/input assistance in favour of the petitioner under the Rajiv Gandhi Kisan Nyay Yojna 2020–21. The petitioner had cultivated the crop with the assistance of Respondent No. 11 on the agricultural land and, upon his turn arising, Respondent No. 11 issued a paddy procurement token dated 03.01.2021 specifying the prescribed quantity of paddy. The petitioner accordingly brought the paddy to the premises of Respondent No. 11 on 05.01.2021; however, on 06.01.2021, Respondent No. 11 refused to purchase the same by recording a note on the said token citing an order of Respondent No. 10, thereby causing grave prejudice and financial loss to the petitioner.

2. Facts of the case are that the petitioner is a registered beneficiary under the Public Financial Management System (PFMS) and on the basis of such registration has availed loan from Respondent No. 11 under the Kisan Credit Card (KCC) Scheme for the Kharif season 2020–21, which was utilized for cultivation of paddy on her agricultural land with the assistance of Respondent No. 11. Upon her turn arising, Respondent No. 11 issued a paddy procurement token dated 03.01.2021 specifying the prescribed quantity, and accordingly the petitioner brought her paddy to the procurement centre on 05.01.2021; however, on 06.01.2021, Respondent No. 11 refused to purchase the same by making an endorsement on the token citing instructions of Respondent No. 10, as a result of which the paddy remains unsold and is still lying with the petitioner who is ready and willing to sell the same even today. It is submitted that the petitioner is unable to repay the loan amount of Rs. 2,70,052/- along with accrued interest since 31.03.2021 due to non-purchase of her paddy, and there is apprehension that Respondent No. 11 may initiate coercive civil or criminal proceedings for recovery and may also deprive the petitioner of benefits under the KCC Scheme and the Rajiv Gandhi Kisan Nyay Yojna for the year 2021–22. Therefore, the petitioner has preferred the present petition seeking direction to the respondent authorities to purchase the registered quantity of paddy and recover the loan amount without interest or in the alternative to waive the loan if procurement is not undertaken, and further to grant input assistance under the Rajiv Gandhi Kisan Nyay Yojna 2020–21 as well as to provide fresh agricultural loan, including seeds, fertilizers and cash assistance, for the Kharif season 2021–22 with recovery to be made through mandi in accordance with law.

3. Following reliefs have been prayed by way of this petition:-

10.1 That, this Hon'ble Court may kindly be pleased to issue appropriate writ by directing the respondent authority to purchase the registered and prescribed paddy from the petitioner immediately and recover the loan amount of Rs. 2,70,052/- without interest.

10.2 That, this Hon'ble Court may kindly be pleased to issue appropriate writ by directing the respondent authority to exempt the entire loan (Rs. 2,70,052/-), if the respondents authority is unable to purchase the registered the paddy quantity (150 quintals).

10.3 That, this Hon'ble Court may kindly be pleased to issue

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2026 Supreme(Online)(Chh) 12013

IN THE HIGH COURT OF CHHATTISGARH AT BILASPURAmitendra Kishore Prasad, JVijay Laxmi Joshi – AppellantVersusState Of Chhattisgarh – RespondentWPC No. 2575 of 2021

A writ of mandamus for agricultural procurement or loan waiver cannot be issued where the claimant fails to satisfy objective eligibility criteria stipulated under a state-monitored portal-based policy, as legitimate expectation cannot override mandatory administrative conditions.

Cases Referred (4)

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Amitendra Kishore Prasad, J
Vijay Laxmi Joshi – Appellant
Versus
State Of Chhattisgarh – Respondent
WPC No. 2575 of 2021