Judicial review of tender processes is limited to reviewing the fairness of decision-making. Courts will not adjudicate technical disputes or intervene in automated bidding processes on the basis of alleged portal malfunctions when such claims lack substantiated evidence and user compliance with established procedural timelines is absent.

JUDGMENT :

ANIL KSHETARPAL, J.

1. Through the present Petition, the Petitioner by invoking writ jurisdiction of this Court under Article 226 of the Constitution of India, essentially seeks directions to treat its bid for Coal Bed Methane (CBM) Block SR-ONHP(CBM)-2025/2 in Raniganj Coalfield, West Bengal, as validly submitted in the Special CBM Bid Rounder-2025 and to consider the same along with other bids, or, in the alternative, to reconduct the bidding process for the said block.

2. The primary grievance of the Petitioner is that its bid could not be completed due to an alleged technical malfunction/error that arose at the critical stage of online price bid submissions on the e-bidding portal, which displayed that the net worth of the Petitioner was insufficient.

3. The question that arises in the present case is as to whether the Petitioner stood deprived of opportunity to submit its financial bid owing to a technical malfunction in the bid portal?

4. To answer the aforesaid question, it would be appropriate to understand the turn of events that took place. Pursuant to the Hydrocarbon Exploration and Licensing Policy ('HELP'), Respondent No.1 through Respondent No.2, floated a Notice Inviting Offers ('NIO') dated 15.04.2025 under the Open Average Licensing Policy ('OALP'), thereby inviting online bids for three Onland CBM Blocks, including the subject CBM Block, on a revenue sharing basis.

5. The NIO prescribed, inter alia, minimum net worth requirements, architecture of bidding process and the twin requirement of valid bid submission, namely, timely online submission through the DGH/Respondent No.2 e-portal, and mandatory submission of hard copies of documents along with bid bond and supporting Bank Guarantee or Insurance surety Bond in lieu of net worth. Additionally, in terms of the NIO, where the net worth of a bidder was less than the prescribed minimum net worth, the bidder had the option of topping up the same through a Bank Guarantee. However, the bid including the financial bid was requested to be uploaded online.

6. Initially, the deadline for closure of bid submission was 18.02.2026, however, the same was extended till 05.03.2026 (12:00 hrs.) for all bidders. Upon closure of the bidding window, the online bids were opened by the Respondents and four entities namely, Oil India Limited, Essar Oil and Gas Exploration and Production Limited, Consortium of: Oilmax Energy Pvt. Ltd. and SAS Infotech Pvt. Ltd. and lnvenire Petrodyne Limited were found to have submitted their complete bid.

7. It may be noted that while the system displayed the status of other bidders as submitted on the portal, the Petitioner's status reflected as not submitted.

8. It is the Petitioner’s case that on 05.03.2026, after physically submitting the mandatory documents, it proceeded to complete the e-filing formalities on the e-portal. However, during the course of submission, the e-bidding portal allegedly closed, resulting in termination of the Petitioner’s session and consequent non-submission of its bid.

9. Immediately thereafter, the Petitioner on the same date addressed an email communication to Respondent No.2, alleging a technical malfunction in the bidding portal and requesting consideration of its bid. Upon