M/s Dhanlaxmi Merchandise Pvt. Ltd. v. State of Madhya Pradesh & Ors. and connected matters
Background
Two companies had won sand-mining contracts from the Madhya Pradesh State Mining Corporation at high bids, later surrendered them, and then won a re-tender at lower (but still above-reserve) prices. The Corporation's Board rejected both fresh bids and cancelled the auction, reasoning that the lower prices compared to the companies' own earlier bids made the process "non-competitive." The Madhya Pradesh High Court upheld the cancellation.
Decision Breakdown
The Supreme Court held the cancellation unlawful and restored the original auction results. While a public authority can reject even the highest bid, that power must rest on reasons rational to the actual auction conducted. The auctions here were transparent, with multiple qualified bidders and no collusion, and bids exceeded the reserve price. Comparing the new bids to the companies' own surrendered earlier bids was legally insufficient, especially since the rule treating an old bid as a price floor for future auctions was only introduced later and could not apply retroactively.
Lesson Learnt
A government body cancelling a tender cannot invoke "public interest" or lower revenue as automatic justification: the stated reason must have real evidentiary backing specific to that process, not an arbitrary comparison to unrelated past figures.