Satinder Pal Singh & Ors. v. Bedi Hospital & Ors.
Background
The Chandigarh Administration auctioned a hospital plot, won by Bedi Hospital for a price well below an adjoining plot's value. Before the final Allotment Letter and Conveyance Deed were issued, the Administration cancelled the award and refunded the money, re-auctioning the site to a higher bidder. Bedi Hospital challenged the cancellation, and the High Court ruled in its favor.
Decision Breakdown
The Supreme Court held that under the applicable rules, an enforceable sale contract arises only upon execution of the Conveyance Deed, not merely from winning a bid. Since no such deed had been issued, the Administration retained its right to cancel without needing to justify it, so long as it acted fairly and for a genuine public purpose (securing a better price), which it had done transparently here. However, finding the High Court's own interim orders had created an unfair years-long limbo, the Court directed a fresh, properly conducted e-auction for the site within three months rather than simply awarding it to either party.
Lesson Learnt
In government auctions of public property, winning a bid and paying money does not create a binding sale: the contract is only finalized once the Conveyance Deed is executed; until then, the authority can cancel and re-auction to secure a fair price if it acts transparently and refunds promptly.