State of M.P. v. M/s Ruchi Printers
Background
The Madhya Pradesh government had placed a printing order with Ruchi Printers for land-record booklets, with a firm deadline of 31.3.2008 after which no further booklets would be accepted. A later communication dated 22.5.2008 appeared to allow acceptance of more booklets, but the government cancelled that communication in 2009. The High Court had directed the State to honour the 22.5.2008 communication and accept/pay for the later-printed booklets; the State appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that time was of the essence of the printing contract, and that the printer had no authority to print booklets after the clear 31.3.2008 cut-off communicated by the government. The 22.5.2008 communication purporting to allow late supply was found to be "palpably illegal" and was rightly cancelled by the State in 2009, so no enforceable right arose from it. The High Court's order compelling acceptance of the late-printed booklets was therefore set aside, though the Court clarified that any payment still owed for booklets genuinely supplied on time (by 31.3.2008) must be made forthwith.
Lesson Learnt
In government supply contracts, once a deadline is clearly and unambiguously communicated, a supplier cannot claim payment for work done after that cut-off merely because a later, irregular communication seemed to suggest otherwise: courts will look at what was actually and validly authorized.