Karnataka High Court
Administrative and Public LawCivil Procedure and Evidence

A court cannot compel evaluation of an e-bid no longer available in the procurement system.

SRI. K. M. ASHWATHNARAYANA vs THE STATE OF KARNATAKA

Karnataka High CourtJUDGMENT: October 01, 20262 MIN READSOURCE JUDGMENT
A court cannot compel evaluation of an e-bid no longer available in the procurement system.. SRI. K. M. ASHWATHNARAYANA vs THE STATE OF KARNATAKA. Karnataka High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner challenged the rejection of his bids for two municipal infrastructure packages and the dismissal of his appeals.

Source reference: paras. 1–2

An earlier order directed that, if no work order had issued, the petitioner’s financial bid be evaluated.

Source reference: para. 3

The respondents later stated that the bid had been rejected on 2 January 2026 and that the e-procurement system no longer made its documents available for evaluation.

Source reference: paras. 5–7, 12

The petitioner disputed this and asserted that the documents could be retrieved with authorisation, but produced no material demonstrating their present availability.

Source reference: paras. 9–13
02

Issues

1. Whether the petitioner’s financial bid could be retrieved from the e-procurement system and evaluated pursuant to the earlier order.

Source reference: para. 11

2. Whether any effective relief could be granted where the bid documents were unavailable for evaluation and the petitioner had not established another ground for interfering with the tender process.

Source reference: paras. 16–19
03

Law Applied

The Court applied no specific statutory provision, precedent, or substantive tender-law doctrine in resolving the matter.

Source reference: no citation

Its reasoning was confined to the practical and evidentiary limits on granting relief under its writ jurisdiction: a direction to evaluate a bid presupposes that the bid documents are available, and the Court cannot direct an evaluation shown to be technically impossible or reconstruct or substitute a bid from documents separately produced by the bidder.

Source reference: paras. 14–17
04

Reasoning

The earlier direction to evaluate the bid presupposed that the bid and its supporting documents remained accessible.

Source reference: para. 14

The respondents stated that the rejected bid was no longer accessible through the e-procurement system, and the petitioner did not provide appropriate material to establish otherwise.

Source reference: paras. 12–15

In the absence of the bid documents, the Court considered evaluation impracticable; it also declined to reconstruct or substitute the bid using separately produced documents, which would have to comply with the tender conditions and prescribed procedure.

Source reference: paras. 16–18

No other basis for interfering with the tender process was demonstrated.

Source reference: para. 19
05

Holding

The Court held that no effective direction to evaluate the petitioner’s financial bid could be issued on the record before it and dismissed the petition.

It clarified that it expressed no opinion on the merits of the bid or tender process; dismissal rested solely on the stated non-availability of the bid for evaluation.

Source reference: para. 21

Pending interlocutory applications were also disposed of.

Source reference: para. 22
Karnataka High Court

Original Court PDF

SRI. K. M. ASHWATHNARAYANAvsTHE STATE OF KARNATAKA

Karnataka High Court · October 01, 2026

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