Patna High Court
Administrative and Public LawConstitutional Law

A successful applicant’s failure to deposit prescribed security on time justifies rejection under the advertised terms.

Munna Prasad Yadav vs The Indian Oil Corporation Limited

Patna High CourtJUDGMENT: September 23, 20262 MIN READSOURCE JUDGMENT
A successful applicant’s failure to deposit prescribed security on time justifies rejection under the advertised terms.. Munna Prasad Yadav vs The Indian Oil Corporation Limited. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Indian Oil Corporation invited applications for an LPG distributorship at Kharagpur, Saharsa. The petitioner applied and was selected in a draw of lots held on 24 January 2018.

Source reference: pp. 5–6

He was required to submit specified documents and deposit the prescribed 10% security amount within the stipulated period. He claimed that the Corporation’s office did not accept his documents and deposit when he approached it; the Corporation maintained that he failed to comply despite a reminder.

Source reference: pp. 5–6

By order dated 6 July 2018, the Corporation cancelled his candidature for non-payment of the security amount within time. The petitioner challenged that order.

Source reference: pp. 5–6

The Corporation stated that a fresh draw had been held, respondent No. 5 had been selected, and the distributorship had been commissioned.

Source reference: pp. 5–6
02

Issues

Whether the Corporation’s rejection of the petitioner’s candidature for failure to deposit the prescribed security amount within the stipulated period warranted interference

Source reference: pp. 9–10

Whether the petitioner had established a valid ground for relaxation of the advertised requirement, particularly in light of the subsequent selection and commissioning of the distributorship

Source reference: p. 10
03

Law Applied

The Court applied the principle that a public corporation, as a State instrumentality under Article 12 of the Constitution, must act fairly, reasonably, and uniformly and adhere to the standards prescribed in its advertisement.

Source reference: pp. 7–9

Relying on M/s Indian Oil Corporation Ltd. v. Raj Kumar Jha & Ors., 2012 (2) PLJR 783, the Court reiterated that departure from advertised requirements risks subjective treatment and that strict adherence promotes uniformity.

Source reference: pp. 7–9

The Court also referred to the order in Mukesh Pandey v. Hindustan Petroleum Corporation & Ors., LPA No. 925 of 2012.

Source reference: p. 7
04

Reasoning

The Court treated the failure to deposit the 10% security amount within the stipulated period as the decisive and undisputed circumstance.

Source reference: pp. 9–10

It held that the petitioner had not established a valid basis for relaxing that requirement, and that granting an individual relaxation would be inconsistent with the requirement that the Corporation apply the advertisement uniformly.

Source reference: pp. 9–10

The subsequent selection of respondent No. 5 and commissioning of the distributorship further weighed against interference.

Source reference: p. 10
05

Holding

The Court held that the petitioner had shown no ground to set aside the order dated 6 July 2018.

The writ petition was dismissed, and any pending interlocutory applications were disposed of.

Source reference: pp. 9–10
Patna High Court

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Munna Prasad YadavvsThe Indian Oil Corporation Limited

Patna High Court · September 23, 2026

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