Patna High Court
Administrative and Public LawCommercial and Corporate Law

A successful draw confers no distributorship right when the offered land lies outside the advertised location.

Manoj Kumar Yadav vs M/s Indian Oil Corporation Limited and Ors

Patna High CourtJUDGMENT: September 22, 20262 MIN READSOURCE JUDGMENT
A successful draw confers no distributorship right when the offered land lies outside the advertised location.. Manoj Kumar Yadav vs M/s Indian Oil Corporation Limited and Ors. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Indian Oil Corporation advertised an LPG distributorship at Tisi Narsam, Gram Panchayat Tisi Narsam South, Madhubani, under the OBC category. The petitioner applied, was selected in the draw of lots, and deposited ₹30,000.

Source reference: paras. 2–4, 11

During field verification, the Corporation found that the showroom land offered by him was at Sakradhi/Sakrari, not at the advertised location.

Source reference: paras. 2–4, 11

The petitioner relied on Circle Officer certificates alleging a discrepancy in the advertised location and asked that his land be accepted or that he be allowed to offer alternative land.

Source reference: paras. 2–4, 11

The Corporation rejected his candidature and forfeited the deposit. A fresh selection followed, and the distributorship was commissioned in favour of another candidate.

Source reference: paras. 2–4, 11
02

Issues

1. Whether the Corporation lawfully rejected the petitioner’s candidature because the offered showroom land was outside the advertised location, notwithstanding the alleged discrepancy in the advertisement.

Source reference: paras. 16–19

2. Whether the petitioner’s selection in the draw of lots entitled him to the distributorship or otherwise warranted interference with the rejection order.

Source reference: paras. 19–22
03

Law Applied

The Unified Guidelines for Selection of LPG Distributors, 2017 required a candidate to satisfy the prescribed eligibility conditions, including the requirement that the showroom land be within the advertised location.

Source reference: paras. 8, 16

A public corporation, as a State instrumentality under Article 12, must act fairly and uniformly and adhere to the standards stated in its advertisement; allowing departures may undermine equal treatment (M/s Indian Oil Corporation Limited v. Raj Kumar Jha & Ors., 2012 (2) PLJR 783).

Source reference: paras. 13–14, 20

Success in a draw of lots, subject to verification of eligibility, does not confer an indefeasible or vested right to the distributorship.

Source reference: paras. 16, 19
04

Reasoning

The Court found that the petitioner’s offered land was at Sakradhi/Sakrari rather than the advertised location, Tisi Narsam. Although he was given an opportunity to offer alternative land within the advertised location, he did not do so and continued to seek acceptance of the original site.

Source reference: para. 17

The alleged discrepancy in the advertisement did not excuse non-compliance with the location requirement, and his success in the draw did not create a right to the distributorship.

Source reference: paras. 18–19

The Court applied the requirement of strict adherence to advertised selection criteria and also noted that the distributorship had been commissioned in favour of a third party.

Source reference: paras. 20–21
05

Holding

The Court held that the Corporation’s rejection of the petitioner’s candidature did not warrant interference.

It dismissed the writ petition as devoid of merit and disposed of any pending interlocutory applications.

Source reference: paras. 22–25
Patna High Court

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Manoj Kumar YadavvsM/s Indian Oil Corporation Limited and Ors

Patna High Court · September 22, 2026

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