Adherence to Selection Criteria is Mandatory and Vested Third-Party Rights Cannot Be Unsettled Absent Patent Illegality

The Appellant applied for a Gramin LPG Distributorship following a June 2017 advertisement and was selected via draw of lots in August 2018

Her candidature was subsequently cancelled by BPCL on February 14, 2020

The cancellation was based on the Appellant's failure to provide correct land documents for the proposed showroom within the stipulated timeframe; specifically, the original lease deed contained an incorrect Khesra number

Although BPCL offered a one-time opportunity to provide alternative land, the Appellant submitted a correction deed only after the application deadline

A Writ Petition challenging the cancellation was dismissed by a Single Judge on December 13, 2024, noting the failure to meet guidelines and the intervening creation of third-party rights in favor of Respondent No. 4, who had already invested in the facility

1. Whether the impugned judgment of the Single Judge suffers from legal infirmity warranting interference under intra-court appellate jurisdiction

2. Whether a typographical error in land particulars can be rectified after the prescribed deadline in a public selection process

3. Whether the Court should unsettle an allotment after third-party rights have crystallized and substantial investments have been made

The Court applied the principle that terms of a selection process must be adhered to strictly and uniformly to avoid arbitrariness, as established by the Supreme Court in Bedanga Talukdar v. Saifudaullah Khan (2011) 12 SCC 85

It further applied the doctrine of administrative finality regarding third-party rights, which dictates that Courts should exercise restraint in unsettling rights where a beneficiary has altered their position based on valid administrative action, unless the action is patently illegal or mala fide

The Court reasoned that the Appellant failed to satisfy the eligibility criteria within the mandatory timeframe, as the correction deed was executed after the last date for applications

Relying on Bedanga Talukdar, the Court emphasized that selection guidelines cannot be relaxed for individual candidates as it would introduce inequity into the process

Crucially, the Court observed that Respondent No. 4 had already been allotted the distributorship and had made "substantial investments" toward construction

Since the Appellant failed to file a rejoinder to contest these facts or prove that the allotment to Respondent No. 4 was illegal or motivated by mala fides, the Court held that the balance of equity favored maintaining the status quo to protect crystallized third-party interests

It held that there was no legal infirmity in the Single Judge’s order because the Appellant failed to provide valid documents within the stipulated time and third-party rights had already attained finality

The High Court affirmed that it will not divest accrued rights of a third party in the absence of established illegality