An inadvertent error in uploading a lease deed is curable upon verification of the original.

Indian Oil Corporation issued an advertisement dated 28 June 2023 inviting applications for Regular/Rural Retail Outlet Dealership, including a location on “SH-1 between Salkathoni Tea Estate to Titlagarh” in Charaideo, Assam.

The petitioner executed a registered 30-year lease deed on 17 October 2023 for the offered land and applied for dealership as a Group-1 candidate on the same date. She was provisionally selected in the draw of lots.

During scrutiny, the respondents pointed out a discrepancy in her father’s name across the Scheduled Tribe certificate, HSLC certificate and lease deed; the petitioner submitted an affidavit clarifying that the names referred to the same person.

On 6 October 2024, she informed the respondents that an incorrect page of the registered lease deed had been uploaded, showing commencement from 18 October 2023, whereas the registered deed itself stipulated commencement from 17 October 2023.

The respondents rejected her candidature on 24 October 2024 on the ground that the uploaded lease commenced after the application date.

During the writ proceedings, the original registered lease deed and a certificate from the Sub-Registrar were produced, confirming commencement of the lease from 17 October 2023.

Whether the respondents were justified in rejecting the petitioner’s candidature solely on the basis of the incorrectly uploaded page of the lease deed, without considering the original registered lease deed.

Whether the erroneous uploading of a page showing an incorrect lease commencement date constituted a non-rectifiable deficiency under the applicable dealership brochure.

Whether the petitioner’s application was required to be reconsidered on the basis of the original registered lease deed dated 17 October 2023.

The Court applied the Brochure for Selection of Dealers for Regular and Rural Retail Outlets, June 2023, particularly Clauses 4(vi)(b) and 23(g).

The governing principle was that deficiencies must be treated as non-rectifiable only where expressly identified as such in the brochure.

The brochure contemplated mandatory verification of original documents, and rejection where the original document was not produced during scrutiny within the stipulated period; it did not state that uploading an incorrect page, by itself, necessarily resulted in rejection.

An inadvertent error in uploading a document is therefore curable where the original registered document establishes compliance with the eligibility requirement.

The original registered lease deed and the Sub-Registrar’s certificate conclusively showed that the lease commenced on 17 October 2023, the date on which the petitioner submitted her application.

Thus, the petitioner possessed the requisite long-term lease on the relevant date.

The rejection was based only on the mistakenly uploaded page mentioning 18 October 2023, rather than on the contents of the original registered instrument.

Since Clause 23 of the brochure did not classify such an uploading error as a non-rectifiable deficiency and the brochure required verification of original documents, the Court held that the error was inadvertent and curable.

The respondents were consequently required to consider the petitioner’s representation and evaluate her candidature on the basis of the original lease deed.

The rejection communication dated 24 October 2024 was quashed and set aside.

The respondents were directed to proceed with evaluation of the petitioner’s Group-1 application by taking into account the original registered lease deed dated 17 October 2023, with liberty to undertake further verification of the deed if considered necessary.

The interim order was vacated, and there was no order as to costs.