### Appellate Authority cannot exceed jurisdictional scope by cancelling unrelated contracts not subject to the appeal.

The petitioner, a registered contractor, participated in a tender process (Tender ID 140417) issued by the Rural Works Department, Bihar.

The petitioner's bid for Tender ID 140417 was declared non-responsive on the grounds that a false experience certificate had been uploaded.

Consequently, the Engineer-in-Chief issued a show-cause notice and subsequently passed an order dated 18.09.2025 blacklisting the petitioner’s firm for two years.

The petitioner’s appeal was dismissed by the Departmental Secretary (Appellate Authority) via order dated 16.12.2025.

The appellate order not only upheld the blacklisting but also directed the cancellation of a Letter of Acceptance (LOA) for a separate, unrelated contract (Tender No. 142157).

1. Whether the penalty of blacklisting for a period of two years was disproportionate to the admitted mistake of uploading an incorrect document.

2. Whether the Appellate Authority exceeded its jurisdiction by cancelling a Letter of Acceptance for a tender that was not the subject matter of the appeal.

The court's decision is grounded in the principles of administrative law, specifically the Doctrine of Proportionality and the Scope of Appellate Jurisdiction.

Under the Bihar Contractors Registration Rules, 2007, an authority must ensure that the "penalty... is proportionate to the act alleged".

Furthermore, it is a settled principle that an appellate authority cannot travel "beyond the scope of appeal" or the "subject-matter" of the dispute to pass orders detrimental to the appellant regarding unrelated transactions.

The Court observed that while the petitioner admitted to the mistake of uploading the wrong document, the proportionality of a two-year blacklisting required re-examination.

Critically, the Court found that the Appellate Authority’s jurisdiction was confined to Tender No. 140471.

By cancelling the Letter of Acceptance for Tender No. 142157—a separate contract not under challenge in the appeal—the Appellate Authority acted outside its legal mandate.

The Court concluded that the authority had "clearly exceeded its jurisdiction" by passing directions on matters that were not part of the original dispute or the appellate proceedings.

The matter was remitted back to the Appellate Authority to reconsider the petitioner’s case, specifically regarding the proportionality of the blacklisting period and the jurisdictional error regarding the unrelated tender.

The Appellate Authority was directed to dispose of the matter within eight weeks of the petitioner filing an application for reconsideration.