Article 226 jurisdiction is inappropriate for adjudicating serious disputed facts underlying blacklisting proceedings.

The petitioner was empanelled as a training partner under the National Action Plan for Skill Development of Persons with Disabilities and was offered training of 3,990 persons with disabilities at 21 centres.

The respondents released ₹41,62,086 towards the first instalment for training 510 trainees in 17 batches.

During surprise inspections conducted in June 2024, the respondents allegedly found manipulation of biometric attendance, discrepancies in the number of trainees physically present, and forged or fabricated supporting documents.

The petitioner submitted a clarification, followed by replies to show-cause notices dated 14 February 2025 and 15 May 2026.

Thereafter, the respondents passed an order dated 17 July 2026 blacklisting the petitioner and issued a demand notice dated 21 July 2026 seeking recovery of ₹41,62,086 with 10% penal interest.

The petitioner challenged these actions under Article 226, contending that only 17 batches were assessed and that no trainee was examined.

Whether the impugned blacklisting order and demand notice were liable to be quashed on the ground that the respondents had inspected only certain batches and had not examined any trainee.

Whether the writ court should exercise jurisdiction under Article 226 where adjudication of the challenge required determination of disputed questions of fact concerning biometric manipulation and forged documents.

The Court applied the principle that jurisdiction under Article 226 of the Constitution ought not ordinarily to be exercised where resolution of the dispute involves serious and disputed questions of fact requiring appreciation and evaluation of evidence, particularly where such issues cannot be satisfactorily adjudicated on affidavits alone.

The Court also applied the administrative-law principle that judicial review does not warrant interference merely because the authority relied on inspections or material that the petitioner disputes, unless the decision is shown to be arbitrary or otherwise legally unsustainable.

No specific statutory provision or judicial precedent was cited in the judgment.

The Court found prima facie material indicating manipulation of biometric attendance and fraudulent conduct.

In several batches, the number of trainees physically present was nil, five, or three, while biometric records showed 26, 29, and 27 trainees respectively.

At another centre, no trainee was present although biometric records reflected the presence of 45 trainees.

The petitioner’s explanation that trainees had left because of heavy rain was not accepted as sufficient, particularly since the newspaper reports relied upon to support that explanation appeared to have been digitally altered as to their publication dates.

The Court held that the limited inspection of batches and non-examination of trainees did not, by themselves, establish arbitrariness.

Since the challenge involved disputed factual questions regarding attendance records, inspections, and alleged forged documents, the Court declined to undertake a detailed evidentiary examination in writ proceedings.

It declined to quash either the blacklisting order dated 17 July 2026 or the demand notice dated 21 July 2026, and dismissed the writ petition along with the connected applications.