Article 226 permits recovery of undisputed contractual dues arbitrarily withheld by State instrumentalities.

Opposite Parties 2–5, central public-sector instrumentalities under the Ministry of Jal Shakti, invited a tender for providing architectural services for developing playfields and residential quarters connected with hydro projects in Odisha.

The petitioner, having quoted the lowest price, was awarded the contract and completed the assigned work. He submitted bills amounting to ₹16,60,809/- to Opposite Party No. 5, but the amount remained unpaid.

Despite repeated correspondence seeking payment, the authorities neither released the amount nor raised any objection to the petitioner’s entitlement.

The petitioner therefore approached the High Court under Article 226 of the Constitution seeking payment with interest. The respondents contended that the petitioner should pursue an alternative remedy, since the claim arose out of a contract.

Whether a writ petition under Article 226 is maintainable for recovery of contractual dues where the claimant’s entitlement is undisputed and no complex question of fact arises.

Whether the respondent-authorities could withhold the petitioner’s admitted dues for an extended period without raising any objection or providing justification.

Whether the petitioner was entitled to interest on the unpaid contractual amount.

The Court applied the principle that although a writ petition ordinarily will not be entertained merely to enforce a contractual money claim, Article 226 jurisdiction may be exercised where the entitlement is undisputed, no disputed questions of fact or complex evidentiary issues arise, and the State or its instrumentality has acted arbitrarily in withholding payment.

Relying on Suganmal v. State of M.P., AIR 1965 SC 1740, and the principles restated in Godavari Sugar Mills Ltd. v. State of Maharashtra, (2011) 2 SCC 439, the Court held that the power to order payment in a writ proceeding exists and may be exercised where public-law elements or infringement of statutory or legal rights are involved.

Under Surya Constructions v. State of U.P., (2019) 16 SCC 794, read with ABL International Ltd. v. Export Credit Guarantee Corpn. of India Ltd., (2004) 3 SCC 553, arbitrary State action in the contractual sphere is amenable to judicial review under Article 226 where the amount payable is wholly undisputed.

The Court found that the petitioner had completed the contracted work and that the bill for ₹16,60,809/- had been submitted.

The respondents did not dispute either the petitioner’s entitlement or the amount payable, and no document suggested the existence of a complex factual or contractual controversy.

Accordingly, the ordinary rule requiring the claimant to pursue a civil suit or other remedy did not apply.

The prolonged and unexplained withholding of the admitted dues by public authorities was considered arbitrary and inconsistent with their public-law obligations.

Since the claim was undisputed and the respondents had failed to justify non-payment despite repeated demands, the Court exercised its Article 226 jurisdiction and also awarded interest for the period of unjustified withholding.

The Court held that the respondents could not withhold the petitioner’s undisputed contractual dues without justification.

Opposite Parties 2–5 were directed, jointly or separately, to pay ₹16,60,809/- to the petitioner within four weeks of communication of the judgment, together with interest at 6% per annum, calculated from the expiry of one month from the date of submission of the bills until actual payment.