Authorities cannot retrospectively reduce District Jail Purchase Committee rates after supplies are made.

The petitioners challenged the District Magistrate’s decision dated 29 September 2015, which reduced the rates for commodities they had supplied to Bettiah Jail, despite the rates having been approved by the District Purchase Committee.

They sought payment at the Committee-approved rates, less amounts already paid.

The petitioners relied on Tanuja Kumari v. State of Bihar & Ors., CWJC No. 66 of 2013, which addressed interference with rates approved by District Jail Purchase Committees.

1. Whether the petitioners were entitled to payment at the rates approved by the District Purchase Committee, notwithstanding the subsequent reduction.

2. Whether the Inspector General of Prisons should be directed to release funds for the balance payment.

The Court applied the Bihar Jail Manual, including Rule 1051(v), concerning the procedure for approval and recommendation of rates by a District Jail Purchase Committee, and Rule 24(6), concerning the Inspector General’s authority to sanction a higher rate than that recommended by the Central Purchase Committee.

Following Tanuja Kumari, the Court treated the District Jail Purchase Committee’s approved rates as not liable to be unilaterally reduced after supplies had been made pursuant to that approval; it also relied on legitimate expectation and promissory estoppel.

The Court considered the case covered by Tanuja Kumari, which held that, once supplies had been made at rates approved by the District Jail Purchase Committee, those rates could not be reversed to the supplier’s prejudice during the contract.

Applying that precedent, the Court held that the petitioners were entitled to the benefit of the District Purchase Committee’s rates, with credit for payments already received.

The Inspector General of Prisons, Bihar, was directed to release the funds, and the process was to be completed within three months from receipt or production of a copy of the order.