Automated bidding extensions in e-auctions are valid if system-driven and uniformly applied to all participants.

The Petitioner challenged the e-auction settlement of two sand ghats (Group No. 4) in Muzaffarpur.

The auction, originally scheduled for 26.12.2022 from 11:00 A.M. to 01:00 P.M., commenced at 11:05 A.M. due to technical issues.

Under Clause 12 of the tender, a bid within the final five minutes triggers a one-hour extension.

Respondent No. 7 placed a bid at 01:00:30 P.M. (within the final five minutes of the revised 01:05 P.M. deadline), causing the system to automatically extend the window to 02:05 P.M.

Respondent No. 7 then placed the highest bid of Rs. 1,56,27,150/- at 02:00:30 P.M.

The Petitioner, whose final bid was at 01:47:56 P.M., alleged the auction closed at 02:00 P.M. and the Respondent’s bid was invalidly accepted after expiry.

1. Whether the bid submitted by Respondent No. 7 at 02:00:30 P.M. was within the permissible time-frame according to Clause 12 of the e-auction notice and the actual commencement time of the auction.

2. Whether the actions of the respondent authorities in declaring Respondent No. 7 as the successful bidder were arbitrary, biased, or violative of the principles of natural justice.

Principles of fairness, transparency, and non-arbitrariness in government contracts as established in Monarch Infrastructure (P) Ltd. v. Ulhasnagar Municipal Corporation, emphasizing that all participants must be treated alike.

Restrictive judicial review in contractual/technical matters unless there is manifest arbitrariness or mala fides as per Silppi Constructions Contractors v. Union of India.

Doctrine from University of Mysore v. C.D. Govinda Rao, holding that courts should be slow to interfere with the findings of expert/technical committees in the absence of mala fides.

The Court examined the Scrutiny Committee report and the "Auction Synopsis Report," which confirmed that the auction's start time was shifted to 11:05 A.M. due to technical reasons.

Because the closing window shifted to 01:05 P.M., the bid at 01:00:30 P.M. was validly within the "last five minutes" specified in Clause 12.

The resulting one-hour extension to 02:05 P.M. was system-generated and automatic, precluding any manual intervention or favoritism.

The Court reasoned that since the extension applied uniformly to all qualified bidders, there was no discrimination.

The Petitioner failed to refute the authenticity of the system logs or prove any breach of the tender conditions.

The writ petition was dismissed, and the settlement in favor of Respondent No. 7 was upheld.