Courts must defer to the tendering authority’s reasonable interpretation of qualification criteria absent patent absurdity.

Chennai Metro Rail Limited invited bids for the Automatic Fare Collection System under its Phase II project. EXEO Global Pte. Ltd. submitted a bid, but on 10 July 2026 CMRL declared it non-responsive without stating reasons in the online endorsement.

CMRL subsequently identified three grounds: the petitioner had not demonstrated the required turnover through its own financial statements; it relied on experience attributed to an affiliated entity; and it did not meet the bidder-level experience requirements.

During the writ proceedings, CMRL supplied detailed reasons, considered the petitioner’s written response and heard it, but maintained the disqualification.

The petitioner sought to quash the decision and have its technical bid reconsidered and price bid opened.

1. Whether CMRL’s finding that the petitioner had not established the required annual turnover from its own financial documents was so arbitrary or unreasonable as to warrant interference under Article 226.

2. Whether CMRL was entitled to find that the petitioner did not satisfy the experience criteria by relying on the tender’s requirements for the bidder or single entity, notwithstanding the petitioner’s proposed specialised subcontractor.

Under Article 226, a court should give primacy to the tendering authority’s interpretation of its own qualification requirements and should not substitute its view for that of the authority; interference is justified where the conclusion is absurd or rests on a minor technical defect that does not substantially affect qualification.

The tender’s EQC Clause 2(I) requires the legal entity or entities comprising the bidder—not its parent, group companies, subsidiaries or other affiliates—to satisfy the qualification criteria.

EQC Clause 2.3.2 required the single entity to establish the specified average annual turnover, while the experience criteria and ITB Clauses 30.1 and 30.2 left the employer to determine qualification by examining the documentary evidence submitted.

The Court applied these principles consistently with the tender-law authorities cited by the parties and the principles it distilled from them.

The petitioner relied on consolidated financial statements and published material to attribute overseas revenue to itself, but the documents did not clearly distinguish its turnover from that of its parent and other group companies.

The Court found the respondents’ assessment—that the submitted documents did not establish the petitioner’s own turnover—was not patently absurd or a mere excuse, and declined to re-evaluate the evidence in place of the tender experts.

As to experience, although the tender could permit consideration of a subcontractor’s experience in some circumstances, the relevant qualification entries required the single entity to meet the criteria.

Whether the petitioner could rely on a proposed subcontractor before that subcontractor was identified or accepted by the employer was, at minimum, open to more than one view; the employer’s interpretation therefore received primacy.

No costs were awarded, and the connected miscellaneous petition was closed.