Delhi High Court orders transparent annual rules for Ramleela grounds, flags first-come-first-served allotments as unfair

The petitioner had organised the Ramleela Dussehra Mahotsav at Chunk-C Ground, Shivaji Place, Raja Garden, in 2023 and 2024. It applied on 26 May 2026 for allotment of the ground for the 2026 event.

After the Court directed the authorities to decide the application, the Board rejected it on 28 September 2026, reasoning that Respondent No. 6 had applied earlier and that allotment was governed by a first-come-first-served criterion.

The petitioner challenged that rejection, relying on the DDA SOP dated 1 September 2026, which provided a preference for societies that had booked the same site in two of the preceding three years.

The Court declined to disturb the existing allotment because the festivities were about to commence.

1. Whether the authorities could reject the petitioner’s application by applying a first-come-first-served criterion when no notice had specified the application window or that criterion.

2. Whether first-come-first-served was a constitutionally reasonable and suitable method for allocating competing applications for a public ground.

3. Whether the petitioner was entitled to cancellation of Respondent No. 6’s 2026 allotment and immediate allotment of the ground to the petitioner.

A criterion’s determinacy does not, by itself, establish its constitutional reasonableness or consistency with public policy; public allocation processes must provide clear, prospective rules and a fair basis for assessing competing claims.

The Court referred to Anant Raj Ltd. v. State of Haryana, (2022) 15 SCC 596, and Centre for Public Interest Litigation v. Union of India, (2012) 3 SCC 1, in discussing the risk that unequal access to administrative information may advantage some applicants in a first-come-first-served process.

The Court also considered the DDA SOP and HLCC guidelines, but held that the allocation framework must be made clear and comprehensive; prior experience may be relevant but should not confer an automatic right or create a de facto monopoly.

The Board had not published a notice identifying the application period or stating that applications would be decided on a first-come-first-served basis, undermining the transparency and equal footing required for a fair allocation process.

Even assuming that criterion applied, the Court found it inadequate: the earliest application does not necessarily represent the strongest claim, and reliance on application timing can reward applicants with earlier access to administrative information.

The record also showed applications submitted before the DDA SOP was issued, leaving unclear how the earlier applications related to the applicable guidelines.

As the 2026 festivities were imminent, however, cancellation and transfer of the existing allotment were not feasible.

The guidelines must include a published application process, common eligibility assessment, relevant operational and safety requirements, published comparative criteria where applicants compete, a limited role for continuity and experience, and a grievance-redressal mechanism.

No immediate relief was granted against the 2026 allotment, and the directions were expressly prospective, without retrospectively altering the 2026 policy or determining applicants’ rights under it.

The petition and pending applications were disposed of accordingly.