Facts
The petitioners, transporters engaged in LPG carriage, were awarded work orders by Indian Oil Corporation Limited (IOCL) on 25 April 2024 for a period of five years, subject to supplying Tata-make trucks conforming to the tender requirements.
Source reference: p.9, para. 7Following complaints, IOCL issued show-cause notices dated 11 November 2025 alleging that certain trucks supplied by the petitioners were supported by forged or false documents and that their details were not available in Tata Motors’ internal records.
Source reference: p.9, para. 7The allegations concerned 14 vehicles in WP(C) No. 1549/2026, 18 vehicles in WP(C) No. 1572/2026, 16 vehicles in WP(C) No. 1627/2026, and two vehicles in WP(C) No. 1460/2026.
Source reference: pp.8–9, paras. 3–6In an earlier proceeding, the High Court permitted the petitioners to submit replies and directed IOCL to provide an opportunity of hearing before deciding the show-cause proceedings.
Source reference: p.10, para. 7The petitioners contended that they had purchased second-hand vehicles after verifying the VAHAN, DigiLocker and mParivahan records, which identified the vehicles as Tata vehicles.
Source reference: p.10, para. 8Despite this, IOCL passed orders dated 2 March 2026 placing the petitioners on its holiday list, relying principally on the absence of corresponding records with Tata Motors and alleged chassis-number mismatches.
Source reference: p.8, para. 1; pp.13–14, paras. 14 and 18Issues
Whether IOCL was justified in placing the petitioners on its holiday list on allegations of forgery and furnishing false information merely because the vehicles’ particulars were unavailable in Tata Motors’ internal records, despite the official registration and electronic records identifying the vehicles as Tata vehicles?
Source reference: pp.13–14, paras. 16–18Whether the impugned orders dated 2 March 2026 were sustainable when the petitioners had relied on documents and information available through VAHAN, DigiLocker and mParivahan, and when the Transport Department’s records apparently supported the petitioners’ case?
Source reference: pp.10–12, paras. 8, 10–12; pp.13–14, para. 17Whether the petitioners should instead be permitted to replace the vehicles giving rise to doubts, subject to verification by IOCL, so that LPG carriage could continue under the original work orders?
Source reference: p.14, para. 18; p.15, paras. 19–20Law Applied
The Court applied the tender conditions, including Clause 7.2.2.10 of the Transport Discipline Guidelines and Clause 82(f) of the tender document, concerning compliance with vehicle and documentary requirements.
Source reference: p.12, para. 12It also relied on the Ministry of Road Transport and Highways’ communications dated 8 August 2018 and 17 December 2018, under which electronic vehicle records available on DigiLocker or mParivahan are legally recognised at par with original documents and may be produced through those applications.
Source reference: pp.11–12, para. 10The Court further applied the principles of fairness, proportionality and reasonableness in administrative action: while IOCL could verify the conformity, safety and fitness of LPG-carriage vehicles in the public interest, a severe penal consequence such as holiday-listing could not be imposed on the basis of an unsubstantiated allegation of forgery when the petitioners’ official documents appeared to be in order.
Source reference: pp.13–14, paras. 17–18Reasoning
The Court accepted that IOCL was entitled, and indeed obliged, to ensure that vehicles used for LPG transportation satisfied the prescribed make, safety and fitness requirements.
Source reference: p.14, para. 18However, the material relied upon by the petitioners—registration certificates and electronic records from VAHAN, DigiLocker and mParivahan—identified the vehicles as Tata vehicles and had been obtained through officially recognised systems.
Source reference: pp.10–12, paras. 8 and 10–11The Transport Department also indicated that the registration certificates conformed to the petitioners’ assertion.
Source reference: p.13, para. 15In these circumstances, the mere fact that Tata Motors could not locate corresponding entries in its internal records did not establish that the petitioners had forged documents or intentionally furnished false information, particularly where the petitioners claimed to have purchased the second-hand vehicles bona fide after due diligence.
Source reference: pp.12–14, paras. 12 and 17Although IOCL referred to chassis-number mismatches, the Court noted that the verification exercise had not been uniformly conducted for all vehicles.
Source reference: p.14, para. 18The Court therefore found the allegation of forgery and the resulting holiday-listing action unjustified and disproportionate, while preserving IOCL’s power to require replacement and verify compliant vehicles.
Source reference: pp.14–15, paras. 18–20Holding
The High Court held that the impugned IOCL orders dated 2 March 2026 placing the petitioners on the holiday list were legally unsustainable and set them aside.
The petitioners were directed to replace the vehicles in question with proper vehicles conforming to the tender requirements.
Source reference: p.15, paras. 19–20IOCL was directed to verify and induct the replacement vehicles and permit the petitioners to continue LPG carriage under the original work orders dated 25 April 2024.
Source reference: p.15, paras. 19–20The replacement vehicles were to be supplied expeditiously, and IOCL was directed to complete verification within one week of their supply.
Source reference: p.15, para. 20All four writ petitions were accordingly allowed, with no order as to costs.
Source reference: p.15, paras. 21–22Original Court PDF
Raja Ram MalakarvsIndian Oil Corporation Limted And Ors
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