Non-submission of online bid due to unsubstantiated technical glitches does not warrant judicial interference in automated tenders.

The Petitioner sought a writ of mandamus to validate its bid for a Coal Bed Methane (CBM) block in West Bengal under the Special CBM Bid Round-2025

The Notice Inviting Offers (NIO) mandated a dual submission process: online submission through a dedicated e-portal and physical submission of hard copies

While four other entities successfully submitted complete bids, the Petitioner’s status reflected as "not submitted"

The Petitioner alleged that a technical malfunction regarding net-worth validation on the portal prevented its final financial bid submission just before the 12:00 hrs deadline on 05.03.2026

An Audit Trail Report provided by the portal operator showed the Petitioner engaged in fragmented, repetitive activities and failed to complete mandatory steps such as verifying passwords and saving envelopes, while other bidders successfully uploaded bids during the same timeframe

1. Whether the Petitioner was deprived of the opportunity to submit its financial bid due to a technical malfunction in the bidding portal

2. Whether the Petitioner’s physical submission of documents satisfied the mandatory bidding requirements of the NIO despite the lack of an online financial bid

The court applied Article 226 of the Constitution of India regarding the limited scope of judicial review in contractual and tender matters, emphasizing restraint in interfering with the decision-making process unless the action is arbitrary or mala fide

The court relied on the principle that online submission is a sine qua non (essential condition) when specifically mandated by tender terms (NIO Clauses 1(iv) and 4(i))

The court distinguished Cineom Broadcast India Ltd. v. Municipal Corporation of Gr. Mumbai, noting that without a curative clause in the NIO, a late or incomplete bid cannot be excused

It also applied the evidentiary principle that a party’s inconsistent stands (pleading "forcible logout" only in a rejoinder) undermines the credibility of factual allegations

The court analyzed the Audit Trail Report, which provided a minute-by-minute log of all bidders' activities. It observed that while other bidders (e.g., Invenire Petrodyne) successfully submitted bids at the same timestamp (11:47:10 hrs), the Petitioner wasted significant time on repetitive document uploads and initiated its process only on the final day, demonstrating a lack of due diligence

The court found that the Petitioner failed to complete the sequence of "password verification" and "envelope saving" required after the price bid data was saved

The court rejected the Petitioner’s claim of a "net-worth error" because the system allowed other bidders with similar financial structures to proceed using "Not Applicable" declarations, which the Petitioner failed to use

The court determined that resolving the "technical glitch" claim would require a fact-intensive inquiry into server logs and algorithms, which is outside the remit of a writ court, especially when the contemporaneous record suggests user-side delay rather than system-wide failure

It held that the Petitioner failed to prove any systematic malfunction or technical glitch that prevented its submission; rather, the delay was attributable to the Petitioner's own lack of diligence

The court concluded that online submission was a condition precedent under the NIO, and physical submission alone could not render a bid valid

All pending applications were closed