Patna HC Upholds 3-Year JEEViKA Blacklist Of Training Provider Over Repeated DDU-GKY Project Defaults

In brief

The question

1. Whether BRLPS gave the petitioner adequate notice of the proposed blacklisting and an opportunity to respond

The court held

The Court rejected the challenges based on inadequate notice and disproportionality, held that the petition lacked merit, and dismissed it.

It also directed

The termination and three-year blacklisting therefore remained undisturbed; any pending applications were also disposed of.

01Facts

The petitioner entered into an MoU with Bihar Rural Livelihoods Promotion Society (BRLPS) on 30 December 2017 to train and place 550 candidates under DDU-GKY.

¶ 2–3

BRLPS released the first instalment of ₹78,81,884, but alleged repeated defaults, including failures concerning training, compliance, and submission of project-closure documents.

¶ 2–3

On 26 May 2025, BRLPS notified the petitioner that blacklisting was among the actions that could be taken; the petitioner appeared before the CEO on 6 June 2025.

¶ 4–6

By order dated 31 December 2025, BRLPS terminated the project and blacklisted the petitioner for three years.

¶ 1, 7, 10

The petitioner sought to quash the order, arguing that it had not received an adequate show-cause notice and that the blacklisting was disproportionate.

¶ 1, 7, 10

02Issues

i.1. Whether BRLPS gave the petitioner adequate notice of the proposed blacklisting and an opportunity to respond

¶ 4–9

ii.2. Whether blacklisting the petitioner for three years was disproportionate and warranted interference under Article 226 of the Constitution

¶ 10–11

03Law Applied

The Court considered the principles of natural justice, the proportionality of blacklisting, and the scope of judicial review under Article 226.

¶ 8–11

It also referred to the MoU and the applicable DDU-GKY guidelines, SOPs, and notifications as the framework governing the petitioner’s obligations and the respondents’ action.

¶ 8–11

The judgment did not cite a specific statutory provision or precedent establishing a separate test for blacklisting.

¶ 8–11

04Reasoning

The Court held that the letter dated 26 May 2025 was not merely an invitation to attend a hearing: it expressly warned that blacklisting could be initiated under the MoU and applicable DDU-GKY instruments.

¶ 4–9

The petitioner appeared before the CEO, and the Court also noted the history of communications and notices concerning alleged defaults dating back to 2018.

¶ 4–9

It therefore rejected the contention that no show-cause notice had been issued.

¶ 4–9

Given the recorded history of non-performance and non-submission of closure documents, the Court found that a three-year blacklisting did not shock its conscience and declined to interfere under Article 226.

¶ 10–11