Registered business office requirements in tenders must be bona fide and not created solely to qualify for technical eligibility.

The Petitioner, a firm providing golf carts on rent throughout India, challenged a communication dated 11.06.2026 which rejected its bid for a tender issued by the Respondent (ITPO) on 15.05.2026.

The tender sought to empanel an agency for providing low-floor battery-operated golf carts at Bharat Mandapam.

Clause 11(i) of the tender mandated that the bidder’s registered business office must be located in Delhi/New Delhi, failing which the bid would be summarily rejected.

The Petitioner’s bid was rejected for not fulfilling this technical eligibility criteria.

The Petitioner relied on a GST registration dated 27.05.2026 for an address at Kasturba Gandhi Marg, New Delhi, and other documents showing an address in Chattarpur, Delhi.

The Respondent argued that the Petitioner's MSME registration showed its location in Meerut, U.P., and the Delhi GST certificate was obtained only one day prior to bid submission.

1. Whether the Respondent’s rejection of the Petitioner’s bid for failing to meet the "local office" eligibility criteria was arbitrary or in violation of the principles of fair procurement under Article 14 of the Constitution.

2. Whether the documents provided by the Petitioner (GST certificate and lease agreements) sufficiently established a "registered business office" in Delhi as per Clause 11(i).

Clause 11(i) of the Tender conditions, which requires a registered business office in Delhi/New Delhi for technical eligibility.

Standards of judicial review in contractual/tender matters under Article 14 of the Constitution, mentioning precedents such as Tata Cellular v. Union of India and Ramana Dayaram Shetty v. International Airport Authority of India which emphasize fairness and transparency.

Rules 144 and 173 of the General Financial Rules, 2017, regarding transparent procurement procedures.

The Court found that the Petitioner failed to demonstrate a bona fide registered business office in Delhi.

It noted that the GST certificate for the New Delhi address was issued on 27.05.2026, a single day before the bid was submitted, suggesting it was obtained solely to qualify for the tender.

The Court accepted the Respondent’s justification for Clause 11(i)—that the nature of the service (golf carts) requires a local presence to ensure immediate replacement in case of mechanical breakdown.

Regarding the Chattarpur address, the Court observed that the Petitioner lacked a GST registration for that location and characterized it as a mere warehouse rather than a "registered business office".

The Court concluded that the Petitioner’s primary location remained Meerut, and the attempts to show a Delhi office were superficial and intended only to circumvent eligibility requirements.

The Court answered that the Petitioner did not meet the technical eligibility criteria as it lacked a genuine registered office in Delhi at the time of the tender.

The Writ Petition and all pending applications were dismissed.