Rejection of Bid Due to Non-Compliance with Prescribed Integrity Pact Format Held Not Arbitrary

The Petitioner challenged the rejection of its technical bid regarding a tender (NIT No. 1910) for the construction of a District Panchayat Building.

The Respondent No. 3 rejected the Petitioner's bid on January 21, 2026, because the Pre-Contract Integrity Pact (Annexure-J) submitted by the Petitioner failed to mention the "name of work," was not downloaded from the official portal, and lacked the required footer.

Consequently, Respondent No. 4 was declared the sole successful bidder and was issued a Work Order on February 2, 2026.

The Petitioner contended these defects were hyper-technical and indicated that accepting a sole bidder in a first call violated state guidelines.

1. Whether the rejection of the Petitioner’s technical bid on the grounds of non-compliance with the prescribed format of the Integrity Pact was arbitrary or irrational.

2. Whether the award of the contract to a single technically qualified bidder after the first call of the tender was legally permissible under the prevailing government guidelines.

The Court applied the principles of judicial review under Article 226 of the Constitution of India, noting that the scope is limited to examining whether an administrative process is arbitrary, mala fide, or discriminatory.

It held that the terms of a Notice Inviting Tender (NIT) are binding on all bidders and the authority can insist on strict compliance to maintain transparency.

Furthermore, the Court relied on the Government of Chhattisgarh Order dated November 27, 2014, which stipulates that if multiple bids are received but only one is found technically qualified, it shall not be treated as a "single tender".

The Court found that the Petitioner admittedly failed to upload the Integrity Pact in the specific format provided in the tender portal, omitting the name of the work and the document footer.

It reasoned that since the tender conditions explicitly required bidders to use the prescribed format from the portal, the Respondent’s decision to reject the bid for these omissions was a legitimate exercise of administrative discretion and not arbitrary.

Regarding the competitive process, the Court observed that because two bidders had initially participated, the qualification of only one (Respondent No. 4) did not trigger the "single tender" prohibition under the 2014 Government Order.

The Court concluded that the financial bid of the sole qualified bidder could be legally opened and accepted under such circumstances.

The Court ruled that the Petitioner failed to comply with the mandatory tender conditions and that the state guidelines permitted the award of the contract to the remaining technically qualified bidder.

No order as to costs was made.