Retail dealership rejection upheld where offered land failed eligibility requirements under both Groups I and III.

The petitioner applied for retail outlet dealership at Rajapur on the Koilwar–Chhapra Road, Bhojpur, under the Open Category, Group-I.

He was initially placed at Serial No. 3 among the selected candidates and participated in the lottery process.

After being asked to submit documents relating, inter alia, to his date of birth, educational qualifications and land ownership, he submitted the relevant materials and deposited ₹50,000 with Indian Oil Corporation Ltd.

On 24 May 2019, IOCL rejected his candidature on the ground that the land documents were invalid for consideration under Group-I, while stating that his candidature could be considered with Group-III applicants.

During the proceedings, IOCL contended that the petitioner was subsequently given an opportunity to offer land under Group-III within 90 days, but failed to do so.

A further rejection order was thereafter passed under Group-III, which the petitioner did not challenge.

The petitioner therefore sought quashing of the rejection of his selection and consequential reliefs.

Whether IOCL’s rejection of the petitioner’s candidature under Group-I on the ground that the offered land documents were invalid was erroneous or liable to be quashed.

Whether the writ petition had become infructuous or otherwise unsustainable because the petitioner failed to offer land under Group-III and did not challenge the subsequent rejection order.

Whether the petitioner was entitled to consequential relief, including continuation of his dealership selection or refund of the deposited amount.

The Court applied the governing IOCL dealership guidelines concerning eligibility and classification of applicants into Group-I and Group-III, particularly the requirement that the land offered by an applicant must satisfy the applicable category conditions.

The Court also applied the procedural principle that a subsequent adverse order affecting the same subject matter must be challenged if the petitioner seeks substantive relief against it; an unchallenged subsequent rejection cannot ordinarily be bypassed in writ proceedings.

No statute or judicial precedent was expressly relied upon in the judgment.

The Court found that the petitioner’s land documents were not valid for consideration under Group-I, which justified IOCL’s initial rejection and its direction that the petitioner could instead be considered under Group-III.

The petitioner was subsequently afforded an opportunity to offer land under Group-III but failed to do so.

Since a further rejection order was passed under Group-III and was not challenged, the Court held that the petitioner could not obtain dealership-related relief merely by challenging the earlier Group-I rejection.

The Court further concluded that the offered land did not satisfy the requirements of either Group-I or Group-III and that there was no error or irregularity in IOCL’s decision.

No relief was granted regarding the dealership selection.

However, the Court directed that, if the petitioner wished to recover the ₹50,000 deposited with IOCL, he could furnish his bank-account details to the concerned authority for refund.