Selection in a dealership draw creates no vested right until eligibility conditions are satisfied.

Indian Oil Corporation Limited (IOCL) advertised a retail outlet dealership under the OBC category at a specified location in Saran. The petitioner applied, was successful in the draw of lots, deposited the initial security amount and submitted documents.

IOCL later sought a certified family tree and prescribed consent documents concerning the offered land. By communication dated 10 April 2023, it found the petitioner ineligible for Group 1 and stated that he could be considered in Group 3.

The petitioner challenged that decision, asserting that he had submitted the required documents and that the co-sharers had consented to use of the land.

IOCL maintained that the landowner was not an eligible family member, required documents had not been furnished in time, and the petitioner’s share fell short of the minimum area.

1. Whether IOCL acted unlawfully or arbitrarily in finding the petitioner ineligible for Group 1 and relegating his candidature to Group 3 because he did not meet the land-related documentary and eligibility requirements.

2. Whether success in the draw of lots conferred on the petitioner a vested right to the dealership before verification of his eligibility.

The Selection Brochure governed eligibility, including the land and supporting-document requirements for Group 1; applicants must satisfy those prescribed conditions, and selection in a draw remains subject to eligibility verification.

The Court relied on the principle that a public-sector corporation, as a State instrumentality under Article 12, must act fairly and adhere uniformly to the standards in its advertisement and selection terms. It referred to M/s Indian Oil Corporation Limited v. Raj Kumar Jha & Ors., 2012 (2) PLJR 783, which emphasised strict adherence to advertised standards.

The respondents also cited Mukesh Pandey v. Hindustan Petroleum Corporation & Ors., LPA No. 925 of 2012.

The Court found that the petitioner had not furnished the complete required documents within the stipulated time: the family tree was submitted later, and the required consent from the concerned landowner was not provided.

The record also did not establish that the offered land qualified as eligible family-owned land for Group 1.

Applying the Selection Brochure and the requirement of consistent adherence to its terms, the Court held that IOCL’s decision to deny Group 1 status and relegate the candidature to Group 3 was not contrary to the prescribed requirements. The draw-of-lots result did not cure the failure to meet eligibility conditions or create a vested right to the dealership.

The writ petition was dismissed, and any pending interlocutory applications were disposed of.