Strict Adherence to Eligibility Criteria in Public Advertisements Precludes Relaxation for Discrepancies in Title Documents

The petitioner applied for an LPG distributorship in Alampur following a 2017 advertisement by the Indian Oil Corporation (IOCL)

Though initially successful in the draw of lots, a Field Verification of Credentials (FVC) revealed that the petitioner’s lease deed for the showroom was executed after the application deadline

IOCL permitted the petitioner to offer alternate land. However, discrepancies arose regarding the ownership of the new land; the revenue records and Land Possession Certificate listed "Ranglal Dusadh" or "Ranglal and Suresh," while the petitioner’s personal documents identified his father as "Ram Lal Ram"

Despite clarifications from the Circle Officer stating the variations were clerical, IOCL found the evidence insufficient to establish the identity of the landowner

IOCL cancelled the petitioner’s selection on November 23, 2018, and forfeited his deposit

Subsequently, respondent No. 6 was selected and commissioned as the distributor

1. Whether the alternate land offered by the petitioner fulfilled the eligibility criteria prescribed under the Unified Guidelines for Selection of LPG Distributors and the terms of the advertisement

2. Whether the Court can interfere with the Corporation's decision-making process regarding the verification of eligibility under Article 226 of the Constitution

The court primarily applied the Unified Guidelines for Selection of LPG Distributors, 2017, specifically regarding eligibility and the forfeiture of security deposits under Clause 26(b)

It relied on the precedent set in M/s Indian Oil Corporation Limited Vs. Raj Kumar Jha ors (2012), which established that the Corporation, as a 'State' under Article 12, must adhere strictly to the standards set in an advertisement to maintain objectivity and prevent discrimination

The court also applied the principle that judicial review under Article 226 is limited to the legality of the decision-making process, not the merits of the decision itself

The court found that the petitioner’s initial selection was conditional upon successful field verification and did not create a vested right

Applying the rule of strict adherence to advertisement terms, the court noted that IOCL acted fairly by providing the petitioner an opportunity to submit alternate land

However, the petitioner failed to provide definitive documentary evidence to resolve the inconsistencies between his father's name and the names listed in the revenue records

The court reasoned that IOCL was justified in holding a "hyper-technical" yet uniform standard to avoid the appearance of subjective bias or mischief

Since IOCL followed the prescribed guidelines and afforded the petitioner a chance to be heard, there was no procedural impropriety in the decision-making process

The court held that there was no arbitrariness in IOCL’s decision to cancel the selection and forfeit the deposit. Furthermore, the court noted that third-party rights had already accrued as respondent No. 6 had been commissioned

The writ petition was dismissed