Successful draw-of-lots candidates acquire no enforceable right absent fulfilment of advertised eligibility conditions.

Indian Oil Corporation Limited issued an advertisement dated 17 June 2017 inviting applications for LPG distributorships, including at Bounsi, District Banka. A subsequent corrigendum stated that the location “Bounsi” would also include Village Panchayats Daliya and Kaswa Mandar.

The petitioner, a resident of Village Panchayat Kaswa Mandar, applied under the open (women) category and offered family-owned land at Kaswa Mandar for the showroom and godown.

She was declared eligible, succeeded in the draw of lots held on 27 December 2017, deposited the requisite fee, and underwent Field Verification of Credentials on 28 February 2018.

By order dated 3 October 2018, the Corporation rejected her candidature on the ground that the offered land was outside the advertised location and that she did not possess eligible land at Bounsi.

The petitioner challenged the rejection, contending that Kaswa Mandar had been included within the advertised location. The Corporation maintained that the corrigendum referred only to the revenue village of Bounsi situated within Gram Panchayat Kaswa Mandar, and not to the entire Gram Panchayat; it also relied on the petitioner’s alleged admission that she had no land within Bounsi.

1. Whether the Corporation lawfully rejected the petitioner’s candidature on the ground that the land offered at Mouza Kaswa Mandar did not fall within the advertised location of Bounsi.

2. Whether the petitioner acquired an enforceable right to LPG distributorship merely by being declared successful in the draw of lots, despite the selection being subject to Field Verification of Credentials and fulfilment of the prescribed eligibility conditions.

3. Whether the impugned rejection order was arbitrary, illegal, or contrary to the advertisement, corrigendum, and applicable selection guidelines.

The Court applied the principle that Indian Oil Corporation, being “State” within the meaning of Article 12 of the Constitution, must act fairly, reasonably, objectively, and uniformly.

Once eligibility standards are prescribed in an advertisement, the Corporation must adhere to them strictly and cannot selectively relax or alter them.

The Court relied on M/s Indian Oil Corporation Limited v. Raj Kumar Jha , 2012 (2) PLJR 783, which held that strict adherence to advertised standards is necessary to prevent arbitrariness, discrimination, or misrepresentation.

The Court also relied on the applicable Unified Guidelines for Selection of LPG Distributorship, under which success in the draw of lots remains conditional upon fulfilment of eligibility requirements and successful Field Verification of Credentials.

The decision in Mukesh Pandey v. Hindustan Petroleum Corporation , LPA No. 925 of 2012, was also cited by the respondents.

The Court held that the draw of lots did not confer an unconditional or vested right upon the petitioner because her selection remained subject to FVC and compliance with the advertisement and Unified Guidelines.

During verification, the Corporation found that the offered land at Mouza Kaswa Mandar was not within the advertised location of Bounsi.

The respondents’ case was that Gram Panchayat Kaswa Mandar contained three distinct villages—Bounsi, Kaswa Mandar, and Naththan—and that the advertisement covered the revenue village Bounsi rather than the entire Gram Panchayat.

The Court accepted the Corporation’s assessment that the petitioner had failed to satisfy the land-location requirement and further noted her letter dated 28 February 2018, said to record that she did not possess land within Bounsi.

Applying the rule of strict adherence to advertised eligibility standards, the Court concluded that the Corporation was entitled to reject the candidature after FVC, notwithstanding the petitioner’s prior success in the draw.

The Court found no arbitrariness, illegality, or infirmity in the rejection order.

It held that the offered land did not satisfy the advertised-location requirement, that success in the draw of lots created no enforceable right independent of FVC and the eligibility conditions, and that the rejection order dated 3 October 2018 was lawful and consistent with the advertisement and selection guidelines.

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