Facts
The petitioner, a registered society providing skill-based training, was authorized by the State to train candidates under the Mukhyamantri Koushal Vikas Yojna.
Source reference: para. 2The list of trainees was supplied to the petitioner via the Chhattisgarh State Skill Development Authority (CSSDA) portal.
Source reference: para. 3In 2021—five years after the training was completed—Respondent No. 2 issued an order (Annexure-P/1) alleging that 14 beneficiaries were ineligible (10 underage, 5 overage, and 1 duplicate entry) and directed the petitioner to refund ₹2,40,000/-.
Source reference: para. 1-2The petitioner challenged this order, contending they had no authority to select or reject candidates provided by the State portal.
Source reference: para. 3Issues
1. Whether the petitioner can be held liable for the training costs of ineligible candidates when the list of trainees was provided and authorized by the State’s own portal?
Source reference: para. 6-72. Whether the impugned order directing a refund is sustainable in law given the admission of clerical error by the respondent authority?
Source reference: para. 6-8Law Applied
The court applied principles of administrative law and natural justice under Article 226 of the Constitution of India.
Source reference: no citationThe core principle established is that an agency cannot be penalized for executing a contract based on data provided by the principal (the State) when the principal admits that the inclusion of ineligible beneficiaries was a result of its own "clerical mistake".
Source reference: para. 6Liability cannot be fastened upon a service provider for an error committed by the state officials responsible for candidate selection.
Source reference: para. 7Reasoning
The Court observed that the respondents failed to produce any document proving that the petitioner had the authority to select or reject candidates or that specific age-based instructions were violated in the work order.
Source reference: para. 6Crucially, the Court highlighted that the Respondent No. 2 admitted in the impugned order that the selection of ineligible beneficiaries occurred due to a "clerical mistake of the office".
Source reference: para. 6The Court reasoned that since the petitioner was duty-bound to train the persons listed on the CSSDA portal, they could not be held responsible for the State's administrative failures.
Source reference: para. 6The Court found it legally incongruous that the State sought to penalize the petitioner instead of taking action against the "erring officials" responsible for the selection error.
Source reference: para. 7Holding
The Court answered the issues in the negative, holding that the liability for training ineligible candidates cannot be fastened upon the petitioner.
The High Court quashed the impugned order dated 30.07.2021 (Annexure-P/1) as unsustainable in law.
Source reference: para. 8The writ petition was allowed in full.
Source reference: para. 9Original Court PDF
SAMVEDNA SEVA VIKAS SAMITI, AMBIKAPURvsTHE STATE OF CHHATTISGARH
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