Withheld transporter payments require a reasoned decision, with refund upon proof of complete delivery.

The petitioner, a transporter engaged by the Madhya Pradesh State Civil Supply Corporation under the wheat procurement scheme for 2021–22, was entrusted with transporting 14 bundles of tare purchased by the Corporation from Sewa Sahakari Sansthan, Sahdora (Kakda), under Challan No. 598 dated 10 May 2021.

The petitioner transported and supplied the bundles to Manas Swa Sahayata Samooh. A dispute subsequently arose because the Corporation alleged that only four bundles had been received back and that ten bundles remained unreturned by the Samooh.

After issuing notice to the petitioner and receiving its reply, the Corporation conducted an enquiry. By letter dated 25 July 2022, the Corporation recorded that the Samooh’s portal reflected receipt of all 14 bundles supplied by the petitioner.

Thereafter, by letter dated 20 March 2024, the District Manager requested the Chief Executive Officer, District Panchayat, Ashok Nagar, to recover ₹4,82,380 or the remaining bundles from the Samooh.

The petitioner’s representations dated 14 November 2022 and 11 October 2023 seeking release of its transportation dues remained undecided, leading to the writ petition.

Whether the respondent-Corporation could continue withholding the petitioner’s transportation dues when its own correspondence indicated that the petitioner had supplied all 14 bundles and that the dispute concerned non-return by the recipient Samooh.

Whether the respondent-Corporation was required to decide the petitioner’s representations by passing a reasoned order and determining whether the amount of ₹4,82,380 was payable.

The Court applied the principles governing judicial review under writ jurisdiction, particularly the duty of a public authority to consider and decide a pending representation fairly, rationally, and by assigning reasons.

An administrative authority must give due consideration to relevant records and cannot indefinitely withhold a person’s dues without explaining the basis for such withholding.

Where the authority’s own records indicate that the petitioner may have performed its contractual obligation, the authority must undertake a reasoned determination and release the amount if the entitlement is conclusively established.

The Court found that the letter dated 25 July 2022 specifically related to the 14 bundles entrusted to the petitioner and referred to Monu Transport, thereby supporting the petitioner’s case that the entire consignment had been supplied.

The subsequent letter dated 20 March 2024 showed that the Corporation itself treated the non-return of ten bundles as a dispute with the concerned Samooh and sought recovery from that Samooh, rather than establishing any default by the petitioner.

In these circumstances, the Corporation could not remain silent on the petitioner’s representations while pursuing recovery against the recipient society.

However, because the Corporation disputed whether the goods reflected on the Samooh’s portal were necessarily those supplied by the petitioner, the Court declined to issue an immediate positive direction for payment.

Instead, it required the Corporation to make a reasoned determination based on the relevant correspondence.

The authorities were directed to refund the amount if it was conclusively found that the petitioner had delivered the goods to the Samooh.

If the amount was not refunded, the authorities were required to explain the reasons for withholding it.

The Court therefore granted limited relief in the form of a reasoned decision on the representations, without directly ordering payment of ₹4,82,380.