Patna High Court
Administrative and Public LawCivil Procedure and Evidence

Writ interference with LPG distributorship selection requires established violation of applicable eligibility guidelines.

Rubee Devi vs The Indian Oil Corporation Ltd. and Ors

Patna High CourtJUDGMENT: September 08, 20263 MIN READSOURCE JUDGMENT
Writ interference with LPG distributorship selection requires established violation of applicable eligibility guidelines.. Rubee Devi vs The Indian Oil Corporation Ltd. and Ors. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Indian Oil Corporation Ltd. issued an advertisement dated 18 June 2017 for an LPG distributorship at Phuchti Kala, Ekma, District Saran, reserved for Scheduled Caste women.

Source reference: paras. 1–2; pp. 1–3

Rubee Devi applied and participated in the selection process, in which Nitu Devi was declared successful in a draw of lots held on 12 February 2018.

Source reference: paras. 1–2; pp. 1–3

The petitioner challenged the selection principally on the ground that the land offered by Nitu Devi for construction of the LPG godown—Plot No. 2929, Khata No. 469, measuring 15.99 decimals—was allegedly not compliant with the applicable guidelines.

Source reference: paras. 3–5; pp. 2–3

The Corporation stated that the land had been validly leased through registered lease deed No. 3514 dated 22 July 2017 and was found compliant during field verification under the Unified Guidelines for Selection of LPG Distributors, June 2017.

Source reference: paras. 6–8; pp. 3–4

A Letter of Intent was issued to Nitu Devi on 13 June 2018, followed by execution of the distributorship agreement after fulfilment of the stipulated conditions.

Source reference: para. 9; p. 4

The distributorship was subsequently commissioned and was functioning when the writ petition was decided.

Source reference: para. 21; p. 9
02

Issues

Whether the selection of respondent No. 6 through the draw of lots and the subsequent Letter of Intent were illegal or arbitrary for non-compliance with the applicable LPG distributorship guidelines.

Source reference: paras. 18–19; pp. 7–8

Whether the land offered by respondent No. 6 for the LPG godown was disqualified because a canal allegedly passed through it.

Source reference: paras. 3–5, 8, 20; pp. 2–4, 8–9

Whether the High Court should interfere under its writ jurisdiction with the Corporation’s field-verification findings and completed distributorship in the absence of established illegality or arbitrariness.

Source reference: paras. 18, 21–22; pp. 7–9
03

Law Applied

The Court applied the Unified Guidelines for Selection of LPG Distributors, June 2017, and the conditions contained in the Corporation’s brochure governing eligibility, land availability, godown requirements, and field verification.

Source reference: paras. 6–9, 19; pp. 3–5, 8

The governing judicial-review principle was that writ jurisdiction is not invoked merely on the basis of an unsubstantiated allegation; interference with an administrative selection requires the petitioner to establish illegality, violation of the prescribed conditions, or arbitrariness.

Source reference: paras. 18, 21–22; pp. 7–9

The Court also treated the findings of the competent authority following field verification as sufficient where no contrary material conclusively demonstrated non-compliance.

Source reference: paras. 19–20; p. 8
04

Reasoning

The Court found that the selection was conducted through a draw of lots among 22 eligible applicants and that respondent No. 6’s documents and offered land were thereafter subjected to field verification under the applicable 2017 guidelines.

Source reference: paras. 6, 19; pp. 3, 8

The competent authority found the land compliant and issued the Letter of Intent.

Source reference: paras. 6, 19; pp. 3, 8

The petitioner’s principal objection—that a canal passed through Plot No. 2929—was not established.

Source reference: paras. 8, 15, 20; pp. 4, 6–9

The Corporation stated that the canal was situated approximately five metres from the plot’s western boundary, while documents produced by respondent No. 6 indicated that no part of the plot had been acquired for the canal.

Source reference: paras. 8, 15, 20; pp. 4, 6–9

In these circumstances, the Court held that the petitioner had not demonstrated that the plot was disqualified under the guidelines.

Source reference: paras. 19–20; p. 8

The subsequent commissioning and functioning of the distributorship also reinforced the absence of a basis for writ interference, particularly where only a bare allegation of irregularity had been made.

Source reference: para. 21; p. 9
05

Holding

The Court answered the issues against the petitioner.

It held that the selection of Nitu Devi, the Letter of Intent, and the consequential LPG distributorship were not shown to be illegal, arbitrary, or contrary to the applicable guidelines.

Source reference: paras. 18–22; pp. 7–9

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

Source reference: paras. 23–24; p. 9
Patna High Court

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Rubee DevivsThe Indian Oil Corporation Ltd. and Ors

Patna High Court · September 08, 2026

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