Chhattisgarh High Court

Writ jurisdiction is not maintainable for adjudicating money claims arising from purely contractual disputes.

M/S GAYATRI CONSTRUCTION vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, a registered proprietorship firm, was awarded a tender for the construction of a "Single Village Piped Water Supply Scheme" under the Jal Jeevan Mission in District Mungeli

Source reference: para 3

The tender value was ₹79.87 lakhs with a nine-month completion period

Source reference: para 3

While the Petitioner received 70% of the bill amount during the execution phase, the remaining 30% was withheld by the respondent authorities

Source reference: para 3

The Petitioner alleged that despite full completion of the work and representations made to the authorities, the payment remained unpaid without justification

Source reference: para 3

Consequently, the Petitioner filed a writ petition under Article 226 of the Constitution of India seeking a direction for the release of the balance amount with 18% interest per annum

Source reference: para 2
02

Issues

Whether the High Court can exercise its writ jurisdiction under Article 226 to adjudicate purely contractual disputes involving monetary claims and factual determinations regarding work completion

Source reference: para 5, 8
03

Law Applied

judicial review in contractual or commercial matters must be exercised with great restraint and only in cases of clear arbitrariness, mala fides, or irrationality

Source reference: para 7

writ power should not be invoked to decide contractual disputes or protect private interests at the cost of public interest

Source reference: para 7

the Government must be allowed "fair play in the joints" in contractual matters

Source reference: para 7
04

Reasoning

The Court observed that the dispute arose purely from contractual obligations under a tender agreement

Source reference: para 5, 8

It found that the Petitioner’s claim for the withheld 30% payment involved disputed questions of fact—specifically, the verification of work quality, measurement, and technical compliance—which cannot be adjudicated in writ proceedings

Source reference: para 5, 8

The Court reasoned that there was no evidence of gross arbitrariness or mala fides on the part of the State; rather, the withholding appeared to be a matter of procedural and contractual compliance

Source reference: para 8

Applying the Tata Motors precedent, the Court noted that technical issues are outside the domain of judicial expertise and that the Petitioner had access to alternative efficacious remedies, such as a civil suit or arbitration, to resolve factual disputes

Source reference: para 5, 8
05

Holding

The High Court dismissed the writ petition, holding that a petition seeking the release of payment under a contract is misconceived when it involves factual determinations

The Court concluded that the scope of judicial review is limited and does not extend to settling commercial dues where the decision-making process is not shown to be irrational or contrary to law

Source reference: para 8

The Petitioner was left to avail appropriate alternative legal remedies

Source reference: para 8
Chhattisgarh High Court

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M/S GAYATRI CONSTRUCTIONvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 25, 2026

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