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 3The tender value was ₹79.87 lakhs with a nine-month completion period
Source reference: para 3While the Petitioner received 70% of the bill amount during the execution phase, the remaining 30% was withheld by the respondent authorities
Source reference: para 3The Petitioner alleged that despite full completion of the work and representations made to the authorities, the payment remained unpaid without justification
Source reference: para 3Consequently, 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 2Issues
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, 8Law 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 7writ power should not be invoked to decide contractual disputes or protect private interests at the cost of public interest
Source reference: para 7the Government must be allowed "fair play in the joints" in contractual matters
Source reference: para 7Reasoning
The Court observed that the dispute arose purely from contractual obligations under a tender agreement
Source reference: para 5, 8It 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, 8The 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 8Applying 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, 8Holding
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 8The Petitioner was left to avail appropriate alternative legal remedies
Source reference: para 8Original Court PDF
M/S GAYATRI CONSTRUCTIONvsSTATE OF CHHATTISGARH
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