Writ jurisdiction is not maintainable for contractual disputes involving factual determinations of work completion.

The Petitioner, a registered Class ‘C’ contractor, was awarded multiple contracts between 2022 and 2024 for Piped Water Supply Schemes under the Jal Jeevan Mission (JJM).

Following the execution of works and submission of bills, an internal audit conducted by Respondent No. 4 in April 2024 raised objections regarding the rate analysis of Functional Household Tap Connections (FHTC).

Consequently, Respondent No. 2 issued a circular in December 2024 directing the retrospective revision of contract rates and the recovery of ₹1,871 per connection, leading to the withholding of the Petitioner’s final bills and security deposits.

The Petitioner challenged these actions under Article 226, alleging a violation of natural justice and promissory estoppel, and sought the release of outstanding payments.

1. Whether the High Court, in its writ jurisdiction, can adjudicate a dispute involving the unilateral revision of contract rates and non-payment of dues arising from a concluded commercial contract.

2. Whether the impugned actions of the Respondents were sufficiently arbitrary or mala fide to warrant judicial interference in a contractual matter.

The Court primarily relied on the principles of judicial restraint in contractual and commercial matters as articulated by the Supreme Court in Tata Motors Limited v. The Brihan Mumbai Electric Supply & Transport Undertaking (BEST) and Others (2023).

The core rule established is that writ courts should not interfere in contractual disputes unless a "clear-cut case of arbitrariness, mala fides, or irrationality" is demonstrated.

The Court further applied the doctrine that disputes involving factual determinations—such as work completion, quality, and measurement—are civil in nature and should be resolved through alternative remedies like arbitration or civil suits rather than under Article 226.

The Court observed that the grievance pertains to the non-release of contractual dues and the retrospective adjustment of rates based on audit observations.

Applying the Tata Motors precedent, the Court reasoned that the petitioner failed to demonstrate any exceptional circumstances, such as gross arbitrariness or palpable irrationality in the decision-making process.

The Court noted that the dispute involves complex factual determinations regarding the measurement and verification of work, which fall squarely within the domain of private civil law.

It emphasized that judicial review is limited in technical and commercial matters, and courts must allow "fair play in the joints" to the government in managing public contracts.

Consequently, the Court found the petition to be a surrogate for a money suit.

The Court concluded that the Petitioner's remedy lies in availing appropriate alternative legal proceedings, such as a civil suit or arbitration, for the recovery of alleged dues.

All reliefs sought were denied.