Madhya Pradesh High Court
Contract LawAdministrative and Public Law

Writ jurisdiction is unavailable for disputed contractual payment claims; parties must pursue contractual remedies.

Krishna Kumar Karoliya vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: September 24, 20263 MIN READSOURCE JUDGMENT
Writ jurisdiction is unavailable for disputed contractual payment claims; parties must pursue contractual remedies.. Krishna Kumar Karoliya vs The State Of Madhya Pradesh. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Collector granted administrative approval for construction works in four villages, including a PDS Godown at Bheempura, District Damoh, with the Rural Engineering Department as the construction agency.

Source reference: no citation

The petitioner participated in the tender process, executed an agreement with the respondent department on 27 February 2024, and received a work order dated 29 February 2024.

Source reference: no citation

He claimed to have completed construction up to the roof level and submitted bills for payment.

Source reference: no citation

However, the work was allegedly not reflected on the online portal, preventing payment.

Source reference: no citation

The Executive Engineer and the petitioner made several communications and representations seeking correction of the portal and release of payment, but no decision was taken.

Source reference: para. 2

During the proceedings, the petitioner could not produce a work-completion certificate.

Source reference: para. 3

The respondents asserted that there was a dispute concerning the sanction of the work and that no completion certificate had been issued.

Source reference: paras. 3–4
02

Issues

Whether the High Court could issue a writ of mandamus directing the respondents to correct the online portal and release payment allegedly due under the construction work order.

Source reference: paras. 1–3

Whether the writ petition was maintainable in view of the disputed sanction of the work, absence of a work-completion certificate, and availability of a contractual remedy.

Source reference: paras. 4–6
03

Law Applied

The Court held that writ jurisdiction should be exercised with restraint in contractual and commercial matters.

Source reference: para. 7

In Tata Motors Ltd. v. Brihan Mumbai Electric Supply & Transport Undertaking (BEST), 2023 SCC OnLine SC 671, the Supreme Court held that interference in contractual matters is ordinarily unwarranted unless arbitrariness, mala fides, bias, or irrationality is clearly established; courts must also avoid entering into technical and commercial questions.

Source reference: para. 7

Relying on Tata Cellular v. Union of India, (1994) 6 SCC 651, the Court reiterated that judicial review examines the decision-making process and not the merits of the contractual decision, and that courts should not substitute their own view for that of the authorities in the absence of arbitrariness or illegality.

Source reference: para. 8

Where contractual remedies are available and factual or technical disputes arise, a writ of mandamus ordinarily should not be issued.

Source reference: paras. 6, 9
04

Reasoning

The Court found that the respondents had raised a dispute regarding the sanction of the work, as reflected in the communication dated 19 September 2024, and that the petitioner had not placed any work-completion certificate on record.

Source reference: para. 6

Since the claim for payment depended on disputed contractual facts, including the validity of the sanction and completion of the work, the Court held that the matter could not appropriately be adjudicated in writ jurisdiction.

Source reference: paras. 6, 9

The alleged non-reflection of the work on the online portal did not, by itself, establish an enforceable public-law entitlement to payment.

Source reference: paras. 6, 9

Applying the principles of restraint governing contractual disputes, the Court concluded that the petitioner had an adequate remedy under the contract.

Source reference: paras. 6, 9
05

Holding

The Court declined to issue a writ directing correction of the online portal or release of payment.

The writ petition was dismissed because the dispute concerned contractual matters, no work-completion certificate had been produced, and a contractual remedy was available to the petitioner.

Source reference: para. 9

The petitioner was granted liberty to avail the remedy provided under the contract for redressal of his grievances.

Source reference: para. 10
Madhya Pradesh High Court

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Krishna Kumar KaroliyavsThe State Of Madhya Pradesh

Madhya Pradesh High Court · September 24, 2026

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