Writ Jurisdiction Under Article 226 Is Not Maintainable for Adjudicating Contractual Disputes Involving Complex Factual Controversies

The Petitioner, a road construction firm, was awarded a contract under the PMGSY for road maintenance in District Mungeli.

Despite completing the work and receiving a Completion Certificate on 02.01.2023, the Respondent authorities withheld approximately ₹3.11 Crore from the final bill.

This withholding was based on a letter dated 06.01.2020 issued by the Collector, Mining Division, requiring a "Royalty Clearance Certificate"—a condition the Petitioner claimed was neither in the tender agreement nor supported by statute.

The Petitioner challenged this executive instruction as arbitrary and sought a writ of mandamus for the release of dues.

1. Whether a writ petition under Article 226 of the Constitution of India is maintainable when the dispute involves complex and disputed questions of fact arising out of a contract

2. Whether the High Court should adjudicate a monetary claim for withheld dues where the liability and compliance with royalty payments are contested

Principle that writ jurisdiction is not intended to supplant civil remedies for contractual disputes involving disputed facts, as established in State of Bihar v. Jain Plastics and Chemicals Ltd.

The Court should normally refuse discretion under Article 226 if the matter lacks a public law character or requires oral evidence as held in Joshi Technologies International Inc. v. Union of India.

Doctrine affirming that while there is no absolute bar, the High Court should relegate parties to civil suits or arbitration for "purely contractual matters" involving technical measurements or factual controversies based on Union of India v. Puna Hinda and M.P. Power Management Co. Ltd. v. Sky Power Southeast Solar India (P) Ltd.

The Court observed that the Petitioner’s claim for ₹3.11 Crore was intrinsically linked to factual determinations regarding the procurement of minor minerals and the validity of royalty payments.

The court reasoned that deciding whether the Petitioner complied with mineral laws or if the Royalty Clearance Certificate was mandatory requires a detailed appreciation of evidence and documents.

Following the precedents of the Supreme Court, the Court noted that Article 226 cannot be used to avoid contractual obligations or decide "hotly disputed questions of facts".

Since the dispute fell within the realm of private law and lacked a distinct "public law element," the Court found it inappropriate to exercise its extraordinary jurisdiction.

The Petitioner's proper remedy lies in a civil suit or other alternative forums, not under Article 226.

The petition was dismissed, though liberty was granted to the Petitioner to pursue alternate legal remedies.