Telangana Small Scale Industries Steel And Wooden Furniture Manufacturers Association vs. State Of Telangana

Facts

The petitioners, a manufacturers' association and several furniture manufacturers, filed a writ petition challenging the action of Respondent No. 2 (State Project Director, Samagra Shiksha) in issuing a letter dated 01.12.2025 and entering into agreements on 29.11.2025 with Respondents No. 6 and 7. These agreements pertained to a tender (Bid Notice No. (NIT) 06/55/2024-25 dated 26.04.2025) for the supply, commissioning, and installation of bunker beds in KGBVs in Telangana State. The petitioners sought to declare these actions illegal, arbitrary, and unconstitutional, and to set them aside. They also sought a stay on further proceedings. The respondents, including the State of Telangana and the Union of India, were arrayed as parties, along with the successful bidders (Respondents No. 6 and 7). The court had previously issued a status quo order on 11.12.2025.

Held

The High Court held that the petitioners were not entitled to the relief prayed for in the writ petition. The Court observed that the authority floating the tender is the best judge of its requirements and that judicial interference should be minimal, limited to preventing arbitrariness, irrationality, bias, mala fides, or perversity. The Court cited several Supreme Court judgments, including Montecarlo Limited Vs. National Thermal Power Corporation Limited and M/s. Galaxy Transport Agencies, which emphasize that the authority authoring the tender document is best placed to understand and appreciate its requirements, and its interpretation should generally not be second-guessed by a court in judicial review. The Court found that the actions of the respondents were in consonance with the language of the tender document and served the intended purpose. Consequently, the status quo order dated 11.12.2025 was vacated, and the writ petition was dismissed as devoid of merits. No order as to costs was made.

Key Issues

1. Whether the action of Respondent No. 2 in issuing the letter dated 01.12.2025 and entering into agreements dated 29.11.2025 with Respondents No. 6 and 7, in connection with the tender for supply, commissioning, and installation of bunker beds, was illegal, arbitrary, and unconstitutional, warranting judicial intervention under Article 226 of the Constitution of India. Petitioner's arguments: The petitioners contended that the actions of Respondent No. 2 were illegal, arbitrary, and unconstitutional. They sought to have the agreements set aside and further proceedings stayed. While the specific grounds for challenging the tender process are not detailed in the provided text, the overall prayer indicates a dispute over the fairness and legality of the award. Respondent's arguments: The respondents argued that the decision-making process in awarding the tender was consistent with the language of the tender document and served the purpose for which the tender was floated. They relied on various Supreme Court judgments emphasizing judicial restraint in matters of tender evaluation, particularly when dealing with complex technical subjects. They argued that the court should not sit as an appellate authority over the tender-issuing authority and that interference is warranted only in cases of arbitrariness, irrationality, bias, mala fides, or perversity.