Judicial Restraint in Contractual Matters: The Supreme Court emphasized minimal interference in contractual disputes involving State instrumentalities, citing Subodh Kumar Singh Rathour v. The Chief Executive Engineer & Ors. (2024 SCC OnLine SC 1682) and Slippi Constructions Contractors v. Union of India ((2020) 16 SCC 489). (Paras 12, 12.1, 12.2) Courts must avoid "microscopic scrutiny" of tenders and respect the autonomy of public sector undertakings. (Para 12.3)

Public Trust Doctrine: Natural resources like petroleum are held by the State in trust for public benefit, requiring transparent and non-arbitrary allocation. (Para 14) Reference made to Illinois Cent R Co v. State of Illinois (1892 SCC OnLine US SC 237) and Natural Resources Allocation, In re ((2012) 10 SCC 1). (Para 14)

Advertisement Compliance: BPCL’s advertisement mandated strict adherence to application guidelines, including self-declaration of land ownership (Group 1) or firm offer (Group 2). (Para 10, Clause k) Respondent’s belated request for reclassification from Group 2 to Group 1 was untenable as it contravened explicit terms. (Para 15)

Misplaced Sympathy by High Court: The High Court’s direction to consider the respondent under Group 1 was erroneous, as it overlooked contractual specificity and procedural finality. (Para 17) Litigation prolonged due to multiple writ petitions, causing public detriment. (Para 19)

Held

No. The Supreme Court held: The High Court exceeded its jurisdiction by substituting BPCL’s contractual discretion with sympathetic considerations. (Para 18) Judicial interference in commercial matters must be limited to cases of patent arbitrariness or mala fides. (Para 12.2)

Appeal allowed. High Court’s order set aside. BPCL to proceed with allotment as per rules. (Para 18)

Major Acts and Provisions:

• Article 226 of the Constitution of India – Writ jurisdiction of High Courts. (Para 11)

• Article 12 of the Constitution of India – Definition of "State" for fundamental rights enforcement. (Para 13)

• Doctrine of Public Trust – As recognized in M.C. Mehta v. Kamal Nath (1997) 1 SCC and Reliance Natural Resources Ltd. v. Reliance Industries Ltd. (2010) 7 SCC 1. (Para 14)

Question of Law:

Whether the High Court, in exercise of its writ jurisdiction under Article 226, could direct reclassification of a retail outlet dealership application contrary to the advertised terms and contractual stipulations?

Subjects:

Judicial restraint, Public Trust Doctrine, Contractual autonomy, State instrumentality, Natural resources allocation, Writ jurisdiction.