Granted leave to appeal against the judgment of the High Court of Orissa, which dismissed the writ petition of the appellant who had mistakenly placed an exorbitant bid in an e-auction for a mining lease. The Supreme Court acknowledged the human error and found the forfeiture of the security deposit to be punitive and disproportionate. The court quashed the impugned communication and allowed a fresh e-auction while directing the appellant to pay Rs 3 crore to the first respondent.

1. Introduction and Background

   • Leave granted.
   • Appeal against the High Court of Orissa’s judgment dismissing the appellant's writ petition.

2. Parties Involved

   • Director of Mines and Geology, Bhubaneshwar (1st Respondent)
   • MSTC Ltd. (2nd Respondent)
   • State of Odisha (3rd Respondent)

3. Factual Matrix

   • Tender document for e-auction of mining lease floated on 9th January 2023.
   • Appellant submitted fees and bid security in compliance with tender requirements.
   • E-auction process and technical bids outlined under the Mineral Auction Rules, 2015.

4. E-Auction Process and Error

   • Auction scheduled for 21st March 2023 with a Floor Price of 84.00%.
   • Auction lasted almost seven hours, with the appellant mistakenly bidding 140.10% instead of 104.10%.
   • Appellant’s immediate attempt to rectify the mistake through calls and emails.

5. Response from the First Respondent

   • Rejection of appellant's request for bid rectification.
   • Impugned communication declaring the appellant as the Preferred Bidder.

6. High Court Proceedings

   • Appellant's writ petition dismissed, holding the appellant bound by its bid.

7. Appellant’s Grounds for Appeal

   • Bona fide human error.
   • No reasonable businessman would intentionally bid 140.10%.
   • Disproportionate punishment of security deposit forfeiture.

8. Respondents’ Arguments

   • E-auction process attained finality, and rectification not permissible.

9. Supreme Court’s Analysis

   • Examination of the e-auction process.
   • Human error and lack of rectification options in the system.
   • Reference to past judgments and the doctrine of proportionality.

10. Conclusion and Orders

    • Quashing the impugned communication.
    • Allowing a fresh e-auction.
    • Appellant directed to pay Rs 3 crore, with specific appropriations.
    • Setting aside the High Court’s judgment and partly allowing the appeal.