[2026:RJ-JP:21644] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR S.B. Civil Writ Petition No. 9109/2026 Pawan Kumar Meena S/o Shri Shiv Charan Meena, Resident of P- 86, RBI Officers Quarters, Gandhi Nagar, Jaipur-302015, Rajasthan ----Petitioner Versus 1. State of Rajasthan, Through The Principal Secretary, Urban Development And Housing Department, Government Secretariat, Jaipur, Rajasthan. 2. Chairman, Urban Improvement Trust, Alwar, Bhagat Singh Circle, Alwar, Rajasthan - 301001. 3. Secretary, Urban Improvement Trust, Alwar, Bhagat Singh Circle, Alwar, Rajasthan - 301001. ----Respondents For Petitioner(s) : Mr. Ashish Poonia For Respondent(s) : HON'BLE MR. JUSTICE MANEESH SHARMA Order 21/05/2026 1. The present writ petition has been filed by the petitioner, assailing the rejection letters/orders dated 30.04.2026 and 01.05.2026 passed by respondent No. 3. 2. Brief facts giving rise to the present writ petition are that the Urban Improvement Trust, Alwar, issued an e-auction programme for the sale of various residential/commercial plots, including the property in question, i.e., Plot No. K165 (Corner Plot), Ambedkar Nagar, Alwar (hereinafter referred to as the 'Subject Plot'), which was listed at Serial No. 40. 3. The petitioner participated in the e-auction for the Subject Plot and accordingly submitted his bid. After the closure of the bid process, the petitioner sought official confirmation via e-mails dated 23.04.2026 and 27.04.2026. Upon seeking the said confirmation, the petitioner was orally informed that his bid had been rejected. [2026:RJ-JP:21644] (2 of 7) [CW-9109/2026] 4. Subsequently, upon detailed representations dated 28.04.2026 and 02.05.2026 filed by the petitioner, respondent No. 3 issued letters dated 30.04.2026 and 01.05.2026, wherein it was stated that the petitioner's bid was rejected under Condition 12 of the terms and conditions of the e-auction and Rule 14, Annexure- A, Clause (j) of the Rajasthan Municipalities (Disposal of Urban Land) Rules, 1974 (hereinafter referred to as "the Rules of 1974"), since the Subject Plot K-165 had not fetched its appropriate value as the opposite Plot No. K-166 sold in e-auction held in November 2025 @ Rs. 79,500/-. 5. Upon a query being made to learned counsel for the petitioner by this Court, learned counsel for the petitioner fairly admits that the petitioner was the sole bidder in respect of the e- auction of the Subject Plot K-165. 6. Learned counsel for the petitioner submits that the respondent-Authorities have arbitrarily rejected the petitioner's bid despite his being the sole and highest bidder for the Subject Plot. He further submits that the alleged reason for rejection of the bid vis-a-vis Condition 12 of the terms and conditions of the e-auction as well as Rule 14, Annexure-A, Clause (j) of the Rules of 1974 is unsustainable in the eye of law, as the discretion of the Chairman cannot be arbitrary. He further submits that the reason for rejection of the bid qua inadequate bid amount or auction did not realize the potential value similar to the opposite Plot No. K-166 is also contrary to the mandate of the law. He, therefore, prays that the rejection letters/orders dated 30.04.2026 and 01.05.2026 [2026:RJ-JP:21644] (3 of 7) [CW-9109/2026] may be quashed and set aside among other consequential prayers. 7. In order to buttress his contention, he places reliance upon a judgment passed by the Co-ordinate Bench of this Court in the matter of Kamla Jain Vs. State of Rajasthan and Ors.1, and a judgment of the Hon'ble Apex Court in the matter of Golden Food Products India Vs. State of Uttar Pradesh and Ors.2 8. Heard and considered the submissions made by learned counsel for the petitioner and perused the material available on record. 9. The fundamental objective of an e-auction is to guarantee transparency, encourage competition, and maximize revenue through the active participation of multiple bidders. Where an auction elicits a response from merely a single bidder, the process is divested of its inherent competitive character. To accept the bid of a sole bidder, particularly when adequate bid amount is not quoted in comparison to the previous auction held in the same vicinity, defeats the very purpose of the auction and public interest. 10. It is an admitted fact that Subject Plot No. K-165, Ambedkar Nagar, Alwar, is a corner plot having an area admeasuring 157.3 square meters; the reserve price of the Subject Plot No. K-165 was fixed at Rs. 75,000/- per square meter, and the auction of the said plot was held on 22.04.2026 to 23.04.2026. 11. Further, from the record of the case, it is evident that the petitioner was a sole bidder who bid at the rate of Rs. 75,100/- 1 S.B. CWP No.15608/2025 2 2026 SCC Online SC 24 [2026:RJ-JP:21644] (4 of 7) [CW-9109/2026] per square meter as against the reserve price of Rs.75,000/-, and another Plot No. K-166, situated just opposite to the Subject Plot K-165, had earlier been auctioned/sold in an e-auction dated 07.11.2025 @ Rs. 79,500/- per square meter as against the reserve price of Rs. 55,000/-, while following Condition 12 of the terms and conditions of the e-auction as well as Rule 14, Annexure-A, Clause (j) of the Rules of 1974, and in the larger public interest, the respondent-Authority cancelled the bid of the petitioner. 12. It would be apt to reproduce Condition 12 and 16 of the terms of conditions of the said e-auction, which read as under: Clause 12: ^^cksyh v/;{k U;kl ds fu.kZ;k/khu gksxhA fcuk dksbZ dkj.k crk, cksyh dks Lohd`r@vLohd`r djus dk vf/kdkj fu;ekuqlkj U;kl v/;{k dks gSA** Clause 16: ^^Hkw[kaM ij jktLFkku uxj fodkl U;kl ¼uxjh; Hkwfe fuLrkj.k½ fu;e 1974 ds lHkh izko/kku jkT; ljdkj }kjk le;≤ ij fd;s x;s la'kks/ku lfgr ykxw gksaxsA** 13. It is evident from the above rules that the Chairman of the Trust possesses the absolute right to accept or reject any bid without assigning any reason thereof. Thus, it cannot be said that rejection of the petitioner's bid is contrary to the mandate of the law. 14. Further, another reason assigned for the rejection of the petitioner's bid was that the Subject Plot K-165 had not fetched its fair or appropriate value as the opposite Plot No. K-166 in the same colony has been sold in a previous e-auction dated 07.11.2025 @ Rs. 79,500/- per square meter as against the fixed reserve price of Rs. 55,000/- per square meter, and in the present [2026:RJ-JP:21644] (5 of 7) [CW-9109/2026] case, for the Subject Plot No. K-165, the petitioner put in a bid @ Rs. 75,100/- per square meter as against the reserve price of Rs. 75,000/- per square meter. 15. The petitioner has not challenged the rejection of his bid on the basis of any mala fide intention of the respondent-Authority, as from the record, no such ground has been pleaded by the petitioner. 16. Therefore, the facts of the case reveal that the action of the respondent is just, proper and appears to be taken in the larger interest of the public to realize maximum value, thus, cannot be said to be arbitrary, unreasonable or mala fide. 17. The scope of judicial review in the matter of cancellation of a bid is quite restrictive as it is well-established law that the Court should exercise its discretionary power conferred under Article 226 of the Constitution with great care and caution, and should exercise it only in furtherance of the public interest, with a caveat that the action is not based upon any mala fide or arbitrariness, and to ensure that if any public property is sold, the highest possible price is fetched. 18. 18. Thus, the Court should always keep the larger public interest in mind in order to decide whether it should interfere with the decision of the concerned authority. In the present case, the e- auction of the Subject Plot, which is public property, has only fetched a solitary bid; therefore, the rejection of the same cannot be said to be, in any manner, arbitrary. After all, it was in the public interest to see that the highest possible price be fetched for such properties. Thus, the impugned rejection of the petitioner's [2026:RJ-JP:21644] (6 of 7) [CW-9109/2026] bid was based on aforesaid considerations that are neither irrational nor arbitrary and this Court cannot sit in appeal over such factual and financial assessment. 19. Even otherwise, it is trite law that the highest bidder does not have an indefeasible right to get his bid accepted; bids can be rejected based on potential value assessments by the governing authority, or when the e-auction has fetched just a solitary bid. 20. In this view of the matter, the submissions advanced by learned counsel for the petitioner, that the petitioner being the sole and highest bidder, it is incumbent upon the respondent- Authority to accept the bid and complete the tender process, cannot be accepted. 21. As far as the judgments cited by learned counsel for the petitioner are concerned, in the matter of Kamla Jain (Supra), the impugned auction process was a case of a second auction, where the first auction had received zero bids, underscoring the lack of market interest in the plot therein. In Golden Food Products India (Supra), there were two bidders who participated in the auction and the appellant therein quoted his offer 15.23% above the reserve price, whereas in the present case the reserve price was fixed at Rs. 75,000/- per square meter and the petitioner herein quoted Rs. 75,100/- which is merely 0.14% above the reserve price; further, the present case pertains to a sole bidder, which clearly reflects that the auction process has lost its competitive character. Thus, it is evident that the cases relied upon by learned counsel for the petitioner are distinguishable on facts and are of little assistance to the petitioner. [2026:RJ-JP:21644] (7 of 7) [CW-9109/2026] 22. Apart from the above, the petitioner has failed to show this Court as to how he has been put to irreparable loss on account of the rejection of his bid and the institution of a subsequent/fresh e- auctioning thereof, as the petitioner is always free to participate in the subsequent/fresh e-auction for the Subject Plot. 23. Thus, on a cumulative assessment of the entire case, this Court is of the considered view that the rejection of the solitary bid received from the petitioner vide the impugned letters/orders does not suffer from any perversity or arbitrariness, so as to warrant any interference by this Court under the powers conferred by Article 226 of the Constitution of India. 24. In the upshot of the above discussion, the writ petition fails and is accordingly dismissed. 25. All other pending application(s), if any, stand disposed of. (MANEESH SHARMA),J SOURAV/19