Government contracts must comply with Article 299(1); implied contract liability cannot support recovery as land revenue.

Article 299(1) makes compliance with the prescribed form and execution requirements mandatory for Government contracts, so no enforceable implied contract can be inferred from auction participation, bid documents, or acceptance of auction terms. On that basis, Section 155(b) of the Madhya Pradesh Land Revenue Code, 1959 could not be used to recover the amount as arrears of land revenue on an implied-contract theory. The separate question whether recovery was independently available under Sections 82 and 85 of the Indian Forest Act, 1927, read with the forest contract rules and auction conditions, remained unresolved and required further factual and legal examination on remand.

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Issues: (i) Whether, in the absence of a contract executed in the manner required by Article 299(1) of the Constitution of India, an implied contract could be inferred against the Government and the amount recovered as arrears of land revenue under Section 155(b) of the Madhya Pradesh Land Revenue Code, 1959. (ii) Whether the amount could nevertheless be recovered as arrears of land revenue under any other provision of law, including the Indian Forest Act, 1927 and the Madhya Pradesh Forest Contract Rules.

Issue (i): Whether, in the absence of a contract executed in the manner required by Article 299(1) of the Constitution of India, an implied contract could be inferred against the Government and the amount recovered as arrears of land revenue under Section 155(b) of the Madhya Pradesh Land Revenue Code, 1959.

Analysis: The constitutional requirement for Government contracts is mandatory. A valid Government contract must satisfy the prescribed form and execution requirements, and non-compliance leaves no enforceable contract. On that basis, no implied contract can be spelled out against the Government merely from bidding at auction, signing bid documents, or accepting auction conditions. If there is no contract within Article 299(1), Section 155(b) cannot be invoked on the footing of an implied contract to recover the amount as arrears of land revenue.

Conclusion: No implied contract could be inferred against the Government, and Section 155(b) of the Madhya Pradesh Land Revenue Code, 1959 did not authorize recovery of the deficiency as arrears of land revenue.

Issue (ii): Whether the amount could nevertheless be recovered as arrears of land revenue under any other provision of law, including the Indian Forest Act, 1927 and the Madhya Pradesh Forest Contract Rules.

Analysis: The question whether Sections 82 and 85 of the Indian Forest Act, 1927, read with the applicable forest contract rules and the auction conditions, independently permitted recovery had not been investigated by the High Court. The matter required factual and legal examination on that limited point before final disposal.

Conclusion: The question was left for further investigation on remand and was not finally determined.

Final Conclusion: The appeal succeeded to the extent that recovery could not rest on Section 155(b) of the Madhya Pradesh Land Revenue Code, 1959, and the matter was sent back for decision on the remaining statutory basis for recovery.

Ratio Decidendi: Article 299(1) of the Constitution of India excludes implied Government contracts and renders non-compliant agreements unenforceable, so liability cannot be recovered as arising under an implied contract.

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