Public interest litigation cannot be used to attack bona fide arbitration referrals or awards without proof of illegality or public injury.

Public interest litigation under Article 226 is intended to vindicate public duty and public interest, not to advance a private or collateral dispute. Where the petitioner lacks a real interest and places no reliable material to show illegality, mala fides, or public injury, writ jurisdiction should not be used to disturb a bona fide administrative decision. A party dispute may be referred to arbitration, and the mere choice of arbitration does not by itself indicate impropriety or bar judicial deference. On the stated facts, the challenge to the referral and award lacked material support and was outside proper limits of judicial review.

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Issues: Whether the High Court was justified in entertaining a public interest litigation under Article 226 of the Constitution of India and in quashing the decision referring the dispute to arbitration and the arbitral award.

Analysis: Public interest litigation is meant to vindicate public duty and protect public interest, not to advance a private or collateral dispute. Where the applicant has no real interest in the transaction and no material is shown to establish illegality, mala fides, or public injury, the writ jurisdiction should not be invoked to disturb a bona fide administrative decision. A party dispute may legitimately be referred to arbitration, and the absence of any bar under the Arbitration Act to such reference means that a court should not infer impropriety merely because an arbitral forum was chosen instead of ordinary litigation. The record contained no reliable material to show that the auction was unfair, the reference to arbitration was extraneous, or that public revenue had been imperilled. The High Court therefore acted on conjecture and exceeded the proper limits of judicial review.

Conclusion: The public interest litigation was not maintainable in the circumstances, and the High Court was not justified in setting aside the referral to arbitration or the award.

Ratio Decidendi: A writ petition styled as public interest litigation cannot be used to challenge a bona fide dispute resolution measure or an arbitral award in the absence of material showing illegality, mala fides, or real public injury.

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