Provisional auction bids create no vested right before confirmation; judicial review of cancellation stays narrow in public auction matters.

Under the Punjab Package Deal Properties (Disposal) Rules, 1976, the highest bid at public auction remained provisional until confirmed by the Sales Commissioner, so no vested right arose merely from deposit of earnest money. The competent authority could cancel the auction and order re-auction where it found inadequate publicity and an insufficient bid, and the appellate and revisional authorities upheld that decision. Judicial review in auction matters is limited to arbitrariness, irrationality, bias, mala fides, or perversity, and the Court will not substitute its own view for the authority's assessment of public interest and price realisation.

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Issues: Whether the highest bidder at a public auction of property governed by the Punjab Package Deal Properties (Disposal) Rules, 1976 acquired any vested right before confirmation of sale, and whether the High Court was justified in interfering with the cancellation of the provisional bid.

Analysis: The scheme of the Rules required the auction notice to be publicly notified and made subject to the reserve price and to confirmation by the Sales Commissioner. Under Rule 8(1)(h), the highest bid was only provisional until confirmed, and no final right accrued to the bidder merely because earnest money had been deposited. The competent authority found inadequate publicity and an insufficient bid, cancelled the auction, and directed re-auction. The appellate and revisional authorities upheld that decision. In matters of public auction and tender evaluation, judicial review is limited to cases of arbitrariness, irrationality, bias, mala fides, or perversity, and the Court will not substitute its own view for that of the authority best placed to assess the need for public interest and maximum price realization.

Conclusion: The highest bidder had no vested right to insist on confirmation of the sale, and the High Court ought not to have interfered with the cancellation order. The challenge to the cancellation was rejected in substance.

Final Conclusion: The order directing confirmation of the auction sale was set aside, and the authority's decision to cancel the provisional bid and proceed to re-auction was restored, while the deposited earnest money was ordered to be refunded with interest.

Ratio Decidendi: Where the governing auction rules make acceptance of the highest bid provisional and subject to confirmation by the competent authority, the highest bidder acquires no vested right to confirmation, and judicial review of cancellation is confined to cases of arbitrariness, irrationality, mala fides, or perversity.

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