Writ relief against arbitrary forfeiture clause in a State raffle scheme was upheld, and the prize claim enforced.

A writ petition under Article 226 was held maintainable to challenge a State-administered raffle authority's refusal to release prize money, because arbitrary or unlawful public action is not excluded merely by the claim's contractual source. The clause requiring automatic forfeiture of unclaimed prize money after three months was held invalid: it was treated as penal, unconscionable, and contrary to public policy, since the State held the prize amount in a fiduciary capacity and showed no corresponding legal injury. Relief was granted by enforcing the prize claim and issuing mandamus against reliance on the forfeiture term.

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Issues: (i) Whether a writ petition under Article 226 of the Constitution of India was maintainable for enforcement of the prize claim arising from the raffle scheme; (ii) whether the clause providing for automatic forfeiture of unclaimed prize money after three months was valid and enforceable.

Issue (i): Whether a writ petition under Article 226 of the Constitution of India was maintainable for enforcement of the prize claim arising from the raffle scheme.

Analysis: The claim arose from a State-administered raffle scheme, and the refusal to pay the prize money was a decision of a public authority. The existence of a contractual or bargain-based source for the claim did not by itself exclude writ jurisdiction where the State's action was arbitrary, unlawful, or contrary to public duty. The availability of a civil remedy was not treated as an absolute bar where the justice of the case warranted constitutional relief.

Conclusion: The writ petition was maintainable.

Issue (ii): Whether the clause providing for automatic forfeiture of unclaimed prize money after three months was valid and enforceable.

Analysis: The rule permitting lapse of unclaimed prize money was accepted as an administrative device, but the further stipulation of automatic forfeiture to the Government was treated as penal, unconscionable, and opposed to public policy. The prize amount was held by the State in a fiduciary capacity, and no legal injury to the State was shown by the delayed claim. A term operating in terrorem and imposing forfeiture without corresponding loss was held unreasonable and contrary to the law of contract and public interest.

Conclusion: The forfeiture clause was invalid and unenforceable against the petitioner.

Final Conclusion: Relief was granted by enforcing the petitioner's right to the prize amount and issuing mandamus against the refusal based on the forfeiture clause.

Ratio Decidendi: A State-imposed term in a raffle scheme that provides for forfeiture of a prize amount without legal injury and operates in terrorem is unenforceable as against public policy, and writ relief may be granted against arbitrary refusal by a public authority even where the claim originates in a contractual arrangement.

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