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Issues: (i) whether the appellant's mistaken bid in the e-auction was a bona fide human error warranting interference and permission for rectification or a fresh auction; (ii) whether enforcement of the bid and forfeiture consequences were disproportionate in the facts.
Issue (i): whether the appellant's mistaken bid in the e-auction was a bona fide human error warranting interference and permission for rectification or a fresh auction.
Analysis: The bid was entered in a competitive auction process where the appellant had earlier bid in marginal increments and immediately on discovering the error sought correction. The record showed that the e-auction platform did not provide any option to cancel or rectify a bid once submitted, and the respondents did not specifically deny the appellant's prompt attempts to inform them. In the circumstances, the mistaken entry was treated as inadvertent rather than deliberate, and the absence of any contractual or procedural mechanism for correction weighed in favour of equitable intervention.
Conclusion: The mistake was bona fide, and the appellant was entitled to relief against strict enforcement of the erroneous bid.
Issue (ii): whether enforcement of the bid and forfeiture consequences were disproportionate in the facts.
Analysis: Judicial review in tender and commercial matters is ordinarily restrained, but interference is justified where rigidity produces manifest unfairness. Applying the doctrine of proportionality, the Court held that forfeiture of the entire security deposit for an evident clerical or typing error would be punitive and unconscionable. At the same time, the appellant's lack of care could not be ignored, and a moderated financial consequence was necessary to protect the public interest and the integrity of the bidding process. Exercising power under Article 142, the impugned communication was quashed and the State was left free to hold a fresh e-auction, with a monetary payment directed against the appellant in substitution of full forfeiture.
Conclusion: Full forfeiture and rigid enforcement were held to be disproportionate, and limited equitable relief was granted with compensatory directions.
Final Conclusion: The appeal was allowed in part by setting aside the impugned judgment, granting relief from the erroneous bid consequences, and permitting the respondents to proceed with a fresh auction while imposing moderated monetary consequences on the appellant.
Ratio Decidendi: In a tender or e-auction process, a prompt and bona fide bidding mistake may justify equitable interference where the platform provides no mechanism for correction and strict enforcement would be disproportionate; relief must balance fairness to the bidder with protection of the public interest.
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