Patent bidding error in a public tender can justify proportional relief and prevent full forfeiture of security.

A patent and self-evident error in a public bid may justify equitable intervention where the mistake is promptly disclosed and the bidder seeks withdrawal before a concluded contract. The Court treated the quoted price as an obvious mistake, found that insisting on justification and then enforcing full forfeiture was impractical, and applied proportionality to balance the bidder's fault with the authority's conduct in the tender process. Limited relief was therefore granted: total forfeiture was not sustained, and it was substituted with a reduced monetary payment against return of the security.

---

---

Issues: Whether the bidder's manifest error in quoting the bid price entitled it to relief against acceptance of the bid and forfeiture of the bank guarantee.

Analysis: The quoted amount was so unrealistic in the context of a large infrastructure contract that the error was self-evident and did not fall within the kind of mistake contemplated by Section 20 of the Indian Contract Act, 1872. The Court held that equitable relief may be granted where a material mistake of fact in a public bid is promptly brought to notice, the mistake is patent, and the bidder seeks withdrawal before a concluded contract. It also found that the authority acted impractically by insisting on justification and then invoking forfeiture, while contributing to the delay by not treating the obvious error as non est. The Court further applied proportionality in moulding relief, balancing the bidder's fault against the authority's conduct and the circumstances of the tender process.

Conclusion: The bidder was entitled to limited relief; the forfeiture was not sustained in full, and the matter was resolved by directing payment of a reduced amount in place of total forfeiture.

Final Conclusion: The appeal succeeded in part, the impugned judgment was set aside, and the forfeiture consequence was moderated by substituting a limited monetary payment against return of the security.

Ratio Decidendi: A patent and self-evident bidding error in a public tender may justify equitable intervention and proportional relief, particularly where the authority could have treated the bid as void or non est instead of insisting on forfeiture.

---