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M/S Vinayak Manufacturers Pvt. Ltd. v. Government E-Market Place & Ors.

Delhi HC16 Mar 2026W.P.(C)/590/2025

Case brief

AI extract

What is this about?

Non-speaking orders; absence of reasons in administrative/quasi-judicial decisions; subsequent documents cannot cure lack of reasons; supplementation by affidavit impermissible; Mohinder Singh Gill v. Chief Election Commissioner (1978) 1 SCC 405; Article 14 transparency and fairness; Government e-Marketplace (GeM); Union of India; appeals rejected without reasons set aside; fresh order after opportunity of hearing; Mishthi Industries cited; Justice Purushaindra Kumar Kaurav; High Court of Delhi; decided 16.03.2026.

What did the court decide?

Impugned appellate decisions set aside; petitions disposed of; liberty granted to the respondents to pass a fresh order after granting an opportunity of hearing to the petitioners; all rights and contentions of the parties left open. ¶54

M/S Vinayak Manufacturers Pvt. Ltd. Vs Government E-Market Place & Ors. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the decisions passed in appeals, being non-speaking (passed without recording reasons), can be sustained in law, and whether the absence of reasons can be cured by subsequently placed documents.

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Court's answer

In the absence of cogent reasons for rejection of the appeals, the impugned decisions cannot be sustained in law; mere placing of subsequent documents does not cure the foundational defect of absence of reasons in the impugned orders.

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Ratio / Principle

The principle (per the Supreme Court in Mohinder Singh Gill) that the validity of a statutory authority's order must be tested solely on the reasons recorded therein, and cannot be supplemented or improved upon subsequently, underscores the requirement of transparency, fairness and accountability in administrative decision-making, which is a facet of Article 14 of the Constitution.

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Key takeaways

Applying the settled position of law, the impugned appellate decisions, being bereft of reasons and sought to be justified subsequently, are unsustainable and are set aside.ratio¶54

Detailed headnote1 paragraphs

Delhi High Court (Purushaindra Kumar Kaurav, J., oral), 16.03.2026 — Four writ petitions (M/s 6X; M/s Ganpati Interglobe Pvt. Ltd.; M/s Vinayak Manufacturers Pvt. Ltd.; M/s Jai Balaji Industry) challenged decisions passed in appeals (against Union of India / Government e-Marketplace respondents) solely on the ground that they were non-speaking. Documents subsequently filed pursuant to the Court's direction (minutes/comments) disclosed no adjudication of the petitioners' contentions. Relying on Mohinder Singh Gill v. Chief Election Commissioner, (1978) 1 SCC 405 — the validity of an order must be tested solely on the reasons recorded therein and cannot be supplemented subsequently by affidavits or otherwise — and noting counsel's reliance on M/s Mishthi Industries (Writ Petition No. 30663/2024), the Court held that absence of cogent reasons is fatal and cannot be cured by later documents, this requirement of transparency, fairness and accountability being a facet of Article 14. The impugned decisions were set aside; the petitions were disposed of; respondents were granted liberty to pass fresh orders after hearing; rights and contentions left open.

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$~40, 41, 43 and 46

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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Date of Decision: 16.03.2026

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IN THE MATTERS OF:

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+ W.P.(C) 14290/2024 and CM APPL. 69348/2024, CM APPL. 15772/2026

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M/S 6X .....Petitioner

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Through: Rajat Gaur & B S Mathur Advocates. versus

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UNION OF INDIA & ANR. .....Respondents

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Through: Mr.Rohan Jaitley CGSC, Mr.Akshay Sharma, Mr.Dev Pratap Shahi, Mr. Varun Pratap Singh Advocates for UOI.

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Mr Premtosh K Mishra CGSC, Mr Shrey Sharma, Mr Anubhav Upadhyay Advocates. Ms.Shweta Bharti, Ms.Tejaswini Chandrasekhar, Ms. Sonali Khanna, Mr.Jatin Chaddha, Ms. Mehak , Advocates, for respondent/ GeM.

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+ W.P.(C) 15749/2024

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M/S GANPATI INTERGLOBE PVT. LTD. .....Petitioner

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Through: Mr Rana S Biswas, Kartik Chettiar and Yash Tirpathi Advocates.

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Signature Not Verified Signed By:AMIT KUMAR SHARMA Signing Date :20. 03.2026 17:11:26

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Page 1 of 4

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Signature Not Verified

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Signed By:PURUSHAINDRA KUMAR KA URAV

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versus

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UNION OF INDIA GOVERNMENT E-MARKET PLACE & ORS. ....Respondents

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Through: Ms.Shweta Bharti, Ms.Tejaswini Chandrasekhar, Ms. Sonali Khanna, Mr.Jatin Chaddha, Ms. Mehak , Advocates, for respondent/ GeM.

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43 + W.P.(C) 590/2025 and CM APPL. 2779/2025, CM APPL. 15774/2026

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M/S VINAYAK MANUFACTURERS PVT. LTD .....Petitioner Through: Mr Rana S Biswas, Kartik Chettiar, and Yash Tirpathi Advocates.

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versus

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GOVERNMENT E-MARKET PLACE & ORS. .....Respondents

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Through: Ms.Shweta Bharti, Ms.Tejaswini Chandrasekhar, Ms. Sonali Khanna, Mr.Jatin Chaddha, Ms. Mehak , Advocates, for respondent/ GeM.

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+ W.P.(C) 1645/2025 and CM APPL. 7977/2025, CM APPL. 15776/2026

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M/S JAI BALAJI INDUSTRY THROUGH ITS SOLE PROPRIETOR MRS. PRIYANKA AGARWAL .....Petitioner Through: Mr Rana S Biswas, Kartik Chettiar and Yash Tirpathi Advocates.

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versus

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GOVERNMENT E-MARKET PLACE THROUGH ITS AUTHORIZED

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Signature Not Verified

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Signed By:AMIT KUMAR SHARMA Signing Date :20. 03.2026 17:11:26

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Signature Not Verified

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Signed By:PURUSHAINDRA Page 2 of 4 KUMAR KA URAV

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REPRESENTATIVE & ORS.

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.....Respondents

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Through: Ms.Shweta Bharti, Ms.Tejaswini Chandrasekhar, Ms. Sonali Khanna, Mr.Jatin Chaddha, Ms. Mehak , Advocates, for respondent/ GeM.

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CORAM:

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HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV

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J U D G E M E N T

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PURUSHAINDRA KUMAR KAURAV, J. (ORAL)

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In all the afore-captioned writ petitions, the decisions passed in appeals are under challenge. The sole ground is that the same are nonspeaking.

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This submission was noted on last date and accordingly it was directed to bring on record, the minutes of meeting, if it contained any reasons.

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The subsequent documents which have been placed on record do not disclose any adjudication of the issues raised by the petitioners.

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The documents only indicate that certain comments were forwarded for approval to the higher authorities. They do not reveal any adjudication to the contentions urged by the petitioners, nor do they indicate the reasons for which the petitioners’ submissions came to be rejected.

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Learned counsel for the petitioners has placed reliance on the order passed in M/s Mishthi Industries Private Limited Thr. Director Vedansh Garg vs. Union of India and Ors.¹ stating that an administrative or quasijudicial order, particularly one entailing adverse civil consequences, must be supported by intelligible reasons.

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Signature Not Verified

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Signature Not Verified

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Signed By:AMIT KUMAR SHARMA Signing Date :20. 03.2026 17:11:26

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Signed By:PURUSHAINDRA Page 3 of 4 KUMAR KA URAV

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Having heard learned counsel for the parties, this Court is of the opinion that, in the absence of cogent reasons for rejection of the appeals, the impugned decisions cannot be sustained in law. Merely placing of subsequent documents would not cure the foundational defect of absence of reasons in the impugned orders. The Supreme Court in case of Mohinder Singh Gill v. Chief Election Commissioner² has unequivocally held that that when a statutory authority makes an order, its validity must be tested solely on the reasons recorded therein, and such reasons cannot be supplemented or improved upon subsequently by way of affidavits or otherwise. The said principle underscores the requirement of transparency, fairness and accountability in administrative decision-making, which is a facet of Article 14 of the Constitution.

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Applying the aforesaid settled position of law, this Court finds that the impugned decisions, being bereft of reasons and sought to be justified subsequently, are unsustainable and are, hereby, set aside.

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