This judgment affirms the limited scope of judicial review in commercial and contractual matters, particularly regarding public tenders. The Court held that it would 'loathe to even peep into' the Railways' internal decision-making regarding the monitoring of food quality and distribution. The impugned Commercial Circular No. 24/2023, which introduced a cluster-based tender system with higher eligibility criteria and prohibited Joint Ventures, was challenged as arbitrary under Articles 14 and 19(1)(g).
The Court applied the settled principle that the author of a tender document is best suited to interpret its requirements. Judicial interference is only warranted if the decision is shown to be mala fide, arbitrary, discriminatory, or perverse. The Court found that the new policy was based on sound reasoning to address passenger complaints regarding hygiene and food quality, aiming to centralize accountability through IRCTC. The insistence on 'free play in the joints' for the executive in commercial policy formulation meant that mere disagreement with the policy or the lack of specific allegations of favoring individuals did not warrant judicial intervention.
Consequently, the challenge to the ban on joint ventures and the financial thresholds failed as the petitioner offered no material facts to prove the action was designed to exclude specific bidders for favoritism. The Court aligned itself with coordinate benches of the Jharkhand High Court and Karnataka High Court, reiterating that absent mala fides or perversity, the writ jurisdiction under Article 226 does not extend to substitute the administrative judgment on tender eligibility.
