Can Authorities Override Contract Renewal Guidelines for Women Self Help Groups by Open Advertisement? Orissa High Court Reaffirms Binding Nature of Administrative Guidelines

The Orissa High Court held that the 2018 Guidelines governing the selection and renewal of contracts for Women Self Help Groups (WSHGs) supplying Take Home Ration (THR) are binding in the absence of statute, and that authorities cannot bypass these by issuing open advertisements for selection. The judgment upholds longstanding legal principles on the enforceability of non-statutory guidelines and limits administrative discretion, offering binding authority for future disputes over governmental contracts in the social welfare sector.

 

Summary

Category Data
Case Name WP(C)/18134/2025 of M/S.NITAI GAURA WOMENS S.H.G, BHADRAK Vs STATE OF ODISHA
CNR ODHC010459072025
Date of Registration 02-07-2025
Decision Date 24-10-2025
Disposal Nature Disposed Off
Judgment Author MR. JUSTICE SASHIKANTA MISHRA
Court Orissa High Court
Bench Single Bench
Precedent Value Binding within jurisdiction of Orissa High Court
Overrules / Affirms
  • Affirms binding force of administrative guidelines
  • Distinguishes level playing field doctrine
Type of Law Administrative/Constitutional/Contract law in social welfare schemes
Questions of Law
  • Whether an authority can issue open advertisements for selection, bypassing specific guidelines for contract renewal/rescission?
  • Are administrative guidelines legally enforceable in the absence of statutory law?
  • Scope and nature of judicial review in administrative tendering processes.
Ratio Decidendi The Court reaffirmed that in the absence of a statutory enactment, administrative guidelines (here, the 2018 Guidelines for THR/Chhatua distribution) constitute a binding, self-contained code for selection and renewal of WSHG contracts. The Collector’s issuance of open advertisement without first reviewing the incumbent’s performance, as mandated by the guidelines, constitutes a clear violation. The doctrine of a “level playing field” or administrative discretion cannot override express guidelines. The Court further clarified the limits of judicial review in contractual matters, holding that the writ jurisdiction is available for violation of such guidelines, even in the context of contracts.
Judgments Relied Upon
  • Joshi Technologies International Inc. v. Union of India (2015) 7 SCC 728
  • Radha Krishan Industries v. State of H.P. (2021) 6 SCC 771
  • Tata Motors Ltd. v. Brihan Mumbai Electric Supply & Transport Undertaking (2023) 19 SCC 1
  • Reliance Energy Ltd. v. Maharashtra State Road Development Corporation Ltd. (2007) 8 SCC 1
  • Narendra Kumar Maheshwari v. Union of India, 1990 Supp SCC 440
  • E.S. Patangwala Industrial Estate v. Collector of Central Excise (1998) 8 SCC 752
  • Nagpur Improvement Trust v. Yadaoro Jagannath Kumbhare (1999) 8 SCC 99
  • Director, C.B.I v. D.P.Singh (2010) I SCC 647
  • Nazir Ahmad v. King-Emperor, 1936 SCC OnLine PC 41
Logic / Jurisprudence / Authorities Relied Upon by the Court The Court reasoned that when administrative instructions/guidelines fill a statutory vacuum, they become enforceable if deviation directly affects vested rights or undermines the public purpose of the scheme. The principles of statutory interpretation apply equally to such guidelines, as per Supreme Court precedents. Bypassing specific procedures in favour of general principles (e.g., open advertisement) is impermissible where the guidelines contemplate a specific sequence of renewal/review.
Facts as Summarised by the Court Biswonath WSHG had long supplied THR/Chhatua under an annually renewable contract governed by 2018 Guidelines, which require performance review before renewal or rescission. Without reviewing Biswonath WSHG’s performance, the Collector issued an open advertisement to select SHGs. Test reports and beneficiary feedback for incumbent SHGs were positive. Incumbents challenged the legality of the advertisement; new applicants sought finalisation of the selection process.

Practical Impact

Category Impact
Binding On All subordinate courts and authorities within the jurisdiction of Orissa High Court
Persuasive For Other High Courts; Supreme Court (on enforceability of administrative guidelines)
Follows Tata Motors Ltd. v. BEST (2023) 19 SCC 1; Supreme Court precedents on guidelines’ enforceability
Distinguishes Reliance Energy Ltd. v. MSRDC (2007) 8 SCC 1 – level playing field doctrine does not override explicit guidelines

What’s New / What Lawyers Should Note

  • Affirms that in the absence of a statute, explicit government guidelines for contract renewal or selection are legally binding; authorities cannot circumvent them by invoking general discretion or fairness principles.
  • Clarifies that renewal of contracts under government guidelines is not an automatic right, but the process must adhere strictly to the guidelines (e.g., mandatory performance review).
  • Level playing field doctrine or administrative discretion cannot override specific procedures laid down in guidelines.
  • Lawyers can cite this case as binding authority within Orissa to challenge administrative actions that bypass scheme guidelines in welfare contract matters.

Summary of Legal Reasoning

  • The Court addressed whether writ petitions are maintainable in contract-based government schemes, relying on Supreme Court cases (Joshi Technologies, Radha Krishan Industries) but recognizing exceptions for violations of guidelines affecting public schemes.
  • Detailed analysis of the 2018 Guidelines revealed a self-contained, binding code for THR contracts: explicit performance review before contract renewal or rescission, and an absence of any provision for open advertisement.
  • The Collector’s issuance of an advertisement for open selection, without conducting performance review, directly violated Clauses 7 and 12(ii) of the guidelines.
  • Supreme Court authorities (Narendra Kumar Maheshwari, E.S. Patangwala, Nazir Ahmad) confirm that administrative instructions are enforceable where no statute covers the field, and must be followed as written.
  • The “level playing field” and transparency principles (Reliance Energy) cannot trump explicit processes mandated by binding guidelines.
  • The Court refused relief to applicants dependent on the illegal advertisement and confirmed that contract renewal is not a vested right but must follow the guidelines’ procedure.

Arguments by the Parties

Petitioners (WSHGs challenging the advertisement):

  • The 2018 Guidelines lay down explicit procedures for SHG selection and contract renewal; there is no provision for open advertisement.
  • Performance review prior to renewal/rescission is mandatory, and positive reports were received for incumbent SHGs.
  • Other districts have renewed contracts without open advertisement; the Collector exceeded his jurisdiction.
  • Automatic renewal is not claimed, but adherence to guidelines is mandatory.

Petitioners (Applicants seeking finalisation of new selection):

  • Participated in the open selection process upon Collector’s advertisement, fulfilling all eligibility criteria.
  • The selection process was blocked due to a judicial order; sought court direction to finalise selection.

State / Respondent:

  • Renewal of contract is not a matter of right; contracts must be reviewed on performance.
  • Several complaints and adverse reports justified decision to seek open competition.
  • Although guidelines do not expressly provide for advertisement, ensuring fairness and transparency justified the Collector’s action.
  • Open advertisement does not prohibit incumbent SHGs from participating.

Biswonath WSHG (Intervener):

  • No legal authority for issuing advertisement; performance certified as satisfactory.
  • Other districts renewed contracts without advertisement; no adverse findings against them.

Factual Background

The dispute arose from the government’s engagement of Self Help Groups (SHGs) for the annual supply and distribution of Take Home Ration (THR/Chhatua) in Bhadrak, Odisha under the 2018 Guidelines. Biswonath WSHG held such a contract since 2011, renewed annually. Without conducting the prescribed performance review, the Collector instructed fresh selection through open advertisement, leading to legal challenges from incumbent SHGs and applications by new aspirants under the advertisement. Test reports and beneficiary evidence supported incumbent performance.

Statutory Analysis

  • 2018 Guidelines (Government of Odisha, W & C.D. Department):
    • Clause 7: Specifies selection criteria — no mention of open advertisement; prioritises graded SHGs with infrastructure.
    • Clause 12(ii): Mandates annual performance review prior to renewal or rescission of contract.
  • Legal Principle: Where guidelines provide explicit procedures, authorities are bound to follow them exclusively; administrative discretion cannot override.
  • Case Law: Cited Supreme Court precedents establish that administrative guidelines are enforceable and deviations are subject to judicial scrutiny when affecting rights or public scheme objectives.

Alert Indicators

  • ✔ Precedent Followed – The judgment affirms and applies longstanding Supreme Court principles regarding enforceability of administrative guidelines where no statute governs the field.

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