Madras High Court Upholds Gold-Ring Tender Won With One-Paisa Bid, Dismisses PIL by Non-Bidder

The Tamil Nadu Medical Service Corporation, entrusted with the procurement, invited rate-contract bids on 13.07.2026 (para 2.1). A corrigendum of 08.08.2026 collapsed the price schedule into one composite charge per ring, excluding gold, which was to be paid separately at the prevailing IBJA rate; another raised the bid security to Rs.3.75 crore (para 2.2). Of eleven bids, Joyalukkas quoted Rs.0.01 and was L1; under Clause 5.7(viii) the L1 rate was offered to the others, and only Kalyan Jewellers matched it (paras 2.3-2.4). The petitioner said the bid omitted cost heads and was speculative, and that the Corporation could not deal in gold (paras 3.2-3.3).

Relying on Tata Cellular v. Union of India and Michigan Rubber (India) Ltd. v. State of Karnataka, the Bench said judicial review in tender matters is narrow: the court reviews the decision-making process, allows the State fair play in the joints, and interferes only for arbitrariness, mala fides or irrationality, or where public interest is affected (paras 6-8). Two features stood against the petitioner. He did not challenge the scheme or its entrustment to the Corporation (para 9). Nor did he challenge any tender condition, including Clause 5.7, under which the L1 rate was tested and accepted, or Clause 5.8, which he invoked; since he "accepts the entire architecture of the tender", the Court could not readily strike down the outcome those terms produced (para 10). His plea that the Corporation had no power to deal in gold was inconsistent with his prayer that the same body procure afresh (para 11). He was not a tenderer, and none of the ten losing bidders had questioned the award; a court should be slow to unsettle a commercial tender at a stranger's instance (para 12). No arbitrariness, mala fides or irrationality was shown (para 13).