I. Introduction: The Constitutional and Commercial Confluence in Public Tenders

The adjudication of disputes arising from government tenders and public procurement contracts occupies a significant volume of the docket in the Constitutional Courts of India. At the heart of this litigation lies a fundamental tension between two competing jurisprudential imperatives: the State’s freedom of contract as a commercial entity and the State’s constitutional obligation to act fairly, reasonably, and without arbitrariness under Article 14 of the Constitution. Within this complex legal matrix, the question of locus standi—the right to bring a legal action—assumes paramount importance. Specifically, the standing of disqualified bidders, who have been removed at the technical or preliminary stage, to subsequently challenge the qualification of the successful bidder (L1) or the award of the contract itself is a subject of intense judicial debate.

The evolution of Indian administrative law has seen a oscillation between strict judicial restraint and active intervention. The modern position, crystallized through decades of Supreme Court rulings, generally posits that a disqualified bidder, having been validly removed from the “zone of consideration,” loses the locus standi to question the eligibility of the remaining participants. The courts have frequently characterized such litigants as “strangers” to the subsequent stages of the tender process, applying the “clean hands” doctrine and the principle that writ jurisdiction is not a tool for settling commercial rivalries or engaging in a “dog in the manger” policy. However, this exclusionary rule is not absolute. It is punctured by significant exceptions grounded in the “Public Trust Doctrine,” the prevention of mala fides, and the necessity of ensuring a level playing field.

This report provides an exhaustive analysis of the legal principles governing the locus standi of disqualified bidders. It synthesizes the ratio decidendi of landmark judgments, examines the nuances of “essential” versus “ancillary” tender conditions, and explores the emerging jurisprudence regarding “tailor-made” criteria and digital disqualifications in the era of e-tendering.

1.1 The Theoretical Framework: Contractual Autonomy vs. Public Accountability

Government contracts, unlike private commercial agreements, are not immune to judicial review. While the government retains the commercial freedom to choose its contracting partners, this freedom is circumscribed by the “public law” element inherent in state actions. The Supreme Court of India, in a catena of judgments starting from Ramana Dayaram Shetty v. International Airport Authority of India to Tata Cellular v. Union of India [1], has established that the State cannot act like a private individual who is free to pack their cards with whom they please. The State’s action must be in conformity with some principle which meets the test of reason and relevance.

However, the power of judicial review is not an appellate power. The court reviews the “decision-making process” rather than the “decision” itself. This distinction is critical in determining locus standi. If the process of disqualifying a petitioner was lawful, fair, and in accordance with the tender terms, the courts are generally reluctant to allow that petitioner to then act as a “super-auditor” of the successful bidder’s credentials. The rationale is that a party who fails to cross the threshold of eligibility has no vested interest in the outcome of the financial bid or the final award. [3]

1.2 The Concept of “Aggrieved Person” in Tender Jurisprudence

The threshold requirement for maintaining a writ petition under Article 226 is that the petitioner must be an “aggrieved person.” The definition of this term has evolved significantly. In the context of tenders, an aggrieved person is typically one who was eligible to bid, participated in the process, and suffered an injury due to arbitrary rejection or unfair consideration.

The Supreme Court in Jasbhai Motibhai Desai v. Roshan Kumar [5] provided a definitive classification of litigants, which remains the bedrock of locus standi analysis in tender matters, covering the rights and limitations of disqualified bidders.

1. Person Aggrieved: A person whose legal rights have been infringed or who has suffered a legal wrong or injury. In the tender context, this includes a bidder whose bid was wrongly rejected or who was denied the contract despite being the lowest responsive bidder.
2. Stranger: A person who may have a theoretical interest or a grievance in common with the rest of the public but has suffered no specific legal injury. A disqualified bidder is often relegated to this category regarding the qualification of the L1 bidder. [1]
3. Busybody or Meddlesome Interloper: A person who interferes in matters that do not concern them, often masquerading as a crusader for justice. Courts have been increasingly vigilant against “proxy litigation” where a disqualified bidder uses a third party or a “public interest” mask to stall a project. [1]

The classification is dynamic. A bidder is an “aggrieved person” regarding their own disqualification. However, once that disqualification is upheld by the court or deemed valid, their status shifts. They effectively become a “stranger” to the contract between the State and the successful bidder, stripping them of the standing to challenge the L1 bidder’s eligibility. [3]

II. The Doctrine of Exclusion: The “Stranger” to the Contract

The dominant judicial view in India operates on a doctrine of exclusion for disqualified bidders, reflecting that once a participant is ineligible, they generally have no locus standi to contest the remaining process. Whether the contract goes to L1, L2, or is retendered is legally irrelevant to a party already excluded.

2.1 The “Zone of Consideration” and the “Tumble Down” Theory

The “Zone of Consideration” refers to the pool of valid, technically responsive bids that move to the financial evaluation stage. Courts have consistently held that only those within this zone have the locus to challenge the inter-se ranking or eligibility of other participants.

In Mahalakshmi Engineering Works v. Bangalore Electricity Supply Company Limited [6], the Karnataka High Court, relying on Supreme Court precedents, held that “only a participant can question the tender.” The court utilized the “Tumble Down” theory: if the challenge is raised by petitioners who are not participants (or are validly disqualified), the challenge “would thus tumble down.” This was reiterated in the Calcutta High Court’s decision in Praxair India Private Limited, where it was held that a party who did not even put in a bid, or whose bid was rejected, has no locus standi to challenge the tender process. [6]

The rationale is pragmatic. If disqualified bidders were allowed to challenge the L1 bidder, and the L1 bidder were also disqualified, the benefit would flow to the L2 bidder, not the petitioner. Writ jurisdiction is discretionary and equitable; courts generally do not issue writs that are futile for the petitioner. As observed in Surendra Infrastructure Pvt. Ltd. v. The State of Maharashtra [4], once the court upholds the petitioner’s disqualification, the party loses locus standi, meaning “a bidder who has been disqualified cannot question the qualification of other bidders,” and any judicial relief for such a party is misplaced.

2.2 The Precedent of Raunaq International

The cornerstone of the exclusionary rule is the Supreme Court’s judgment in Raunaq International Ltd. v. I.V.R. Construction Ltd..1 In this case, I.V.R. Construction challenged the award of a contract to Raunaq International, alleging that Raunaq did not strictly meet the eligibility criteria. However, I.V.R. Construction itself did not possess the requisite experience qualification.

The Supreme Court delivered a firm rebuke to such challenges, laying down a principle that is frequently invoked to deny locus standi to disqualified bidders:

“We fail to see how the award of tender can be stayed at the instance of a party which does not fulfill the requisite criteria itself and whose offer is higher than the offer which has been accepted. It is also obvious that by stopping the performance of the contract… there is a heavy financial burden on the public exchequer.” [3]

The Court emphasized that the relaxation granted to Raunaq International was permissible under the tender terms and was based on valid principles. More importantly, the challenger (I.V.R.) had no standing to complain about relaxation when they themselves were ineligible. This established the “Raunaq Barrier”: a disqualified or ineligible bidder cannot act as a champion of strict compliance for others while failing to meet the standards themselves.

2.3 The “Dog in the Manger” Policy and Proxy Litigation

Judicial intolerance for “Dog in the Manger” tactics—where a disqualified entity seeks to stall a project merely because they cannot secure it—is evident in recent judgments. The courts view such litigation as an abuse of process, often driven by corporate rivalry rather than genuine legal grievance.

In a 2025 judgment by the Bombay High Court [1], the court dealt with a PIL filed by a political functionary challenging a tender process. The court dismissed the petition, characterizing the petitioner as a “meddlesome interloper” and noting the “stark reality” that unsuccessful parties or non-participants often approach the court to derail projects. The judgment reinforced that a “stranger” to the commercial transaction has no locus to question the award unless “substantial and demonstrable public interest” is established. The court further noted that such petitioners often “masquerade as seekers of justice” but are actually motivated by “extraneous considerations” or “cheap publicity”. [1]

This judicial stance serves a dual purpose: it clears the docket of frivolous commercial litigation and protects infrastructure projects from costly delays caused by disgruntled competitors who have no realistic chance of winning the contract.

III. The Exceptions: Restoring Locus Standi

While the general rule is exclusion, the jurisprudence of Article 226 is broad enough to accommodate exceptions where the exclusion of a bidder or the qualification of L1 strikes at the very root of the “Rule of Law.” A disqualified bidder may regain locus standi if they can demonstrate that the process itself was vitiated by fraud, mala fides, or gross arbitrariness that violates Article 14.

3.1 Assessing Mala Fides and “Tailor-Made” Conditions

One of the strongest grounds on which a disqualified bidder may still invoke locus standi to challenge the tender process—including the qualification of the L1 bidder—is by alleging that the tender conditions were deliberately “tailor-made” to favour a particular entity. This argument proceeds on the premise that the petitioner’s disqualification was pre-ordained, as the eligibility criteria were structured through a process of “reverse engineering” to ensure the selection of the L1 bidder.[8]

In Michigan Rubber (India) Limited v. State of Karnataka [9], the Supreme Court acknowledged that while the State has “free play in the joints” to set terms, courts will intervene if the action of the tendering authority is found to be “malicious and a misuse of its statutory powers” or if the conditions are “tailor-made to suit a person/entity.”

Where a disqualified bidder is able to establish that an eligibility requirement—such as an artificially inflated turnover threshold, a proprietary technology clause, or an unjustified geographic restriction—bears no rational nexus to the object of the contract and was introduced solely to exclude competition while accommodating the L1 bidder, the bar on locus standi is lifted. In such cases, the challenge is not directed against the successful bidder as such, but against the legality of the tender framework itself. As noted in Global Energy Ltd. v. Adani Exports Ltd. (in the context of tailor-made conditions), tender stipulations must satisfy the test of fairness and reasonableness. Once a tailor-made condition is established, the petitioner’s disqualification is rendered void ab initio, having been founded on an illegal and arbitrary criterion.[10]

3.2 The Argument of Unequal Treatment and Article 14

The “Level Playing Field” argument allows a disqualified bidder to challenge the qualification of L1 if they can show discriminatory application of the same tender conditions. This is not a challenge to the merits of L1, but to the arbitrariness of the authority.

A landmark illustration of this exception is the recent BCCL Case (2024).[11] In this case, the appellant (BCPL) was disqualified for a technical defect regarding the format/timing of a Power of Attorney. However, the successful bidder (Respondent No. 8) was allowed to rectify a similar or even more significant lapse regarding mandatory documents. The High Court had dismissed BCPL’s petition, but the Supreme Court intervened.

The Supreme Court held that accepting the L1 bid despite the absence of mandatory documents while rejecting the appellant’s bid for a technicality violated the principles of fairness and transparency. The Court noted:

“The decision of the Government and its instrumentalities must not only be tested by the application of the Wednesbury principle of reasonableness but also must be free from arbitrariness… The right to equality under Article 14 abhors arbitrariness.” [11]

This judgment confirms that a disqualified bidder does have locus standi to challenge the L1 bidder if they can prove that the authority applied a “double standard”—being hyper-technical with the petitioner while being lenient with the favored bidder. The standing arises from the violation of the constitutional right to equality, not from the commercial interest in the contract.

3.3 Substantial Public Interest: The “Raunaq” Exception

Even Raunaq International, which established the exclusionary rule, carved out a specific exception for “substantial public interest.” The Court held that judicial intervention is warranted if “substantial public interest is involved”.[1]

For a disqualified bidder to invoke this, they must demonstrate that awarding the contract to L1 would cause significant harm to the public exchequer or safety. Examples include:

• Price Disparity: If the disqualified bidder’s price (if opened inadvertently or known) is vastly lower than L1’s, courts may examine the validity of the disqualification more closely to prevent loss of public money. [7] However, mere price difference is not enough; the disqualification must be legally questionable.
• Incompetence/Ineligibility: If the L1 bidder notoriously lacks the capacity to perform (e.g., is blacklisted or insolvent), a disqualified bidder may be granted standing as a whistleblower in the public interest.

In Air India Ltd. v. Cochin International Airport Ltd. [2], the Supreme Court reiterated that the State can choose its own method to arrive at a decision, but that decision must be in the public interest. If a disqualified bidder can show that the award to L1 is a “fraud on the public,” the court’s doors are open.

3.4 Statutory Violations

Standing is also more readily recognized when the disqualification or the award violates a specific statute. For instance, if a tender is governed by the MSME Act, and a disqualified MSME bidder challenges the award to a non-MSME L1 on the grounds that purchase preference rules were ignored, the court will likely entertain the petition. The violation of a statutory mandate (like the Tamil Nadu Transparency in Tenders Act or CVC Guidelines) provides a stronger footing than a mere breach of tender conditions. [12]

IV. The Infrastructure Shield: Recent Judicial Trends (2023-2025)

The most significant recent development in this field is the hardening of judicial attitude against interfering in infrastructure projects. The enactment of the Specific Relief (Amendment) Act, 2018, and the Supreme Court’s judgment in N.G. Projects Limited v. Vinod Kumar Jain (2022) have created a formidable shield around L1 bidders in infrastructure sectors.

4.1 The N.G. Projects Paradigm

In N.G. Projects Limited, the Supreme Court dealt with a challenge where the High Court had interfered with a tender for road construction. The Supreme Court reversed the High Court, laying down strict guidelines [3]:

1. Legislative Intent: The Court cited Section 20A and Section 41(ha) of the Specific Relief Act, which prohibit injunctions that would delay infrastructure projects.
2. Judicial Restraint: The Court held that the High Court should “hold its hand” and not stay the construction of infrastructure projects merely because of a technical irregularity.
3. Expertise: The Court reiterated that it lacks the expertise to examine the technical terms of economic activities.
4. Remedy in Damages: The Court suggested that if a party is wrongly excluded, their remedy might lie in seeking damages rather than stalling the project.

This judgment is now routinely cited by High Courts [3] to deny relief to disqualified bidders. In N.G. Projects, the Court explicitly stated that even if there is a technical non-compliance by the L1 bidder, if the authority has accepted it, the court should not interfere unless the decision is totally arbitrary or perverse. This significantly raises the bar for locus standi; a disqualified bidder effectively has to prove “perversity,” not just “illegality.”

4.2 Application in High Courts (2024-2025)

The impact of N.G. Projects is visible in recent High Court decisions.

• Bombay High Court (2024): In a challenge regarding canal restoration, the court cited N.G. Projects to dismiss a petition by a disqualified bidder who questioned the L1’s eligibility. The court held that “small aberrations here and there may be ignored by the employer” and that the petitioner, having been disqualified, could not obstruct the process.[3]
• Sikkim High Court: Similarly, in a case involving road construction, the court cited N.G. Projects to hold that the writ court should refrain from imposing its decision over the employer’s decision to accept a bid. [14]
• Delhi High Court (2025): In National Highways Authority of India matters, the court, while acknowledging the N.G. Projects limitation, still examined whether the action was “arbitrary and capricious.” This indicates that while the “shield” is strong, it is not impenetrable if gross injustice is visible. [15]

V. Procedural Complexities: Challenges in the Digital Age

The shift to e-procurement through platforms like the Government e-Marketplace (GeM) and NIC portals has introduced new dimensions to locus standi for disqualified bidders.

5.1 Digital Disqualifications and “System Error” Defenses

In the digital era, disqualification is often automated. Bidders are rejected for failing to upload documents in specific formats, missing digital signatures, or IP address conflicts.

• The “Digital Signature” Case: In a Bombay High Court case , a bidder was disqualified for absence of a digital signature and failure to submit IP address proof. The petitioner argued these were “curable defects.” The court, however, tended to support strict compliance in e-tenders to maintain the integrity of the digital trail. A disqualified bidder in such cases often struggles to challenge the L1, as the court views the “system’s” rejection as objective and non-discriminatory.[3]
• GeM Portal Suspensions: In M/s Baijnath Agrawal v. State of Chhattisgarh (2025) [16], the court dealt with a bidder suspended by the GeM portal automated logic. The court examined whether the automated suspension (due to dues owed to the portal) could validly disqualify a bidder who was otherwise L1. This highlights a new area of litigation: challenging the algorithm or portal rules rather than the human discretion of the tender committee.

5.2 The “Author of the Document” Rule and Silppi Constructions

The Supreme Court in Silppi Constructions Contractors v. Union of India [13] reinforced the principle that the authority floating the tender is the “best judge” of its requirements.

• Interpretation: If the tender authority interprets a digital submission requirement as “essential” (leading to disqualification) or “ancillary” (allowing L1 to cure it), the court must defer to that interpretation.
• Impact on Locus: This rule makes it extremely difficult for a disqualified bidder to argue that the L1 should have been disqualified for a similar digital glitch. If the authority says the L1’s glitch was minor but the petitioner’s was major, the court will typically defer to the authority’s view, invoking Silppi. [13]

VI. Comparative Data and Analytical Synthesis

To provide a structured overview of how different legal defects impact locus standi for disqualified bidders, the following table synthesizes the relevant case law analyzed.

Table 1: Matrix of Grounds for Challenge and Probability of Standing

6.1 The Economic Logic of Exclusion

A third-order insight derived from the Raunaq and N.G. Projects line of cases is the judiciary’s implicit adoption of “Law and Economics” principles. The courts have recognized that the “cost of justice” (procedural perfection) often outweighs the “benefit” in tender matters.

• Cost Escalation: A stay order on a ₹500 crore highway project for 6 months due to a writ petition can cost the exchequer ₹50-100 crores in escalation and lost utility.
• Shadow Pricing: If disqualified bidders are given easy standing, they can engage in “greenmail”—using litigation to force the successful bidder to offer them sub-contracts or settlements to withdraw the case. The strict locus standi rules act as a barrier against this rent-seeking behavior. [3]
• Fait Accompli: In National Highways Authority of India v. Ganga Enterprises [18], the court dealt with the practical difficulty of unwinding contracts. Once the “egg is scrambled” (contract signed, work started), the remedy of certiorari becomes practically absolutely, leaving the petitioner with only a theoretical right to damages.

VII. Conclusion: The “Lakshman Rekha” of Judicial Review

The locus standi of disqualified bidders to challenge the qualification of a successful bidder is governed by a high threshold of admissibility. The Indian courts have drawn a “Lakshman Rekha” (a strict boundary) around the commercial wisdom of the State, protecting it from the interference of disgruntled competitors who fail to meet the eligibility mark.

The General Rule is Exclusion:

In public procurement, the locus standi of a bidder disqualified at the technical stage is governed by a high threshold of admissibility. Indian courts have drawn a “Lakshman Rekha” (a strict boundary) around the commercial wisdom of the State, safeguarding it from challenges by competitors who fail to meet eligibility criteria. A bidder excluded at this stage is treated as a “stranger” to the subsequent commercial transaction between the State and the successful L1 participant. Under the principles established in Raunaq International and Mahalakshmi Engineering, such a bidder generally has no standing to question either the relaxation of terms or the eligibility of the awardee. The courts consistently prioritize the finality of the tender process and the broader public interest over the grievances of ineligible participants.

The Exceptions are Narrow but Vital:

The exclusionary rule is not a shield for corruption or gross arbitrariness. A disqualified bidder regains the status of an “aggrieved person” and locus standi if they can demonstrate:

1. Discriminatory Treatment: That the authority applied different yardsticks to the petitioner and the L1 bidder (BCCL Case).
2. Malice in Fact or Law: That the conditions were “tailor-made” to exclude competition (Michigan Rubber).
3. Statutory Illegality: That the award violates a legislative mandate.
4. Overwhelming Public Interest: That the award is a fraud on the public exchequer.

Future Outlook:

The trajectory of judicial decisions between 2023 and 2025, particularly the continued reliance on N.G. Projects, reflects a marked tightening of judicial norms in infrastructure-related tenders. Courts are increasingly adopting a restrained, “hands-off” approach, treating technical and commercial disputes as matters better addressed through claims for damages rather than injunctive relief. In this evolving landscape, a disqualified bidder can establish locus standi only by demonstrating more than mere non-compliance by the L1 bidder; the challenge must be anchored in allegations of systemic unfairness or constitutional impropriety attributable to the State. The contest is no longer about comparative documentation, but about whether the referee abandoned neutrality and distorted the rules of the game.

References

[1] BCCL Case (2024) – Bombay High Court. Illustrates discriminatory treatment and Article 14 violation in tender processes. Available at : https://bombayhighcourt.nic.in/generatenewauth.php

[2] Silppi Constructions v. Union of India Available at : https://api.sci.gov.in/supremecourt/2019/21059/21059_2019_4_22_14619_Judgement_21-Jun-2019.pdf

[3] IN THE HIGH COURT OF JUDICATURE AT BOMBAY BENCH AT AURANGABAD WRIT PETITION NO. 8525 OF 2024 M/s. Surendra Infrastructure (P) Lt, accessed on December 12, 2025, Available at: https://bombayhighcourt.nic.in/generatepdf.php

[4] M/s. Surendra Infrastructure (p) Ltd v. The State Of Maharashtra And Ors – LegitQuest, accessed on December 12, 2025, Available at: https://www.legitquest.com/case/ms-surendra-infrastructure-p-ltd-v-the-state-of-maharashtra-and-ors/7AE9B0 

[5] IN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPELLATE JURISDICTION WRIT PETITION NO.867 OF 2024 Hemant Ashar …Petitioner V, accessed on December 12, 2025, Available at: https://bombayhighcourt.nic.in/generatenewauth.php

[6] IN THE HIGH COURT AT CALCUTTA, accessed on December 12, 2025, Available at: https://calcuttahighcourt.gov.in/Show-Judgment-File/2023~mat_878_e.pdf

[7] Gichik Tami v. The State of AP and 7 Ors | Gauhati High Court | Judgment | Law – CaseMine, accessed on December 12, 2025, Available at: https://www.casemine.com/judgement/in/67038c59018d6858b9e948f4

[8] Neutral Citation No. – 2024:AHC:30429-DB A.F.R Reserved on 28.11.2023 Delivered on 21.02.2024 Case :- Writ C No. 26784 of 2023 – Available at: eLegalix, accessed on December 12, 2025, https://elegalix.allahabadhighcourt.in/elegalix/WebDownloadOriginalHCJudgmentDocument.do?translatedJudgmentID=5850

[9] REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NOS. 6615-6616 OF 2022 Airport Authority of I, accessed on December 12, 2025, https://api.sci.gov.in/supremecourt/2021/25000/25000_2021_7_1503_38707_Judgement_30-Sep-2022.pdf

[10] REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPEAL NOs.4862-4863 OF 2021 UFLEX LTD. … Appellant Versus GOVERNMENT OF TAMIL, accessed on December 12, 2025, https://api.sci.gov.in/supremecourt/2021/12246/12246_2021_36_1501_30124_Judgement_17-Sep-2021.pdf

[11]  REPORTABLE IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 11005 OF 2024 (@ SPECIAL LEAVE PETITION, accessed on December 12, 2025, https://api.sci.gov.in/supremecourt/2024/33783/33783_2024_13_1501_56307_Judgement_04-Oct-2024.pdf

[12] P. Ravishankar v. State Of Tamil Nadu … | Madras High Court | Judgment | Law – CaseMine, accessed on December 12, 2025, https://www.casemine.com/judgement/in/61a47bea9fca193d1e428075

[13] IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 1846 OF 2022 (ARISING OUT OF SLP (CIVIL) NO. 2103 OF, accessed on December 12, 2025, https://api.sci.gov.in/supremecourt/2022/3680/3680_2022_41_1501_34222_Judgement_21-Mar-2022.pdf

[14] GANGTOK (Civil Extra Ordinary Jurisdiction) W.P. (C) No. 34 of 2022 1. Mr. Sonam Tsewang Bhutia, S/o – THE HIGH COURT OF SIKKIM, accessed on December 12, 2025, https://hcs.gov.in/hcs/hg_orders/201100000342022_7.pdf

[15] 17-10-2025 (txt) – Delhi High Court, accessed on December 12, 2025, https://delhihighcourt.nic.in/app/showFileJudgment/59417102025CW131762025_180747.txt

[16] TENDER+DISQUALIFICATION | Indian Case Law – CaseMine, accessed on December 12, 2025, https://www.casemine.com/search/in/TENDER%2BDISQUALIFICATION

[17] writ+petition+is+maintainable | Indian Case Law – CaseMine, accessed on December 12, 2025, https://www.casemine.com/search/in/writ%2Bpetition%2Bis%2Bmaintainable

[18] $~ * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 13th October, 2025 + CS(COMM) 16/2016 M/S SIMPLEX, accessed on December 12, 2025, https://delhihighcourt.nic.in/app/showFileJudgment/JIS13102025SC162016_232134.pdf

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