TRANSRAIL LOGISTICS LIMITED  Vs OIL AND NATURAL GAS CORPORATION LTD.

W.P.(C) 6827/2018 & 7393/2018 Page 1
* IN THE HIGH COURT OF DELHI AT NEW DELHI
Reserved on: 23.11.2020
Date of decision : 07.01.2021

+ W.P.(C) 6827/2018 & CM No.25959/2018

+ W.P.(C) 7393/2018 & CM No.28265/2018

CJ DARCL LOGISTICS LIMITED ….. Petitioner
TRANSRAI L LOGISTICS LIMITED …..Petitioner

Through Mr.Anil Goel, Mr.Manu Beri, Advs.

versus

OIL AND NATURAL GAS CORPORATION LIMITED
…..Respondent

Through Mr.Sandeep Sethi, Sr. Adv. with
Mr.Varun Mishra, Adv.

CORAM:
HON’BLE MR. JUSTICE NAVIN CHAWLA
1. These petitions have been filed by the petitioners challenging the
Communication dated 06.06.2018 of the respondent by which the
petitioners were banned by the respondent from all business dealings
with it, for a period of six months. Th e petitioners furth er challenge the
communication dated 19.06.2018 by which their representation against
the abovementioned banning order ha d been rejec ted. The petitioners also
pray for refund of the amount of security/earnest money deposit forfeited
by the respondent.
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2. The respond ent by Notice I nviting Tender , dated 15.09.2017 ,
invited quotation for Rate Contract for Hiring of
Services for All India Material Transportation through Trucks
and Trailers . The said tender was divided into 8 groups -4 groups for
Trailer segment and 4 groups for Truck segment and the petitioner in
W.P.(C) 6827/2018 had participated in all 8 segments, while its
subsidiary company, that is petitioner in W.P.(C) 7393/2018 , had
participated in 4 groups of trailer segment only . The price bids were
opened by the respondent on 05.03.2018, however, the price bids of the
petitioners were not opened and considered by the respondent . By a letter
dated 16.03.2018 , received from the Silchar office of the respondent in
relation to another tender, the petitioner s were informed that their price
bids w ere not opened in view of the banning proceedings initiated against
the petitioners in respect to the tender in question before this Court. By
another communication dated 26.03.2018 , the petitioners were informed
that their bids in the tender in question had been rejected for violation of
the Integrity Pact . The bank guaran tees submitted by the petitioner s as
security deposit/EMD w ere also invoked and forfeited by the respondent
and the same was informed to the petitio ners on 27.03.2018. The
respondent thereafter issued a Show Cause Notice dated 09.04.2018 to
the petitioner s alleging violation of Section 2 of the Integrity Pact . After
considering the reply submitted by the petitioners, the Impugned Order
banning the pet itioners was passed by the respondent and thereafter their
representation against the same was rejected by the Impugned Order
dated 19.06.2018. As noted hereinabove, these communications have
been challenged by the petitioners in the present set of petitio ns.
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3. The learned counsel for the petitioners has submitted that the fact
that the two petitioners are related to each other as holding company and
wholly owned subsidiary company was in full knowledge of the
respondent and , therefore, there was no conce alment of this fact by the
petitioners. He further submits that Section 2 of the Integrity Pact was
amended by the respondent vide its circular dated 04.10.2016. The
restriction on the holding of the subsidiary company participating in the
tender was done away with by such amendment. Therefore, in his
submission, the petitioners could not be held to have violated t he
Integrity Pact merely because of their relationship with each other. He
further submits that merely because Mr. Pradeep Bansal has been
author ized by both the petitioners for administrative convenience and Mr.
Pradeep Bansal in turn authorized Mr. Narendra Sharma to submit the bid
on behalf of the petitioner, CJ Darc l, it could not be said that bids have
been submitted by the petitioners in coll usion with each other.
4. He further submits that in any case, in terms of Clause 2 of Section
3 of the Integrity Pact , it is only where the transgression by the tenderer is
proved beyond a reasonable doubt that the banning order would be
justified . He su bmits that in the present case, the Impugned Order passed
by the respondent does not record such satisfaction and infact , proceed s
on assumption rather than proof beyond doubt as is required under the
Integrity Pact .
5. The learned counsel for the petitio ners further submits that the
report of the purported enquiry or the decision of the Tender Committee
2021:DHC:54
W.P.(C) 6827/2018 & 7393/2018 Page 4
was not supplied to the petitioner s, thereby violating the Principle of
Natural Justice.
6. The learned counsel for the petitioners further submits that the
Impugned Order even otherwise is passed in violation of Principle of
Natural Justice inasmuch as the Show Cause Notice was issued on an
enquiry conducted by Mr. D.P Singh DGM, (Mechanical) P&E,
Corporate M.M , while the Impugned Banning Order has been p assed by
Mr. Ashwini Nagia , E.D -Chief MM. He submits that therefore, the
authority granting an opportunity of hearing to the petitioners has not
passed the order thereby violating the Principles of Natural Justice.
7. As far as the invocation and forfeitur e of the bank guarantee is
concerned, the learned counsel for the petitioners submi ts that in terms of
Clause 16.7 of the tender document and Section 3 of the Integrity Pact ,
the respondent was entitled to “demand and recover ” from the petitioners
liquidat ed damages equivalent to the EMD/bid security and not forfeit the
EMD. The respondent, however, without any prior demand being made
to the petitioners , went ahead and encashed the bank guarantee. He
submits that in terms of Section 4 of Integrity Pact , the petitioners were
entitled to prove and establish that no loss was suffered by the respondent
because of the acts of the petitioners and in that event , even the
respondent is obliged to refund the amount so forfeited. In the present
case, the petitioners h ave asserted in the petitions that no such loss was
caused to the respondent as there was no delay in finalization of the
tender and the work of the tender was duly awarded to a third party. The
respondent has not denied such assertion in its counter affid avit,
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therefore, the petitioners are entitled to refund of the amount that was
forfeited.
8. On the other hand , the learned senior counsel for the respondent
has submitted that this Court, in exercise of its power of judicial review
under Article 226 of t he Constitution of India does not act as an
Appellate Court to review the decision of the respondent -authority on
merits. He submits that the amendment to the Section 2 of the Integrity
Pact will have no effect on the allegations made against the petitione rs.
He submits that Section 2 of the Integrity Pact was amended to make it
more liberal and for authorizing the participation of parent and subsidiary
company in the same tender. In the present case , the Impugned Action
has been taken against the petitione rs not because they have a
relationship of parent/subsidiary company , but because it was concluded
that their bids were collusive in nature and therefore restrict ed
competitiveness and introduced cartelization in the business. He submits
that in the presen t case the bids for the two petitioners were infact
submitted by one person alone, with one directly under his signature and
the other through his power of attorney.
9. As far as the submissions of the petitioners on Section 3 of the
Integrity Pact are concerned, the learned senior counsel for the
respondent submits that from the circumstances on record , there was no
doubt on the violation of the Integrity Pact by the petitioners. He submits
that Section 3 of the Integrity Pact has to be read in a reasonab le manner
and not in a manner as suggested by the learned counsel for the
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petitioners , putting the onus of beyond reasonable doubt on the
respondent.
10. On the issue of forfeiture of the bid security/EMD amount , the
learned senior counsel for the respond ent submits that in the present case
the Contract was yet to be entered into between the petitioners and the
respondent and the forfeiture was at the stage of the bid itself. Placing
reliance on the Judgment of the Supreme Court in Kailash Nath
Associates vs. Delhi Development Authority and Anr. , (2015 ) 4 SCC
136, he submits that Section 74 of the Indian Contract Act would not be
attracted to the forfeiture of the EMD at the pre-contract stage. He also
places reliance on the judgment of the Supreme Court in Villayati Ram
Mittal (P) Ltd. v. Union of India and Anr. , (2010) 10 SCC 532 in
support of his above submission.
11. As far as the submission of the petitioners r egarding suppl ying the
copy of the report of the Tender Committee is concerned, he submits th at
the same had no prejudicial effect on the petitioners and therefore , cannot
be a ground for interfering with the banning order.
12. As far as the submission of the petitioners that the authority
granting an opportunity of hearing has not passed the orde r thereafter , he
submits that under Clause 17.5.2 of the “Integrated Material Management
Manual ” of the respondent provides that upon obtaining approval from
the concerned Director for initiating banning process against the erring
firm, an enquiry officer is appointed by the concerned Director for
conducting the enquiry proceedings . The enquiry officer then issues a
Show Cause Notice to the erring firm bring ing out allegations and
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W.P.(C) 6827/2018 & 7393/2018 Page 7
seeking its response. The enquiry officer then submits his report t o the
Key Executive of the work centre alongwith his recommendation s. The
Key Executive refers the case for obtaining approval of the Committee of
Directors and on obtaining such approval, the Key Executive issues the
order for banning the firm . In the present case , the Key Executive of the
work center was Mr. Ashwini Nagia , E.D -Chief MM, who after obtain ing
the approval of the Committee of Directors , issued the Impugned
Banning Order. He submits that therefore, there was no violation of
Principle of Natural Justice nor the procedure as prescribed was violated
in any manner.
13. I have considered the submission made by the learned counsels for
the parties.
14. As much arguments have been made on the provisions of the
Integrity Pact pre and post its amendment, the sam e are quoted
hereinbelow: –
Existing Provisions Modified provisions
Section -2
Commitments of the
Bidder/contractor Para (1) -2
The Bidder / Contractor will
not enter with other Bidders
into any undisclosed
agreement or understanding,
whether formal or infor mal.
This applies in particular to
prices, specifications,
certifications, subsidiary Section -2
Commitments of the
Bidder/contractor
Para (1) -2
The Bidder/Contractor will not
enter with other Bidders into
any undisclosed agreement or
understanding, whether formal
or informal. This applies in
particular to prices,
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W.P.(C) 6827/2018 & 7393/2018 Page 8
contract, submission or non –
submission of bids or any
other actions to restrict
competitiveness or to
introduce cartelization in the
bidding process. Further, no
bidder s hould have a conflict
of interest that effects the
tender/bidding process, in any
of the following manner:
(i) such Bidder (or any
constituent thereof) and
any other Bidder (or any
constituent thereof) have
common controlling
shareholders or other
ownership in terest;
provided that this
qualification shall not
apply in cases where the
direct or indirect
shareholding in a Bidder
or a constituent (thereof in
the other Bidder(s) (or any
of its constituents) is less
than 1% of its paid up and
subscribed capital; or
(ii) a Constituent of such
Bidder is also a constituent
of another Bidder; or
(iii) such Bidder receives or
has received any direct or
indirect subsidy from any
other Bidder, or has
provided any such subsidy
to any other bidder; or specifications, certifications,
subsidiary contracts,
submission or non -submission
of bids or any other actions to
restrict competitiveness or to
introduce cartelization in the
bidding process.
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(iv) such Bidder has the same
legal r epresentative for
purposes of this Bid as any
other Bidder; or
(v) such Bidder has a
relationship with another
Bidder, directly or through
common third parties, that
puts them, in a position to
have access to each
other’s information about,
or to influence the Bid of
either/or each of the other
Bidder; or
(vi) such Bidder has
participated a s a
consultant to the
authority in the
preparation of any
documents, design or
technical specifications of
the project.

15. As noted hereinabove, the petitioner has based its claim on the
deletion of Clauses (i) and (iv) in the amended Integrity Pact to submit
that the relationship of a holding and subsidiary company or same legal
representative of the two companies is no longer a bar to participate in
the bid. I am, however, unable to agree to the above submission. The pre –
amended Integrity Pact prohibited the bidd ers from entering into any
undisclosed Agreement or understanding, whether formal or informal.
The same has been retained even in the amended Integrity Pact. The pre –
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amended Integrity Pact in addition spells out the circumstances of a
bidder having conflic t of interest that affects the tender/bidding process.
Though this part has been deleted from the amended Integrity Pact, it
does not affect the operation of the first part which prohibits the
bidder/Contractor from entering into any undisclosed Agreement or
understanding.
16. The Supreme Court, in Afcons Infrastructure Limited v. Nagpur
Metro Rail Corporation, 2016 (16) SCC 818 , has held that “the owner or
the employer of a project, having authored the tender documents, is the
best person to understand an d appreciate its requirement and interpret its
documents. The constitutional courts must defer to this understanding
and appreciation of the tender documents, unless there is mala fide or
perversity in the understanding or appreciation or in the applicatio n of the
terms of the tender conditions. It is possible that the owner or employer
of a project may give an interpretation to the tender documents that is not
acceptable to the constitutional courts but that by itself is not a reason for
interfering with t he interpretation given”. Applying the above test, no
perversity is found in the interpretation put by the respondent to the terms
of the Integrity Pact.
17. Even otherwise, in Patel Engineering Limited v. Union of India &
Anr., (2012) 11 SCC 257, and in Khulja Industries Limited v. Chief
General Manager, Western Telecom Project Bharat Sanchar Nigam
Limited & Ors., (2014) 14 SCC 731 , it has been held by the Supreme
Court that the power to blacklist a contractor whether the contract be for
supply of material or equipment or for the execution of any other work
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whatsoever, inherent in the party allotting the contract. There is no need
for any such power being specifically conferred by statute or reserved by
contract.
18. In the present case, the respondent has come to a conclusion that
because the bids that were submitted by the petitioners were submitted by
Mr. Pradeep Bansal; one under his own signatures for Transrail and the
second through his Power of Attorney holder – Mr. Narendra Sharma , for
CJ Darcl, the b ids were designed and coordinated by the same person
thereby violating the provisions of Integrity Pact. The respondent has not
invoked the provision as is contained in the amended Integrity Pact for
proceeding against the petitioners only because of their relationship as
holding and subsidiary company. No fault can be found with the above
finding of the respondent.
19. The petitioners have further placed reliance on Section 3(2) of the
Integrity Pact to submit that the test to be applied by the respondent is
one of „no reasonable doubt ‟ in terms of the Integrity Pact which is
almost akin to the test that is applied in a criminal proceeding . Placing
reliance on the language used in the Impugned Order dated 06.06.2018,
the learned counsel for the petitioner s has submitted that in the present
case, the test applied by the respondent is one of probability rather than
of having no reasonable doubt. He has specifically placed reliance on
paragraph 10 of the Impugned Order which is quoted hereinbelow: –
“10. AND WHEREAS, on enquiry, examination of the
case, considering the reply submitted by you and
having given an impartial, prudent and careful
consideration to the facts, ONGC has come to the
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conclusion that the person submitting the bids is in
effect one and sam e i.e. Mr. Pradeep Bansal. In
Transrail, Mr. Pradeep Bansal submitted the bid
himself and in Darcl he indirectly submitted the bid
through his Manager. In the given circumstances, there
is all possibility that commercial terms/rates submitted
by both the bidders were known to each other. Hence, it
is concluded that the bids submitted by you is in
violation of the provisions of I ntegrity Pact.”
(Emphasis supplied)
20. I am unable to agree with the submission made by the learned
counsel for the petitione rs. It is first to be noted that the impugned orders
are not to be read as a Statue; they have to be read in a reasonable
manner. No doubt. in terms of Section 3(2) of the Integrity Pact the test
to be applied is of one beyond any reasonable doubt, it is a lso a matter of
settled law that in cases of conspiracy, where no direct evidence is
available, the conviction can be on based of circumstantial evidence
which has to be read in a reasonable manner as constituting a complete
chain . Reference in this regard may be made to the judgment of the
Supreme Court in State of Andhra Pradesh vs. IBS Prasada Rao and
Others , (1969) 3 SCC 896 where it was held under : –
“7. In regard to the question of the effect and sufficiency
of circumstantial evidence for the purpose of conviction,
it is now settled law that before conviction based solely
on such evidence can be sustained, it must be such as to
be conclusive of the guilt of the accused and must be
incapable of explanation on any hypothesis consistent
with the innocenc e of the accused. But this does not mean
that before the prosecution can succeed in a case resting
upon circumstantial evidence alone, it must meet any and
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every hypothesis suggested by the accused, however
extravagant and fanciful it might be. Before an a ccused
can contend that a particular hypothesis pointing to his
innocence has remained unexcluded by the facts proved
against him, the
Court must be satisfied that the suggested hypothesis is
reasonable and not farfetched. Further, it is not
necessary that every one of the proved facts must in itself
be decisive of the complicity of the accused or point
conclusively to his guilt. It may be that a particular fact
relied upon by the prosecution may not be decisive in
itself, and yet if that fact, along with other facts which
have been proved, tends to strengthen the conclusion of
his guilt, it is relevant and has to be considered. In other
words, when deciding the question of sufficiency, what
the Court has to consider is the total cumulative effect of
all the proved facts each one of which reinforces the
conclusion of guilt, and if the combined effect of all those
facts taken together is conclusive in establishing the guilt
of the accused, the conviction would be justified even
though it may be that any one or more of those facts by
itself is not decisive.”
21. In G.Parshwanath vs. State of Karnataka, (2010) 8 SCC 593, the
Supreme Court reiterated that: –
“….In deciding the sufficiency of the circumstantial
evidence for the purpose of conviction, the court has to
consider the total
cumulative effect of all the proved facts, each one of
which reinforces the conclusion of guilt and if the
combined effect of
all these facts taken together is conclusive in establishing
the guilt of the accused, the conviction w ould be justified
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even though it may be that one or more of these facts by
itself or themselves is/are not decisive”.
22. In the present case, as stated hereinabove, the respondent has based
its conclusion on the circumstantial evidence of the bids being s ubmitted
by the two companies for and on behalf of only one person and there was
no doubt that therefore, the companies knew of the bids submitted by
each other, which is clearly in violation of the Integrity Pact.
23. It is also no longer res integra that testing a case of black listing
like in the present, this Court is primarily concerned with the decision
making process and cannot in exercise of power of judicial review act as
an Appellate Authority to test the decision on merit unless it is found to
be totally arbitrary, whimsical , unreasonable or disproportionate .
Reference in this regard can be made to the judgment of Supreme Court
in Lalit Popli vs. Canara Bank, (2003) 3 SCC 583 and Afcons
Infrastructure (supra) . In the present case, no such case h as been made
by the petitioners to interfere with the Impugned Decision.
24. At this stage I may also note that the submission of the petitioners
that the petitioners had fully disclosed their relationship to the respondent
and therefore, cannot be accuse d of any concealment. I am however, not
persuaded by the said submission. It is to be noted that such disclosure is
in form of an Annual Report of the two companies. Therefore, the
petitioners expect the respondent to scan through the documents
submitted b y them alongwith the bids to discover their relationship rather
than stating it upfront. They have further tried to take shelter behind
answer to a query raised by the respondent regarding their relationship.
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This being post submission of the bid, cannot i n any case come to the aid
of the petitioners.
25. As far as the submission of the petitioners that the Impugned Order
has been passed by the officer who has not granted the hearing to the
petitioners and therefore, is in violation of the principles of n atural
justice, again cannot be accepted. The respondent has placed on record
Clause 17.5.2 of the “Integrated Material Management Manual” which
prescribes the procedure to be followed by the respondent while
undertaking vendor banning. It is not alleged b y the petitioner that the
procedure followed by the respondent in the present case fell foul of the
said laid down procedure.
26. On the non -supply of the copy of the enquiry report to the
petitioner, the same again cannot be a ground to set aside the impu gned
orders debarring the petitioners. No prejudice has been shown to have
been caused to the petitioners by reason of such non -supply. In fact, even
today, there is no dispute on the facts forming basis of the impugned
action of the respondent.
27. On the issue of forfeiture of the earnest money deposit, Section 4
of the Integrity Pact is relevant and is quoted hereinbelow: –
“Section 4
Compensation for Damages
(1) If the Principal has disqualified the Bidder from the
tender process prior to the award acco rding to Section
3, the Principal is entitled to demand and recover from
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the Bidder liquidated damages equivalent to Earnest
Money Deposi t / Bid Security.

(2) If the Principal has terminated the contract
according to Section 3, or if the Principal is enti tled to
terminate the contract according to Section 3, the
principal shall be entitled to demand and recover from
the Contractor liquidated damages equivalent to
Security Deposit / Performance Bank Guarantee.
(3) The bidder agrees and undertakes to pay the said
amounts without protest or demur subject only to
condition that if the Bidder / Contractor can prove and
establish that the exclusion of the Bidder from the
tender process or the termination of the contract after
the contract award has caused no dama ge or less
damage than the amount of the liquidated damages, the
Bidder / Contractor shall compensate the Principal
only to the extent of the damage in the amount proved. ”
(Emphasis supplied)

28. A reading of the above Section of the Integrity Pact w ould clearly
show that where the bidder is disqualified from the bid due to
transgression of the Integrity Pact, the respondent is entitled to “demand
and recover” from the bidder “liquidated damages” equivalent to earnest
money deposit/bid security. The b idder has to pay the same without
protest subject only to the condition that if the bidder/Contractor can
prove and establish that the exclusion of the bidder from the tender
process has caused no damage or less damage than the amount of the
liquidated dam ages, then the bidder/Contractor shall compensate the
Principal only to the extent of the damage in the amount proved.
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Therefore, on a transgression of the Integrity Pact being found by the
respondent to have been committed by a bidder, the respondent has to
first raise a demand for the liquidated damages equivalent to the earnest
money deposit/bid security. On such demand being raised, the bidder
would be entitled to prove and establish that no loss or loss of a lesser
amount has been caused to the respond ent, in which event either no
amount or lesser amount shall be claimed payable by the bidder.
29. In the present case, the bank guarantee of the petitioners towards
the earnest money deposit was encashed by the respondent without any
notice to the petitio ners. The question therefore is whether the amount so
received can be retained by the respondent in the facts of the present
case. Admittedly, the respondent has not issued any notice to the
petitioner demanding the above amount as liquidated damages. Infa ct, it
is the case of the respondent that the same automatically stood forfeited.
The petitioners have claimed that due to the disqualification of the
petitioner, no loss was caused to the respondent. On the other hand the
respondent claimed that no such l oss is required to be shown. They have
placed reliance on the judgment of the Supreme Court in Kailash Nath
and Associates , (Supra), wherein the Supreme Court has inter alia held
as under: –
“41. It must, however, be pointed out that in cases
where a publi c auction is held, forfeiture of earnest
money may take place even before an agreement is
reached, as DDA is to accept the bid only after the
earnest money is paid. In the present case, under the
terms and conditions of auction, the highest bid (along
with which earnest money has to be paid) may well
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have been rejected. In such cases, Section 74 may not
be attracted on its plain language because it applies
only “when a contract has been broken”.
xxxxxx
43.7 Section 74 will apply to cases of forfeiture of
earnest money under a contract. Where, however,
forfeiture takes place under the terms and conditions of
a public auction before agreement is reached, Section
74 would have no application. ”

30. In the present case, though Section 74 of the Indian Contract A ct,
1872 may not have any application, Section 4 of the Integrity Pact itself
requires a demand to be raised on the earnest money deposit and a right is
created in favour of the bidder to show on such demand that no damage is
suffered by the respondent or that the damage suffered is lesser than the
earnest money deposit, in which case, either no such amount can be
recovered from the bidder or a lesser amount is to be recovered.
31. As noted, the respondent has not denied that no loss was suffered
by the re spondent due to the disqualification of the petitioners from the
bid on account of their transgression of the Integrity Pact. There would
therefore, be no disputed question of fact to be adjudicated. The forfeiture
of the earnest money deposit of the petit ioner, therefore, cannot be
sustained and is ordered to be refunded to the petitioners .
32. Accordingly, while the im pugned orders in so far as they ban the
petitioners from all business dealings with the respondent for a period of
six months are upheld. The respo ndent is however, directed to refund the
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Security Deposit/ Earnest Money Deposits of the pet itioners forfeited by
it, within a period of four weeks of this order.
33. The petition s are disposed of in the above terms.
34. The parties shall bear the ir own costs.

NAVIN CHAWLA, J
JANUARY 07 , 202 1/rv
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