Legal Document View

Unlock Advanced Research with PRISMAI

- Know your Kanoon - Doc Gen Hub - Counter Argument - Case Predict AI - Talk with IK Doc - ...
Upgrade to Premium
[Cites 5, Cited by 0]

Calcutta High Court (Appellete Side)

M/S. Begampur Indane Gramin Vitrak & Ors vs Indian Oil Corporation Limited & Ors on 11 May, 2026

11.05.2026
  ct no. 10
   Sl. 06
    AGM
                               WPA 4012 of 2026
                 M/s. Begampur Indane Gramin Vitrak & Ors.
                                     -Versus-
              Indian Oil Corporation Limited & Ors.

              Mr. Surajit Nath Mitra, Sr. Advocate.
              Mr. Ramesh Dhara
              Mr. Gourav Banerji
                                                ...for the petitioner
              Mr. Amit Kumar Nag,
              Mr. Parth Banerjee
              Ms. Rishita Sarkar.

                             ...for the OICL (Respondent No. 1 to 5)

              Mr. Sorbananda Syanal
              Mr. Hamidur Rahaman

                         ...for the Private Respondent No.6



                 1. The petitioners seek a writ of certiorari to

                    quash the speaking order dated 21.01.2026

                    passed by the competent authority being the

                    respondent no. 4 herein. The impugned order

                    confirms the revocation of approval for the

                    reconstitution    of   the   partnership   firm   in

                    respect of the petitioners' distributorship,

                    primarily on the ground of failure to execute

                    the formal distributorship agreement.

                 2. The petitioners in the instant case prays inter

                    alia, for the following reliefs:

                       "a) Declaration declaring Clause 3.17.12 of
                       Guideline of May 202 of Indian Oil
                       corporation Limited, being contrary to and
                       dehors the 1932 Act, be declared null and
                       void;

                       b) A writ of and/or in the nature of
                       Mandamus Commanding the respondents
                       IOCL to withdraw and/or rescind and/or
                         2




      cancel the impugned memo dated 22nd
      January 2026, forthwith;

      c) A Writ of and/or in the nature of
      Certiorari calling upon the respondents
      IOCL and each of them to certify and
      transmit   the   records     of  the   case
      culminating in impugned memo dated 22nd
      January 2026, so that upon perusal
      thereof, conscionable justice may be
      rendered to the petitioners by quashing the
      same:

      d) A Writ of and/or in the nature of
      Prohibition, prohibiting the IOCL authority
      from giving any effect and/or further effect
      to the impugned memo dated 22nd January
      2026, in any manner whatsoever;

      e) Direction directing the IOCL to conclude
      the reconstitution process in terms of
      approval order dated 21st February 2024,
      forthwith;

      f) Rule N I S I in terms of prayer (a), (b), (c),
      (d) and (e) above and to make the Rule
      absolute if no cause or insufficient cause is
      shown;

      g)   An   interim   order   of   injunction
      restraining the respondent authorities
      from giving any effect and/or further effect
      to the impugned memo dated 22nd January
      2026, in any manner whatsoever;

      h) Stay of operation of the impugned memo
      dated 22nd January 2026;

      i) Ad interim order in terms of prayers (g)
      and (h) above;

      j) costs and incidental arising out of the
      instant petition;

      k) Such other or further order or orders as
      to Your Lordships may deem fit and
      proper."


3. Apropos the facts of the case, it is stated that

   the respondent no. 6 herein is the sole

   proprietor of a firm under the name and style

   of M/s. Begumpur Indane Gramin Vitrak.


4. The licence has been granted by Indian Oil

   Corporation Ltd., being the respondent No. 1
                                   3




   herein       by     executing         an     agreement       on

   06.07.2020           for           running      the        LPG

   distributorship           business.        However,        upon

   facing several problems in operating the same,

   mainly        due         to       financial    constraints,

   respondent No. 6 submitted a representation

   to respondent No. 1 on 06.10.2023 seeking

   reconstitution of the said business from a

   proprietorship to a partnership by inducting

   petitioner Nos. 2 to 4 as partners in the said

   LPG distributorship business.

5. Thereafter,         the        representation         of    the

   respondent No. 6 has been considered by the

   respondent No. 1 at a meeting held on

   17.01.2024 wherein the respondent No. 6

   expressed her willingness to continue running

   the said LPG business and requested the

   officials of the respondent No. 1 to induct the

   petitioner Nos. 2 and 4 as partners for the

   smooth running of the business.

6. Accordingly, a proposed partnership deed has

   been executed amongst the petitioner Nos. 2

   to 4 and the respondent No. 6 along with an

   affidavit.

7. The respondent No. 6 also executed an

   affidavit stating her willingness to induct the

   petitioner Nos. 2 to 4 as partners, declaring

   inter alia, that she has no objection to

   respondent No. 1 permitting of the said LPG
                             4




  distributorship firm from proprietorship to

  partnership.

8. The     reconstitution        of     the     said     LPG

  Distributorship business from a proprietorship

  to partnership has been approved on 21st

  February 2024.

9. Thereafter, respondent No. 1 requested the

  respondent No. 6 to submit the relevant

  documents        for   completing           reconstitution

  process and accordingly, the said documents

  have been submitted.

10.        For the purpose of reconstitution, the

  relevant      statutory       licences      required    for

  running the said business has also been duly

  obtained from the respective authorities in the

  name of the partnership firm on 13.03.2025

  valid upto 31.12.2025, after cancelling the

  proprietorship licence standing in the name of

  respondent No. 6. By virtue of the licences so

  granted, the respondent No. 1 permitted the

  continuance of the said LPG distributorship

  on a partnership basis and continued to

  supply LPG cylinders to the petitioners.

11.        On    11th    June         2025,     during   the

  pendency of the reconstitution, the husband of

  the respondent No. 6 lodged a complaint

  before     the   concerned           police    authorities

  regarding shortage of cylinders from the LPG

  godown. Cognizance has been taken pursuant
                              5




  to the order of this court dated 15th July 2025

  passed in WPA No. 13845 of 2025.

12.        Thereafter, on 26th August 2025, the

  respondent           No.   1   suspended       the      LPG

  distributorship on the ground of expiry of the

  statutory licence granted in favour of the

  proprietorship firm.

13.        The respondent No. 1, by a Memo dated

  19th November 2025 revoked the in-principal

  approval       for    reconstitution    for    the      LPG

  distributorship by invoking clause 3.17.12 of

  the guidelines of the respondent No. 1 of May

  2022 without affording any opportunity of

  hearing to the petitioner.

14.        The    petitioners       contend      that      the

  reconstitution         approval    order      dated     21st

  February 2024 has been revoked by a Memo

  dated 19th January, 2025 which has been

  confirmed by an Order dated 22nd January,

  2026 and the same is arbitrary and perverse

  having been passed without proper application

  of mind.

15.        The    respondent        No.   1     has      acted

  arbitrarily without giving any cogent reason,

  despite having approved the induction of

  petitioner Nos. 2 to 4 as partners of petitioner

  No. 1.

16.        The     petitioner       submit       that,      in

  compliance with the in-principal letter dated
                         6




  21.02.2024, all relevant documents have been

  submitted     to   complete      the    reconstitution

  process.

17.       Despite submission of such relevant

  documents,     respondent        No.    6,   being   the

  erstwhile proprietor of the firm, refused to sign

  the distributorship agreement pursuant to the

  revised reconstitution. The petitioner submits

  that until the date of the order of suspension,

  the respondent No. 1 continued to supply LPG

  cylinders to the petitioners.

18.       The petitioner submits that by virtue of

  the order of approval dated 21st February

  2025, a right has been accrued in favour of

  the petitioners to run the LPG distributorship

  business, since all the statutory licences have

  been issued in the name of the partnership

  firm.

19.       It is submitted that an order of approval

  can be cancelled or withdrawn only in a case

  where a partner of the partnership firm makes

  any     misrepresentation       or    suppresses     any

  material facts with regard to the reconstitution

  of the LPG distributorship from proprietorship

  to partnership. In the instant case, no such

  occasion      arose       for        suppression      or

  misrepresentation of any fact arose and hence

  there exists no ground for cancellation of the

  order of approval.
                             7




20.     The petitioners submit that the minutes

  dated 15.01.2026 being Annexure "P-21" at

  page 165, Clause 8, paragraph 4 (H, I and K),

  demonstrate        that       none   of      the    licences

  submitted before the respondent No. 1 have

  been reverted back to the proprietorship firm.

  The clause H, I and K are reproduced below:

      "h)   Kabita    Mandal was            asked     by   the
      corporation to clearly specify whether her
      claims         towards           submission           of
      reconstitution requiest earlier was out of
      ignorance      which       has   informed       in   her
      earlier letter or due to back mailing which
      she is presenting in this meeting. No firm
      response    was       provided     by     Ms.    Kabita
      Mandal to this question.
      i) Ms. Kabita Mandal had complained to
      IOCL as well as enforcement authorities
      regarding alleged theft of cylinders from
      her distributorship godown by Mr. Nimai
      Mondal, Mr. Mahamaya Kabiraj & Mr.
      Pashupati Mondal. The incoming parters in
      this context submitted the court order
      dated 03.12.2025 reg: GR-3212/2025 by
      AJM, Lalbagh Murshidabad for dismissal of
      the   accused     in      this   case.    Ms.    Kabita
      Mandal further submitted that she has
      appealed to higher court against this order
      of Lalbagh court.
      k) Ms. Kabita Mandal was asked about the
      status of conversion of various licences
      following issued of IOCL's letter dated
      19.11.2025       revoking         the      in-principle
      approval to reconstitution to which she
      replied that none of the licences have been
      reverted yet. Finally, both parties were
      asked to give their final submissions to
      which they repeated the above points."
                           8




21.        The Learned Counsel appearing for the

  respondent No. 1 vehemently opposes the

  contention of the petitioners and submits that,

  till the date of the order of suspension no LPG

  cylinders     have      been     supplied     to     the

  partnership firm. The order of suspension has

  been issued in the name of the proprietorship

  firm instead of the partnership firm.

22.        It is further submitted that since the

  reconstitution has not been completed by

  execution of the distributorship agreement,

  the impugned order does not suffer from any

  infirmity and is a well reasoned speaking

  order. The clause 3.17.12 of the reconstitution

  policy (May 2022) clearly envisages that unless

  the new distributorship agreement is signed,

  respondent No. 1 can cancel the in-principal

  letter and forfeit the application fees. The

  extracts     of   the   clause    3.17.12      of    the

  reconstitution policy is reproduced below:-

      i)   "Cases   where     in-Principle    letter   for

      reconstitution is issued by OMC and new

      Distributorship agreement is not signed, the

      IMC may agree to accept request from

      signatories of the existing distributorship

      agreement to cancel the In-Principle letter

      aid for felt the application fees, if any.

      Changes made in statutory licenses shall be
                             9




      reverted back and the proprietor/partner(s)

      shall indemnity the OMC against any claims

      or demands."

      ii) "By virtue of the said clause in-principal
      approval dated 21.02.2024 has been revoked
      and the reconstitution process has been
      cancelled by imposing a penalty to the tune
      of Rs. 12,13,289.2 for equipment shortages
      and irregularities."


23.       It is submitted by the petitioners that all

  substantial requirements have been fulfilled

  for the reconstitution of the firm as per the

  guidelines dated 9.6.2020.

24.       The failure to sign the distributorship

  agreement is attributable to the unwillingness

  of respondent No. 6, being the original license

  holder to complete the reconstitution process.

25.       The revocation is the disproportionate to

  the alleged lapse. The petitioners submit that

  mere delay in signing a document should not

  lead to the civil death of the business. It is

  further       contended       that    the      competent

  authority, while passing the speaking order in

  pursuant to the earlier directions given by the

  Coordinate Bench of this Court failed to

  consider and appreciate the merits of the

  petitioners' explanation.

26.       Per     contra,       the    learned     counsel

  appearing for the respondent/oil company

  submits        that   the       execution       of   the
                              10




   distributorship agreement is a mandatory

   condition precedent for the recognition of any

   reconstituted partnership.

27.       Under        the        policy,     approvals       for

   reconstitution      are        conditional.      Failure    to

   execute the distributorship agreement within

   the    stipulated     period       leads    to    automatic

   lapse/revocation, as per Clause 3.17.12 of the

   guidelines dated May 2022. It is expressly

   provided    that     if    the      new    distributorship

   agreement is not signed, the OMC may agree

   to accept request from signatories of the

   existing distributorship agreement to cancel

   the    in   principle          letter    and     forfeit   the

   application fees, by the reverting the statutory

   licenses in favour of the original license

   holder. The respondent submits that multiple

   reminders      have       been      sent    both     to    the

   petitioners and the private respondent, but the

   same        remained              unheeded,          thereby

   necessitating the revocation to protect the

   commercial interest of the corporation. The

   learned counsel appearing for the respondent

   no. 1 to 5 relies upon the following judgments-

   Tata Cellular-vs- Union of India reported in

   (1994) 6 SCC 651-

   "73. Observance of judicial restraint is currently the
mood in England. The judicial power of review is
exercised to rein in any unbridled executive functioning.
The restraint has two contemporary manifestations.
                           11




One is the ambit of judicial intervention; the other
covers the scope of the court's ability to quash an
administrative decision on its merits. These restraints
bear   the    hallmarks       of     judicial     control     over
administrative action.
   74. Judicial review is concerned with reviewing not
the merits of the decision in support of which the
application for judicial review is made, but the decision-
making process itself.
   75. In Chief   Constable          of    the    North      Wales
Police v. Evans [(1982)   3    All        ER   141,   154]    Lord
Brightman said:
       "Judicial review, as the words imply, is not an
   appeal from a decision, but a review of the manner
   in which the decision was made.
                              ***

Judicial review is concerned, not with the decision, but with the decision-making process. Unless that restriction on the power of the court is observed, the court will in my view, under the guise of preventing the abuse of power, be itself guilty of usurping power."

In the same case Lord Hailsham commented on the purpose of the remedy by way of judicial review under RSC, Ord. 53 in the following terms:

"This remedy, vastly increased in extent, and rendered, over a long period in recent years, of infinitely more convenient access than that provided by the old prerogative writs and actions for a declaration, is intended to protect the individual against the abuse of power by a wide range of authorities, judicial, quasi-judicial, and, as would originally have been thought when I first practised at the Bar, administrative. It is not intended to take away from those authorities the powers and discretions properly vested in them by law and to substitute the courts as the bodies making the decisions. It is intended to see that the relevant authorities use their powers in a proper manner (p. 1160)."
12

In R. v. Panel on Take-overs and Mergers, ex p Datafin plc [(1987) 1 All ER 564] , Sir John Donaldson, M.R. commented:

"An application for judicial review is not an appeal."

In Lonrho plc v. Secretary of State for Trade and Industry [(1989) 2 All ER 609] , Lord Keith said:

"Judicial review is a protection and not a weapon."

It is thus different from an appeal. When hearing an appeal the Court is concerned with the merits of the decision under appeal. In Amin, Re [Amin v. Entry Clearance Officer, (1983) 2 All ER 864] , Lord Fraser observed that:

"Judicial review is concerned not with the merits of a decision but with the manner in which the decision was made.... Judicial review is entirely different from an ordinary appeal. It is made effective by the court quashing the administrative decision without substituting its own decision, and is to be contrasted with an appeal where the appellate tribunal substitutes its own decision on the merits for that of the administrative officer."

76. In R. v. Panel on Take-overs and Mergers, ex p in Guinness plc [(1990) 1 QB 146 : (1989) 1 All ER 509] , Lord Donaldson, M.R. referred to the judicial review jurisdiction as being supervisory or 'longstop' jurisdiction. Unless that restriction on the power of the court is observed, the court will, under the guise of preventing the abuse of power, be itself guilty of usurping power.

77. The duty of the court is to confine itself to the question of legality. Its concern should be:

1. Whether a decision-making authority exceeded its powers?
2. Committed an error of law,
3. committed a breach of the rules of natural justice,
4. reached a decision which no reasonable tribunal would have reached or, 13
5. abused its powers.

Therefore, it is not for the court to determine whether a particular policy or particular decision taken in the fulfilment of that policy is fair. It is only concerned with the manner in which those decisions have been taken. The extent of the duty to act fairly will vary from case to case. Shortly put, the grounds upon which an administrative action is subject to control by judicial review can be classified as under:

(i) Illegality : This means the decision-maker must understand correctly the law that regulates his decision-making power and must give effect to it.
(ii) Irrationality, namely, Wednesbury unreasonableness.
(iii) Procedural impropriety.

The above are only the broad grounds but it does not rule out addition of further grounds in course of time. As a matter of fact, in R. v. Secretary of State for the Home Department, ex Brind [(1991) 1 AC 696] , Lord Diplock refers specifically to one development, namely, the possible recognition of the principle of proportionality. In all these cases the test to be adopted is that the court should, "consider whether something has gone wrong of a nature and degree which requires its intervention".

Balco Employees' Union (Regd.) -vs- Union of India & Ors. (2002) 2 SCC 33-

"57. Even though the employees of the company may have an interest in seeing as to how the Company is managed, it will not be possible to accept the contentions that in the process of disinvestment, the principles of natural justice would be applicable and that the workers, or for that matter any other party having an interest therein, would have a right of being heard. As a matter of good governance and administration whenever such policy decisions are taken, it is desirable that there should be wide range of consultations including considering any representations which may have been filed, but there is no provision in law which would require a hearing to be 14 granted before taking a policy decision. In exercise of executive powers, policy decisions have to be taken from time to time. It will be impossible and impracticable to give a formal hearing to those who may be affected whenever a policy decision is taken. One of the objects of giving a hearing in application of the principles of natural justice is to see that an illegal action or decision does not take place. Any wrong order may adversely affect a person and it is essentially for this reason that a reasonable opportunity may have to be granted before passing of an administrative order. In case of the policy decision, however, it is impracticable, and at times against the public interest, to do so, but this does not mean that a policy decision which is contrary to law cannot be challenged. Not giving the workmen an opportunity of being heard cannot per se be a ground of vitiating the decision. If the decision is otherwise illegal as being contrary to law or any constitutional provision, the persons affected like the workmen, can impugn the same, but not giving a predecisional hearing cannot be a ground for quashing the decision."

28. The learned counsel appearing for the respondent no. 6 submits that she has been coerced into signing documents relating to reconstitution and conversion of statutory licenses. It is further submitted that, without her consent and taking advantage of her ignorance, the petitioners being caretakers of the proprietorship firm blackmailed and compelled her to sign the relevant documents submitted before the competent authority for reconstitution. It has been further submitted that the petitioners have also been involved in theft of LPG Cylinders from the godown, in 15 respect of which a complaint has been lodged and criminal cases has been initiated against the petitioners. The learned counsel appearing for the respondent no.6 relies upon the judgment State of UP & Ors. Vs. Bridge and Roof Co. (India) Ltd. Reported in (1996) 6 SCC 22 on the proposition of dismissal of writ petition on the ground of availability of effective alternative remedy wherein it has been held that the contract between the parties not being a statutory contract is in the realm of private law.

In M/S Bimala Gas Services & Anr. Vs. Indian Oil Corporation Limited (WPA/12206W/2014) the Hon'ble Coordinate Bench was pleased to hold in this case that reconstitution is a conditional process subject to strict adherence to Oil Marketing Company (OMC) guidelines, including verification of documents, eligibility of partners and previous written approval for any changes from the sole proprietor for entering into the distributorship license.

In Monmohan Dutta & Anr. Vs. Bharat Petroleum Corporation Ltd & Ors. Reported in 2023 SCC Online Cal 2225-

"28. For the reasons as aforesaid this Court is of the considered view that a writ of mandamus cannot be issued directing BPCL to renew the LPG distributorship agreement 16 on the signature of the appellants alone. The appellants do not have any right to carry on the distributorship business to the exclusion of the 9th respondent. BPCL cannot be directed to continue its supplies in the absence of a valid distributorship agreement. In view thereof this Court holds that BPCL was justified in issuing the letter dated 26.09.2022 to suspend supplied to the distributorship."

29. In this context, the petitioners vehemently opposes the same and submit that in respect of the allegations made by respondent No. 6 regarding coercion/blackmail, no FIR or criminal case alleging such coercion or blackmail have been filed by the respondent no. 6 against such alleged offences.

30. In conspectus of the above adumbrated herein, I find that the decision in the impugned order dated 21.01.2026 taken by the respondent no. 4 is a well reasoned speaking order and does not suffer from any infirmity. The petitioners have already invoked the arbitration clause as embodied in the Reconstitution Policy of LPG distribution.

31. The court does not sit as a court of appeal to apprise evidence or substitute its own opinion for that of the administrative authority. The role of the court is limited to 17 examine the decision making process and not the merits of the decisions.

32. The scope of the judicial review in the present matter is circumscribed, inasmuch as the issues involve complex questions of policy and technical considerations pertaining to the grant of LPG distributorship. However, it is trite law that judicial review is not ousted where the action of the State is arbitrary, irrational, or in violation of the principles of natural justice.

33. The petitioners challenge to the order of confirming the revocation of the in-principal approval, is premature. The reconstitution of the firm from a proprietorship to a partnership has not attained finality since the revised distributorship agreement remains unexecuted. Although the names of the partners have been incorporated in the requisite statutory licences submitted for the purpose of reconstitution, the licences continued to stand in the name of the proprietorship of Respondent No. 6.

34. Having heard the parties and upon careful perusal of records, this court is of the considered view that the competent authority has rightly exercised its discretion in confirming the revocation of the in-principal approval by way of a speaking order. The 18 petitioners have failed to adhere to the stipulated timeline despite multiple reminders issued by the respondent corporation.

35. In view of the above the Writ Petition being WPA No. 4012 of 2026 is dismissed. No order as to costs.

36. Urgent photostat certified copy of this order, if applied for, be given to the learned counsel for the parties on usual undertakings.

(Smita Das De, J.)