Rajasthan HC Sets Aside Nakki Lake Boating Tender Over Single-Bid Compliance Lapses

The Hon’ble High Court of Rajasthan, in the case of M/s Ujjain Dreams v. State of Rajasthan & Ors., (2026:RJ-JD:6524), decided on February 17, 2026, ruled that accepting only one qualified bidder without following the required procurement rules invalidated the tender process for boating services at Nakki Lake, Mount Abu.

The petitioner, M/s Ujjain Dreams, challenged the tender outcome after its technical bid was declared non-responsive, and the contract was awarded to respondent no. 4. It was alleged that the rejection was arbitrary, that the successful bidder lacked requisite qualifications, and that the tender was finalized at a price substantially below the base amount in violation of the Rajasthan Transparency in Public Procurement Act, 2012, and Rules, 2013.

On merits, the Court upheld rejection of the petitioner’s bid, finding that the petitioner failed to demonstrate the mandatory three -year’ government or semi-government boating experience required under the tender conditions. The court observed that reliance on a partnership formed shortly prior to bid submission to utilize another entity’s experience certificate did not satisfy eligibility requirements.

However, examining the subsequent tender process, the Court noted that respondent no. 4 remained the sole responsive bidder and that Rule 68 of the 2013 Rules imposed specific obligations in such circumstances, including preparation of a justification note, recording of reasons, assessment of price reasonableness, and consideration of competition-related factors. Upon reviewing internal records, the court found that these safeguards were not complied with, as no justification note was prepared, and the decision to accept the negotiated price was recorded without reasons or financial member inputs. The court further observed that the fixation of elevated base prices despite historically lower accepted bids could discourage participation and undermine statutory principles of competition and transparency.

In view of these deficiencies, the Court held that the decision-making process suffered from arbitrariness and non-compliance with mandatory procurement norms and consequently quashed the tender process and approval of the respondent’s bid.