Supreme Court Quashes Chhattisgarh Sports Kit Tender Condition, Cites Violation of Article 14 and Doctrine of Level Playing Field
Case Name: Vinishma Technologies Pvt. Ltd. v. State of Chhattisgarh & Anr.
Date of Judgment: October 6, 2025
Citation: 2025 INSC 1182, Civil Appeal Nos. (arising out of SLP (C) Nos. 24075, 26192 & 23611 of 2025)
Bench: Hon’ble Mr. Justice Sanjay Kumar and Hon’ble Mr. Justice Alok Aradhe
Held: The Supreme Court allowed the appeals filed by Vinishma Technologies and struck down a tender condition that restricted eligibility to bidders who had supplied sports goods worth at least ₹6 crore to Chhattisgarh Government agencies in the last three years. The Court held that such a condition was arbitrary, discriminatory, and violative of Articles 14 and 19(1)(g) of the Constitution as it created an artificial barrier, promoted cartelisation, and excluded competent suppliers from outside the State. The Court emphasized the doctrine of “level playing field” as part of Article 19(1)(g), holding that government procurement must encourage wider participation and secure best value for the public exchequer.
Summary: The Department of School Education, Chhattisgarh had issued three tenders in July 2025 worth over ₹39 crore for supply of sports kits to government schools. Vinishma Technologies, which had prior experience in Bihar, Karnataka, Gujarat, and Delhi, challenged the eligibility clause limiting participation only to firms with past supply to Chhattisgarh Government agencies. The High Court dismissed its writ petitions, upholding the clause as reasonable. On appeal, the Supreme Court analyzed jurisprudence from Ramana Dayaram Shetty v. International Airport Authority (1979), Association of Registration Plates v. Union of India (2005), Global Energy v. Adani Exports (2005), Uflex v. Government of Tamil Nadu (2022), and Bharat Forge v. UOI (2022), reiterating that tender terms must be fair, non-arbitrary, and proportionate. It held that restricting competition to past local suppliers lacked rational nexus with the object of timely and quality supply of sports kits, especially since bidders with national experience could ensure delivery by engaging local supply chains. The justification of Maoist-affected areas was rejected as disproportionate because the tender concerned sports kits, not sensitive security equipment.
Decision: The Supreme Court quashed the High Court’s orders dated 11.08.2025 and 12.08.2025 as well as the tender notices of 21.07.2025, directing that fresh tenders may be issued without the impugned restriction. It reaffirmed that State authorities must frame procurement conditions consistent with constitutional guarantees, ensuring fairness, competition, and equality of opportunity.