The Lahore High Court has ruled that an intra-court appeal cannot be filed in public procurement disputes when the Punjab Public Procurement Regulatory Authority Rules already provide a complete statutory review mechanism. A two-member bench comprising Justice Chaudhry Sultan Mahmood and Justice Malik Muhammad Owais Khalid delivered the judgment while deciding an appeal filed by a private company.
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The case arose after the Punjab Health Department invited electronic tenders for the procurement of medical equipment, surgical disposables, implants and sutures for the 2025-26 financial year. Following the technical evaluation process, the Technical Evaluation Committee declared several companies technically non-responsive, a decision later upheld by the Grievance Redressal Committee.
The affected companies then approached the Managing Director of the Punjab Public Procurement Regulatory Authority under Rule 67-A of the Punjab Procurement Rules 2014. After reviewing the matter, the managing director overturned the earlier decisions, declared the companies technically qualified and directed that the procurement process continue according to the law.
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Later, a constitutional petition challenging the managing director’s decision was dismissed by a single bench of the Lahore High Court, prompting the petitioner to file an intra-court appeal. However, the division bench held that the forums established under Rules 67 and 67-A possess full legal authority to review, modify, uphold or overturn decisions made during the procurement process.
Furthermore, the court ruled that the managing director’s decision forms part of the statutory review process instead of being an original order, making Section 3(2) of the Law Reforms Ordinance, 1972 applicable. Referring to Supreme Court precedents, the bench concluded that where a special law provides a complete legal remedy, an intra-court appeal is unavailable unless the law specifically permits it, and therefore dismissed the appeal as non-maintainable.